What is a reasonable time frame for a system to be 'mature enough' to audit?

[Dean P.]

Well, our management has decided that they would like to implement an EMS, because it's the right thing to do.

Now, they have decided that they want to have us registered to ISO-14001 by the end of summer, to ensure our Q1 status by the end of the year. My question to this group is, what is a reasonable time frame for a system to be 'mature enough' to audit? We have a great quality system, so I feel that I can have all procedures, programs, and systems documented and in place by June, and we could then have our internal audit in July, followed by our Management Review. Is this enough time for 3rd party auditors to evaluate the effectiveness of our system, even though it will only have been in action for less than 3 months? Or will they stick to verifying compliance of our procedures to the standard, and check effectiveness on the next audit? I have a meeting with our registrar next week but I wanted to know the thoughts of this group first.

I appreciate any and all comments.

 

[Sporty]

That's the way it was done here, we had the procedures in place and one internal audit and management review prior to our readiness review.....with the registration audit about one month after that.
Our first surveillance is WEDNESDAY!
With dedication from Management, you should be ok, at least in my opinion.

 

[Randy]

Dean,

When I do an audit I look for a complete cycle of the system...Internal Audit of all elements, C & P actions, a management review, employee awareness and all the other required rubbish to be in place and operating.

Is the system established? Yes No

Is there proof of management committment? Yes No

Is a policy in place tha is relevent to the org? Yes No

Are the required procedures, documents and other neat thjins in place? Yes No

Are aspects and significant aspects id'd w/ objectives and targets? Yes No

So on and so forth.........

You should receive from your registrar a basic checklist to perform your own pre-assessment with. If they don't or won't give you one make one up. I think Marc still has an audit matrix on his free stuff that I did. If so, feel free to use it. If you feel really free send cash

If you need consulting help give a shout. Right now I'm like a cheap lady of the evening 2 days before payday outside an Army fort.

Good luck

 

[tomvehoski]

Much will depend on your environmental impacts. If they are simple and you don't have any hazardous materials to worry about things will be easier. General manufacturing is not too bad - you have some oils, solvents, coolants, etc., but nothing too bad. I am working with a paint manufacturer now - they have many nasty chemicals to worry about, reporting, spill control and many other impacts to worry about.

Biggest thing is to identify all of your aspects and develop plans for each one you choose to work on. Even if the system is new and plans are not fully implemented they should still give you credit.

Tom

 

[Randy]

With all due respect Tom it doesn't matter if you have 10 zillion gallons of Trichloromethylethyldeath or 1 ounce of Isopropyl, the requirements are the same. ID your aspects, determine which ones are significant and then you " SHALL CONSIDER" (not an absolute here) them when establishing environmental objectives and targets.

Oh by the way Aspects are NEUTRAL. They go far beyond hazardous materials and waste and all that gooey stuff. What you have and how much you have quite honestly should have no bearing on your implementation time line. If you let your Aspects dictate your time line get professional help, because your starting to get lost in the fog.

The biggest thing is to have a plan that everybody buys into and then DO IT!!!! A little snag here or there, no biggy. Keep to your schedule!!

 

[tomvehoski]

I must disagree that level of impacts will not affect the amount of work required to get the EMS done. For example, assume you have a 1000 gallon tank of MEK (or any other nasty stuff). Now you must know:

1. What local, state, and federal regulations apply to MEK?
2. Am I complying with those regulations?
3. What agency do I have to tell if I spill 1 oz? 1 gal? 100 gal? ...
4. Do I have to do air emission reporting?
5. What is my emergency response plan if I spill MEK?
6. I have to train people in handling MEK.
7. I have to have work instructions for handling, storing MEK.
8. Do I need special equipment to handle, store MEK?
9. How does MEK in my product affect my customers?

Hopefully most companies that handle hazardous substances already know the above, but I know many don't. I did a brief baseline assessment on a welding company this week. I saw many impacts that violate MI regulations. Before they can become 14001, they are going to have to do some major organization and build some infrastructure to prevent spills. They are not yet sure if they are required to report certain things. If those 55 gallon drums just had water in them, it would not be a problem.

My assembly client had one environmental work instruction - a summary of the entire system on two pages to let them know the location of recycling bins, responsibilities, etc. The emergency plan was simple and deals with fire, tornado and snow emergencies. Procedures were minimal. System was in place and registered in about four months.

My paint manufacturer has 50+ instructions for handling the various substances they deal with. About 10 pages with EPA, DEQ, fire, police, hospital and other contact information. Their emergency plan outlines every chemical, amounts, tools for cleanup, storage locations, quantities, etc. It is distributed to the local fire department, the MI DEQ, local hospitals and in a storage box on the front lawn so that if the fire department must respond, they know exactly what is in the building and where. 18+ months for implementation, even though much was already in place before 14001 formally began.

I agree buy in and commitment will play a big part, but every significant impact you have generates many more things you need to do. 14001 in addition to requiring you analyze your impacts requires you comply with regulations (4.5.1) - this is where a lot of the extra work can come in.

 

[Dean P.]

I think Tom is implying that, having many hazardous chemicals in house will create the need for spill response plans, emergency plans, etc. as they fall under 4.4.7. These items, however, generally fall under regulatory compliance issues, so we must have these plans in place whether or not we choose to go ISO-14001. Fortunately, our company has been very proactive in this regard, so we have our response plans basically complete.

Now, taking that out of the picture, I don't think the level of hazardous materials will impact our assessment of aspects and impacts, or the setting of objectives and targets. Whether we use MEK or water, we still go through the same evaluation process.

I agree that not having the haz material handing issues identified would add to our timeline, but since they are legal compliance issues means that we should have had them in the first place.

Thanks for the reponses!!!

 

[Randy]

Tom,

I'm not sure if you're a Safety & Environmental professional or someone who is dabbling around with environmental issues. If you have a client, or whatever like you talked about above that has waited on thier 14K program to comply with the law then there's a problem in "River City".

All that compliance stuff like air & water discharge permits, EPA Hazardous Waste #'s, required OSHA training along the lines of 29CFR 1910.1200 (Actually all of subpart Z), 1910.120, 1910 Subpart I, and of course the stuff from 40CFR 260-265 and other applicable reg's, had better be in place now, not after implementation. There may be some DOT issues as well if you are moving 1K gallons of MEK.

The problem with non-professionals in the EHS field is they get wrapped around the axle over trivia and never get to the meat. If you're going to give advice about environmental & safety issues make sure you have more background than an EMS auditors course and some light hearted safety training.

One thing I do is openly let people unashamably know my credentials so as to lend credence to what advice I give. My clients know that they are trusting in someone who has been there in actuallity and not in theory.

Utilizing the methods you seem to be using or refering to, I'd have my client get his lawyer on stand-by because what you alluded to is mandatory not voluntary.

 

[db]

Dealing with aspects

Quote from Randy:
------------------------------------
“If you need consulting help give a shout. Right now I'm like a cheap lady of the evening 2 days before payday outside an Army fort.”
-----------------------------------
You hussy! (let's see would you be an aspect, or impact?)

Actually, I agree with your comment that the volume of nasties does not change the requirements. I have worked with large corporations that have bunches of permits, and the ability to wipe out small communities. I have also worked with small mom and pop shops that are straight forward manufacturing that have very little, if any, nasty stuff (excluding the leftovers in the lunchroom fridge). The requirements are the same, but the amount of effort to identify the aspects, set O&T, and establish programs is far different. I think, if I read his posts correctly, that is what Tom was saying.

The problem might not be the aspects, themselves, but the other things that result from the "SHALL CONSIDER". The more aspects, not quantity of each but total quantity of aspects might affect the timeline. In the two instances I mentioned. Just one building of the larger company might have more aspects than the entire operation of the smaller. It would naturally take longer to identify, consider and act on them.

As far as aspects being neutral, yeah. I often say that aspects are things we move, store, use, spill and/or discard. By themselves, they are quite neutral. Marilyn Block has an excellent book called “Identifying Environmental Aspects and Impacts” [ISBN 0-87389-446-4, published by Quality Press (ASQ)].

One thing I disagree with (most folks tell me I’m wrong) is based on ISO 14001, a company can have a permitted situations (air/water discharge, whatever) and not classify it as “significant” and not have any O&T, or programs. It seems to me that if an aspect is legally regulated it should be automatically regulated. I would be really interested in what you guys (non-gender specific language) think on that.

 

[tomvehoski]

DB is right in what I am trying to say. Requirements are the same no matter what you do. Time needed to evaluate and implement everthing to meet those requirements will vary based on the complexity of the system. Same with any other system - if I make one part, I do one FMEA, PPAP, and control plan. If I make 100 different parts multiply the time by 100.

My MEK examply was hypothetical, but I do run into many companies that do not know if they are complying with regulations or not. Real life examples:

1. Outside used oil storage tank, no secondary containment, no protection against vandalism.

2. 55 gallon barrels of oil based paint, stored outside, in snow banks, some spillage, no containment.

They are not big enough to be noticed or have not had problems, therefore they have not been visited by any external agency. For many of these companies the first time an outsider looks at their system it will be the 14001 auditor.