Significant environmental aspects for rubber printer roller production process

[Randy]

I'm not saying that anything can be disregarded, I'm stating if the determination criteria and methodology do not identify significance it doesn't matter what the aspect is...

In the San Grabiel Valley is a large plume of perchlorate contaminated water. There is a company that is part of the EPA's remediation program and is paying annually to clean the water. When they put together their EMS...registered initially by Intertek...the criteria and methodology they used for aspect significance determination did not identify the perchlorate plume as a significant aspect (they had been one of the major contributors to its generation). Why? Because through their process they identified that everything that could be done was being done, and it was being controlled. The criteria they used gave perchlorate contaminated water a lower score than the utilization of electricity and the generation of solid waste. The electricity they were using was contributing to tons of air emissions being generated and thousands of barrels of oil being burned to generate it. The trash was contributing to the continuing burden of landfilling in LA County. These were aspects of significant environmental impact based on the established criteria and methodology.

What has been stated by everyone about all the science, chemistry, legal jumbo and references to ANAB decisions (which btw matter not one bit to an organization not subject to ANAB grumblings and wishing to just self declare) castrates the essence of 4.3.1 and that is for an organization to be able to take all things into consideration, determine those of what it decides to be of greater value such as legal, controllability, views of parties, potential environmental effect, influence or any number of others and through its own logic differentiate one from another. This doen't mean an organization can ignore a polluting activity, but if it (the activity) is already governed by identified law and processes are in place controlling it and nothing else can be done about it why must it be identified as significant over something that has no legal requirements and controls that also may directly or indirectly impact the environment? The 4.3.1 process allows organizations to look beyond the law and science and seek environmental performance improvement in areas not being managed through traditional concepts and schemes.

4.3.1 is not about the law, it is not about science, it is about identifying and managing environmental impact (or at least it helps to initiate the process)

 

[Sidney Vianna]

...the criteria and methodology they used for aspect significance determination did not identify the perchlorate plume as a significant aspect (they had been one of the major contributors to its generation). Why? Because through their process they identified that everything that could be done was being done, and it was being controlled.

Isn't that the essence of determining significant aspects? So you ensure that operational controls are in place? So, in this case, the perchlorate contamination might not be managed as part of the EMS, ie, O&T's, CA's, etc.... If they are indeed doing all that could be done, in terms of controlling this aspect and perchlorate has a high environmental impact, what would have been the problem identifying it as a significant aspect? They are, as you saying, already controlling it. Doing all they can do about it. By leaving it outside of the significant aspects list, then you might have less oversight over that aspect. I understand your reasoning, but do not agree with it.

 

[Randy]

If they are indeed doing all that could be done, in terms of controlling this aspect and perchlorate has a high environmental impact, what would have been the problem identifying it as a significant aspect?

There's no problem

1st...it's just that the criteria and methodology used didn't identify it as significant

2nd....they had no real control and no potential of control or influence (one of the criteria) because it was being managed by a consent decree

 

[Paul Simpson]

Getting there ?

Taking Randy's example I think this gives a good example of why we have such vastly different posts when I think the principles are not that far apart.

In the San Grabiel Valley is a large plume of perchlorate contaminated water. There is a company that is part of the EPA's remediation program and is paying annually to clean the water.

Describes the current state well. The company is polluting and this state has been accepted by the regulatory authority.

When they put together their EMS...registered initially by Intertek...the criteria and methodology they used for aspect significance determination did not identify the perchlorate plume as a significant aspect (they had been one of the major contributors to its generation).

In my opinion this aspect should still have been identified as significant - I'll explain below.

Why? Because through their process they identified that everything that could be done was being done, and it was being controlled. The criteria they used gave perchlorate contaminated water a lower score than the utilization of electricity and the generation of solid waste. The electricity they were using was contributing to tons of air emissions being generated and thousands of barrels of oil being burned to generate it. The trash was contributing to the continuing burden of landfilling in LA County. These were aspects of significant environmental impact based on the established criteria and methodology.

This is where the significance issue comes in.

• Yes waste to landfill is significant in this instance - it is a pollutant and it creates problems. The company were managing waste prior to the EMS (presumably).
• Similarly with energy. As Randy has explained energy usage impacts on the environment through use of fossil fuels and emissions to atmosphere. At the time of applying for an EMS the company were managing usage.
• So for both of the above the company has evaluated this aspect as significant - why not emissions to water - it satisfies the same criteria?

The issue in the above example seems to be the cost to do something about it. I reject this as a determination of significance.

The cost may mean it is prohibitive to deal with some of the company's significant aspects - it doesn't make them insignificant.

What has been stated by everyone about all the science, chemistry, legal jumbo and references to ANAB decisions (which btw matter not one bit to an organization not subject to ANAB grumblings and wishing to just self declare) castrates the essence of 4.3.1 and that is for an organization to be able to take all things into consideration, determine those of what it decides to be of greater value such as legal, controllability, views of parties, potential environmental effect, influence or any number of others and through its own logic differentiate one from another. This doen't mean an organization can ignore a polluting activity, but if it (the activity) is already governed by identified law and processes are in place controlling it and nothing else can be done about it why must it be identified as significant over something that has no legal requirements and controls that also may directly or indirectly impact the environment? The 4.3.1 process allows organizations to look beyond the law and science and seek environmental performance improvement in areas not being managed through traditional concepts and schemes.

4.3.1 is not about the law, it is not about science, it is about identifying and managing environmental impact (or at least it helps to initiate the process)

EMS is about the law, it is about the chemistry / science.

The "legal jumbo" you talk about is in place because some (hopefully a very few these days) feel they are above the law and can pollute to line their pockets, hence governments apply the science and produce the laws.

The point is not that you have to take only the aspects that are governed by legislation or where there is scientific evidence that the results of the process adversely impact on the environment. The point is that the company must understand its processes before it can evaluate aspect significance. To recommend otherwise on this Forum sews an element of doubt in readers minds and devalues ISO 14001 registration.

I take the point about ANAB but the reason ANAB, IAF and other bodies get involved is that already ISO 14001 registration is being attacked as being meaningless for the environment. They, and all like minded people want it to mean something. In the same way that ISO 9001 registration should say something about the quality of a product you buy from a registered firm.

 

[Randy]

Looks like it's time for me to stop trying to sell snow to Eskimo's I guess and for me to seek another career because I have apparently been leading folks down the wrong path.

I really thought that an organization could use out-of-the-box thinking and creativity and incorporate them into the EMS implementation process but it appears I was mistaken. Apparently the only valid approach is that of a myoptic, diminished perrifial vision process of determining significance...oh yeah I remember...TUNOPIA!

Ya'll realize of course I just had an attack of smart asz and couldn't fight it off don't ya? :mybad: My medication isn't working.

 

[Sidney Vianna]

Env-enron?

I really thought that an organization could use out-of-the-box thinking and creativity and incorporate them into the EMS implementation process but it appears I was mistaken. Apparently the only valid approach is that of a myoptic, diminished perrifial vision process of determining significance...oh yeah I remember...TUNOPIA!

There is no conflict between innovation and performance, but the goal is not to be innovative. It is to deliver on environmental performance. And don't forget that Ken Lay was lauded more than once as the most innovative CEO in America. We all know now where his out of the box corporate thinking led us to.
Going through some motions should not lead to an ISO 14001 certificate. It should require going through some meaningful motions.

 

[Randy]

Who has the absolute right to determine where performance improvement is to be made and what the improved performance will consist of in an EMS, the organization or outside parties?

 

[Paul Simpson]

Innovation in how you improve, not what.

I really thought that an organization could use out-of-the-box thinking and creativity and incorporate them into the EMS implementation process but it appears I was mistaken.

You're absolutely right to encourage innovation in the organization choosing how to address their significant aspects. I have seen some great ways of involving people in saving waste and energy on audit.

Apparently the only valid approach is that of a myoptic, diminished perrifial vision process of determining significance...oh yeah I remember...TUNOPIA!

Far from myopic what I am trying to encourage is people to be aware of the full picture for environment and then to try and address the biggies first - the old Pareto principle.

It doesn't stop organizations using innovative techniques to address some of the less significant aspects - particularly if it gets involvement of the employees. The peripheral vision bit is being able to see beyond the obvious - not an ability to ignore what is in front of you.

 

[Sidney Vianna]

My turn

Who has the absolute right to determine where performance improvement is to be made and what the improved performance will consist of in an EMS, the organization or outside parties?

The answer to this question: the organization implementing ISO 14001 has the right to determine where performance improvement is to be made, but, and in case of an external certification, the registrar has the absolute responsibility to ensure that the course decided by the organization makes sense from an environmental perspective. Rubber stamping an ineffective EMS and granting it an ISO 14001 certificate should not happen. And many stakeholders are already voicing their discontentment.

ISO 14001 was developed in such a fashion that any type of organization, doing any type of activity, any place on the earth could meet its requirements. The abiguity and abstractness of significance determination was for a specific purpose and that purpose was to not require, demand or extort organiztions to do anything other identify through their means those aspects they deam to be of greater importance than any other. The understanding of SO, SO2, NOX, E=MC2 or anything else is actually irrelevant if they don't want to go down that trail. They can have as many crazy things they want and identify their trash and electricity as the most significant if they so choose. To tell someone they need to be a chemical engineer or scientist and apply those mathmatics involved to adequately identify significant aspects is a falsehood and definitely misleading for a novice an the inexperienced..or anyone else for that matter.It is intended to be a simple process for an important reason...so anybody regardless of literacy, education and scientific background could do it.

I am very surprised with this statement. In this very forum, you expressed, several times, your disagreement with registrars that would hire EMS auditors that had none or very little Environmental specific knowledge. According to your post, you support an ignorant (from an environmental perspective) individual to be granted the authority to determine significance of aspects. It just does not add up. Actually, in my interpretation, it would contravene the requirements of ISO 14001 4.4.2 which requires people to be competent for their functions. Someone (or a group) tasked with the responsibility to determine the criteria to establish significance has a very important (if not fundamental) contribution to the EMS. I would sure hope that these people are not illiterate, uneducated and do have a grasp about the chemical, biological and physical attributes of the products and biproducts present in their EMS.

 

[Helmut Jilling]

Ya'll realize of course I just had an attack of smart asz and couldn't fight it off don't ya? :mybad: My medication isn't working.

Maybe have the doc write ya a stronger prescription, Randy, cuz this time there's a bunch of us regulars that think you're on the short end on this debate...

Have a Merry Christmas, or Kwaanza, or Ramma... or whatever the heck we're s'pose to say this week...