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ISO 9001 and ISO 14001 Together

Both ISO 9001 and ISO 14001 share a lot of common elements, such as document control and corrective actions. The committee that created these standards are working hard to bridge the two standards together. The year 2000 version of ISO 9001 makes more links to ISO 14001 than ever before. Therefore, read the following implementation advice and compare it to an ISO 9000 plan. You will quickly find that both systems can be implemented together to save time and money.

The ISO 9000 standards introduced to business a common approach to implementing a management system. It does not matter whether you are familiar with how to implement ISO 9001. Instead, we shall see that ISO 9001 established the path to implementation for ISO 14001.

Your attention should be focused on the exact nature of your business and the scope of your proposed environmental management system. A small business would have different priorities then a large manufacturer or a medium sized service-based firm. Therefore as we review the steps to implementation we will make notes about how specific businesses would apply each step.

You should also take a moment to assess the need for a documented environmental management system versus the resources available to your company. For example, time will be a critical resource. If there is no pressing demand for an environmental management system and everyone is extremely busy then perhaps implementation can wait or be spread out over a longer timeframe. If you know that you have no additional personnel to assist you then you should look at the possible benefits versus the cost of a qualified consultant.

Suggested Steps to Implementation

The order of the steps can also be changed if that better suits your situation. Some of the steps can be carried out concurrently.

The following steps assume that your company's top management has committed to implementing ISO 14000 and that you have been selected to develop an action plan for implementation. If you are already ISO 9001 registered or seeking registration, you will find a lot of overlap in your tasks.

Step 1: Establish a steering committee of managers to oversee implementation.

The first step in implementing ISO 14001 is perhaps the most critical step. One of the best ways to accomplish this is to form a steering committee of top managers. Such a committee would represent the highest senior officials in your company. The formation of such a committee would have several benefits, the most important would be a demonstration of the commitment to the formation of your environmental management system.

Another key advantage is that such a committee would be able to draft the policy statements needed, also called the level 1 documentation. Not only are these managers the best people to write such policy statements, but by writing the statements themselves, they will be familiar with the environmental management system being created.

It is difficult for a committee to implement a consistent management system. Committees are good for forming policies and overseeing implementation. However, an individual is best for the day-to-day task of implementing the plans of the committee. In this case, the individual would the a management representative.

Task 1-Appoint a Management Representative as implementation leader. Such a person would be identified as the official spokesperson of the program. Such a management representative would be responsible for leading the implementation effort and for serving as liaison to the customers and regulators. Later, this management representative will be your company's liaison to a registrar if your company chooses to become officially registered to the ISO 14001 standard.

The management representative has to be a person with executive level authority and experience in implementing management systems or other similar projects. The management representative is expected to draft an action plan for implementation that the executive committee will approve. This same person is expected to carry out the action plan by assigning tasks to specific people within the company. Therefore, this person must be a leader with clear communication abilities.

Task 2-Begin training your internal auditors. The ISO 14001 standard requires that an internal auditing team be established. This team of auditors will perform several functions during and after implementation. They will perform an initial gap analysis, regular system reviews, and eventually regular internal maintenance audits.

 Task 3-Establish a means to document your environmental management system. ISO 14001 states that your environmental management system has to the documented, implemented, maintained, and communicated to all employees. Therefore a company wide policy will have to the published and placed it strategic locations around your company. However, a company wide policy will not be enough. You need to also establish a documented environmental management system. This can be easily incorporated into an existing management system, such as ISO 9000, or be made into a free-standing management system.

The best way to do this is to use the ISO 9000 system of documentation, namely a three tier system. Level 1 are policy statements on each element of section four in ISO 14001. Level 2 would the standard operating procedures to implement the level 1 policy statements. Level 3 would be work instructions to support the standard operating procedures.

Step 2: Self-evaluation of your company.

Three components of your business must be assessed before you form your action plan for implementation. The first component is an audit of the environmental impacts created by your company activities and products.

Task 1-Conduct an environmental impact audit. Such an audit is usually conducted by an experienced environmental consulting firm. Most cities now have environmental engineering firms available that have extensive experience in these types of audits.

The purpose of an environmental impacts assessment is to select baseline information on your company. This will include the level of current discharges, noise levels, safety violations, employee health issues, and other related topics. The database of information created will be used to set the objectives and targets of your company's environmental management system.

Task 2-Examine your existing management system. The second component to examine is the existing management system at your company. This could range from a non-existent system up to a management system that is so complete and well-documented that compliance with ISO 14001 is very easy to achieve. The purpose of examining your management system as it now exists is to determine how much of the documentation you will need already exists. That means looking at any policy statements, operating procedures, and work instructions already in place. You will have to also evaluate the effectiveness of these documents as they are currently being used.

Part of this assessment would be a gap analysis. A gap analysis is when you compare your company's current system against the requirements of ISO 14001. Such an analysis should be done with an eye towards which processes in your company will need the most attention to bring them into conformance with ISO 14001. It is suggested that you create a checklist of which processes are near conformance and which systems need attention. This information will help prioritize tasks within your action plan.

A gap analysis is traditionally conducted by the internal audit team. In many cases, an outside expert is hired to train the internal audit team. Then, as part of their training, the new internal auditors accompany the expert on a gap analysis. In this way the internal auditors can both gain experience and witness an experienced expert conducting a proper audit.

Task 3-Review all applicable regulations and customer requirements. The third component would be a review of all environmental regulations and customer requirements for your company. This is frequently called a regulatory review. Such a review will provide additional information on what environmental targets need to be achieved.

Element 4.2 of ISO 14001 requires a company to establish a plan for the environmental management system that takes into account the environmental aspects of your company, related legal requirements, and the objectives and targets of your system. The three assessments described above create the information needed to fulfil these planning tasks. In the next chapter, we shall see examples of how this information is collected and used.

Step 3: Write policies for your environmental management system.

Your company needs to establish a firm policy on why it has an environmental management system. Perhaps, it is to meet regulatory requirements, customer requirements, limit liability, or to conserve resources. Whatever reason for establishing an environmental management system it is critical that a company wide environmental policy and supporting set of related policies be established.

Task 1-Write the company-wide environmental policy. Both ISO 14001 and 14004 say that a company-wide environmental policy is the first step in establishing an environmental management system. As discussed before, this policy is the result of a company's self-evaluation. This policy statement should express the reason the company has an environmental management system, its nature, scale, and appropriateness to the environmental impacts created by your company. The company wide policy should state your commitment to continuous improvement and the prevention of pollution. Naturally, you would state that you will comply with regulation and customer requirements related to the environment.

 Task 3-Write the Level I documents for your system. After creating the company wide policy, the steering committee would now draft the level 1 documents and place them in a book to be called the Environmental Management Manual.

Each policy statement should be less than one page in length. Each policy statement should reflect the requirements within each numbered element of section 4 of ISO 14001. To review, the following elements make up section 4 of the standard.

4. 1 Environmental Policy

4.2 Planning

4.2.1 Environmental Aspects

4.2.2 Legal And Other Requirement

4.2.3 Objectives And Targets

4.2.4 Environmental Management Programs

4.3 Implementation And Operation

4.3.1 Structure And Responsibility

4.3.2 Training Awareness And Competence

4.3.3 Communications

4.3.4 Environmental Management System Documentation

4.3.5 Document Control

4.3.6 Operational Control

4.3.7 Emergency Preparedness And Response

4.4 Checking And Corrective Action

4.4.1 Monitoring And Measurement

4.4.2 Non-Conformance And Corrective And Preventive Action

4.4.3 Records

4.4.4 Environmental Management System Audit

4.5 Management Review

For each numbered element of section 4, you should create a checklist of requirements. Then, to write each level 1 document, you explain why your company will comply. For example, under element 4.4.2 the standard says that you have to establish a procedure that defines the responsibilities and authorities for handling and investigating non-conformances. In addition you have to take action to reduce the impact from the non-conformance and initiate both corrective and preventive actions.

Therefore, your level 1 policy would begin by naming the person ultimately responsible for this element. Such as, " the engineering manager shall the responsible for corrective and preventive actions." Then you need to state your company's policy on this part of the requirements. Such as, "A documented system of preventive and corrective actions shall be established and maintained. This system will be initiated whatever a non-conformance is discovered within our operations. Actions shall be taken to reduce the effect of the non-conformance, investigate the root cause of the problem, and actions shall be taken to prevent recurrence."

As you can see, you are almost paraphrasing the requirements. The important point to remember is to accurately describe how your environmental management system operates and the unique character of your company. All of this has to be done with a minimal number of words. Appendix D contains examples of such level 1 documents.

Step 4: Form a written action plan based on management discussions and the baseline audit. Assign specific managers specific tasks. Form a project management timeline.

The assessments carried out in step 2 will create a considerable amount of information. It is up to the steering committee to discuss this information in light of the strategic objectives of establishing an environmental management system. In other words, the steering committee has to first establish a consensus on where the company now stands environmentally. Then they have to develop a vision of where the company should be one, five, and ten years from now.

Task 1-Develop a written implementation action plan. The written action plan should be a combination of the steps needed by the company to achieve conformance with ISO 14001 and to achieve the strategic goals of the company. Thus, the action plan is a description of how the company will first achieve conformance to the ISO 14001 standard and then move towards its own goals and continuous improvement. As mentioned before, it is suggested that the management representative review the assessments and draft the action plan for discussion and approval by the steering committee.

Task 2- Incorporate project management techniques into your action plan. Project management techniques are highly recommended for ISO 14001 implementation efforts. This includes the use of a timeline and a GANTT chart to track each phase of your implementation. You should also constantly monitor the completion of tasks assigned to other personnel. As a task completion date approaches, you should check with the affected people to match their amount of work completed against expected results. Regular meetings to find and eliminate bottlenecks in implementation are also suggested.

Step 5: Revise or create your Environmental Procedures Manual (Level II) to reflect the requirements of ISO 14001.

Once a level 1 document manual is created, you are ready to proceed with the creation of level 2 documents (standard operating procedures). In some companies there will already be existing written procedures. In such a case, you would review these procedures to assure yourself that they conform to ISO 14001. However, most companies will find that they need to write additional procedures or amend existing procedures to achieve compliance with ISO 14001.

In most cases, you can assign the creation of a standard operating procedure to someone in the affected department. The management representative should not write more than one or two procedures, if any. Instead, it is recommended that managers in specific departments write the procedures so that they become more familiar with the new environmental management system. Also, a manager within the affected department will know more about the target process.

Task 1 - Review existing written procedures using flowcharts. In the case of a company with any existing procedures, you will need to review the compliance of these procedures against the requirement of ISO 14001. This can be done by using a check list of compliance items from the standard. You should also draw a flowchart of the flow of the existing procedure. Later that flowchart will be used to further evaluate the draft procedure.

Task 2 - Flowchart processes in need of a written procedure. Your gap analysis might reveal the need for additional written procedures. In such cases, you will need to flowchart the process requiring a procedure. For example, you may find that you need a corrective action procedure. You would follow the activities involved in the current system of reporting and correcting non-conformances. This would be summarized as a flowchart. The flowchart would help you to see where needed action were missing or where confusion occurs in the process.

Task 3 - Review flowcharts to see if the procedures are effective. Once you have reviewed and flowcharted existing and proposed procedures it is time to look at the issue of effectiveness. Many companies have written procedures. However, not all of these procedures are effective. In many cases, the procedure doesn't even make sense. This means that the people performing the process are doing something different then what the procedure says.

Therefore, you need to review your flowcharts with managers, technical experts, and the people performing the procedure. Together you must ask whether the flowchart represents the best way to perform the process. In many cases you will discover that a process can be improved. This could involve fewer operational steps, less paperwork, or more efficient work flows. This can result in higher quality, faster processing, and lower costs.

As you can see, such a review for effectiveness can be profitable to your company. Therefore we strongly suggest this type of review in addition to assessing each procedure for conformance.

Task 4 - Draft the new and revised procedures. Once your team establishes a better process or approves the existing procedure, you can translate the flowcharts into written procedures.

The draft procedures should be presented in a standard format. Based on the lessons learned from ISO 9000, the procedures should be numbered and titled. In addition, they should have a space for the date of approval, authorized signature, revision number, and page number.

Task 5 - Steering Committee approves new procedures. As each procedure is found acceptable in its existing form or is drafted as a new procedure, they should be submitted to the steering committee for approval. There is no need to wait for all procedures to be written. You can approve each document as it is completed. However, you should discuss where procedures might share common activities. For example, the process control procedure may have similar activities as the proper disposal of hazardous chemical procedure. These similarities should be identified and assigned to the same team for co-creation.

The steering committee needs to review each procedure to assure that it conforms to the requirements of ISO 14001. They also need to review each draft procedure for accuracy, sensibility, and applicability. Caution should be exercised to make sure that authorities and functions do not overlap. As each procedure is approved the steering committee should note which requirements of ISO 14001 have now been satisfied. Once all procedures are approved they can then see if all requirements of the standard have been met. New procedures mean that some training has to take place.

Step 6: Select a registrar if you know you are receiving a third-party audit. Second party audits will be conducted by your customers.

While the procedures are being written, other activities of implementation can be happening concurrently. For example, you can take the time to select a qualified registrar if registration is part of your action plan. If you are going to be audited by your customer (second-party registration) or performing a self-audit, then you can skip this step.

Task 1-Obtain a list of qualified registrars. Qualified registrar will be third-party organizations recognized by national approval bodies as registrars for ISO 14000. The list of qualified registrars is available from any of these national body, particularly the Registrar Accreditation Board (U.S.), RvA (Netherlands), and the UKAS (United Kingdom). Appendix C has full contact information for these groups.

In particular you are looking for a registrar with experience in issuing ISO 14000 certificates for companies in your industrial group. Each registrar is suppose to publish the scope of industrial categories it covers.

Task 2-Create a list of your company's needs. While you are waiting for the registrar to respond to your request for information, you should list out the needs of your company. Specifically, what your company expects from contracting with a registrar. This would include how the registration audit will be conducted, the cost for services, amount of support expected from the registrar, the expected qualifications of the auditors, and other similar issues.

As we have described before, the registration process is formal and legally binding. Therefore you will want to read the application form, contract, and information packages from each registrar carefully. Your steering committee should be aware of how a registration process proceeds. Then they can be queried as to be expectations they have for the registrar. The resulting list of expectations and needs should be written down so that each prospective registrar can be evaluated using objective measurements. You should also note that the lowest price registrar may not be the best choice if another registrar with a slightly higher price offers more services and a better reputation.

Task 3-Select at least three registrars for further review. Once you receive literature from each prospective registrar you should attempt to reduce the list of candidates to three. This is not a hard and fast rule, but you should always attempt to get at least three or more good candidates. This will give you more ability to negotiate a better contract and price with the winning registrar.

From the final three registrar selected you should ask for references from previous clients. All of the references should be contacted and interviewed. You are looking for the level of professionalism displayed by auditors from the registrar, how well the registrar met customer needs, and how the registrar handled problems. This information should be summarized in a written report which also summarizes the terms and conditions of the registrars' proposed contracts. This report is then presented to the steering committee for review and comments.

Task 4-Select the best registrar and sign a contract. Now the steering committee votes on the best candidate registrar. Once selected, a contract with that registrar needs to be negotiated. This is the point where you want to make sure that all understanding about your relationship with the registrar is placed in writing. For example, you will want a " quit clause " in the contract. This allows you to fire the registrar at any time and not owe the remaining expense. You will also wish to finalize the price for the registrar's services. Typically, a three year contract is signed.

The first year involves reviewing your documentation, an initial visit, the registration fees, and the expense of the registration audit. The second and third years will involve the expense of surveillance audits. All expenses should be itemized on the contract so that if you need additional services from the registrar you already know the price.

From the moment you sign a contract with a registrar, the registrar starts working with your company preparing for the registration audit.

Step 7: Upgrade or create written work instructions as needed.

As standard operating procedures are approved you may begin writing the related work instructions. Just like operating procedures, you can assign specific work instruction creation to particular people. Also, much of the writing of level 2 and level 3 documents can occur at the same time.

Task 1-Study the activities described in the related procedure and the paperwork involved. Each standard operating procedure will undoubtedly refer to specific work instructions, such as lab procedures, forms to complete, inspection instructions, specific tests, process checks to perform, and so on. In many cases there will exist paperwork related to these specific tasks.

You should first create a list of work instructions that are either referred to in a procedure or are known to be part of that procedure. The paperwork associated with such tasks should be examined. This will give you a good picture of some of the activities a person will have to complete as part of a specific task.

Task 2-Create a flowchart of the task being performed. Examining each step of the task being performed you create a flowchart. For each step you add details such as which forms to use, tools involved, and how to perform the specific tasks.

Task 3-Draft the work instruction. Using the flowchart from the previous task, you can now draft the work instruction. Just like the method that you used for writing operating procedures, you write out a description of each step of the task. You note who conducts the activity, when it should happen, equipment to a used, and how to fill out it appropriate paperwork.

Task 4-Submit draft to the affected department manager for approval. Once the draft work instruction is completed it should be forwarded to the affected department's manager for review. This is done to insure that it meets that department's requirements for work instructions and that it does not conflict with other existing instructions.

After the department manager approves of the work instruction, the draft should be forwarded to the steering committee for final approval. Naturally, all work instructions are considered controlled documents and should be treated as such. Any work instruction created as part of the implementation process requires training of affected employs in its usage. Be sure to include such training in your overall plan for implementation.

Step 8: Conduct a system wide internal audit.

When you think your system is in place and you want to compare it to the baseline audit an internal audit of the complete system is conducted. If few weaknesses are found you then schedule the actual ISO 14001 audit. If many weaknesses are found you delay the registration audit and take corrective action.

This is a critical phase in the implementation of ISO 14001. First, you have to assure your management team that your company is ready for a registration audit. This internal audit should produce enough information so that management can decide whether the company is ready. Second, you need to show evidence that you have an internal audit system being used within your environmental management system. By conducting a complete internal audit you will create the evidence of a system in place and its effectiveness.

Task 1- Plan for and conduct the system wide internal audit. Once all documentation as been created, employees trained, and evidence in the form of environmental records collected, you are ready for a complete internal audit. Planning for such an audit involves informing key managers that they will be interviewed and establishing an audit schedule. The audit schedule will layout which department will be examined at which times.

Conducting the internal audit involves interviewing managers and employees, sampling the environmental records, and confirming that procedures and work instructions are being properly followed. Chapter eight will discuss how this is done in detail.

Task 2- Prepare an audit report for management review. Once the audit is completed, the auditors should turn in their written findings to the lead auditor. The lead auditor, in turn, creates a written report on the level of conformance of your company to ISO 14001. This conformance is determine by the completeness of your system and the effectiveness of its usage.

The audit report is then sent to the management committee of your company for review. This first audit report should also be copied to the steering committee for their review. Any deficiencies found within your system should be corrected. It is up to the management committee to assign specific people to the task of completing these corrective actions. It is also the responsibly of the management committee to change the system when needed to achieve a higher level of conformance.

At the same time you should not lose sight of the constant search for opportunities for improvement. When these opportunities are discovered during an internal audit they should be noted on the audit report and brought to the attention of the management committee.

Task 3- Decide when to schedule the registration audit. The audit report should have a section called " conclusions." In the audit reports created during implementation, this section should express the auditors feelings on the level of conformance the company has to ISO 14001. The management committee needs this information to determine whether your company is immediately ready for a registration audit or if further actions are required.

If the management decides that further development of the environmental management system is required then they should develop a plan of additional actions. Just like your initial action plan, this plan will identify particular tasks to be performed by specific people. Only when the management team is convinced of your company's conformance to ISO 14001, or feel that conformance will soon be achieved, should the registration audit be scheduled.

The registration audit is scheduled by your management representative. The management representative contacts the registrar and secures a time when the registrar's audit team is available and your key managers will all be on site.

Step 9: Prepare for the audit by reviewing all points of the environmental management system with management and workers.

Now that the registration audit has been scheduled, you need to prepare your company for the upcoming activities. The better prepared your company is the smoother the audit will proceed and the greater likelihood that your company will receive registration more quickly.

Task 1- Inform all employees of the coming audit. One of a first things to plan and conduct is overview training for all employees. The employees should understand what is involved in an ISO 14001 audit and why the company is seeking registration. Hopefully, by this point, you have been training employees in the revised or new procedures and work instructions. As part of that training you should have mentioned why the company is developing a documented environmental management system.

As part of this overview training, you are reminding all employees of the importance of your company's environmental management system. At the same time you need to prepare the employees for any possible contact with the auditors from the registrar. In particular, the employees have to be able to explain your company's environmental policy. They also have to understand that when questioned they should give truthful answers and that they should answer only questions that they were asked.

Task 2- Prepare your management team for the audit. Along with the employees, you will need to prepare your managers for the audit. Managers will have to be familiar with all policy statements related to the environmental management system. They also have to know the procedures used within their department. A controlled copy of the policy manual and the manual of standard operating procedures for your company's environmental management system must be present in each managers' office.

The managers should be interviewed during your initial internal audit. This should be accompanied by training on proper interview techniques. Managers should be made aware of how they should answer auditor questions. For example, when asked on how they look for continuous improvement each manager should be ready to show written memos and other internal communications reporting opportunities for improvement. Then they should produce their own memos instructing particular people to take advantage of the opportunity.

Finally, the managers should receive some instruction on the steps that occur during a registration audit. They should be made aware of the proposed audit schedule so that they know when they will be audited and how long their department will be examined. It is critical that key managers in your system be available during the entire audit.

Task 3- Select guides for the registrar's auditors. One of the responsibilities of your company will be to provide guides for the auditors provided by the registrar. Guides are employees of your company who are very familiar with operations and your environmental management system. You should select guides based on their ability to think quickly on their feet, take notes, and to be polite at all times.

The guides are provided so that auditors can be quickly moved to the locations and the people they wish to examine. The guides do not answer interview questions for other people. They do not interfere with the audit. They do help the auditors in locating what they need and to foster communication with key people in your facility. For example, if a safety violation is observed the auditor may request that your management representative come to the site of the violation to correct it immediately. The guide would call the management representative while noting the situation.

A guide can be a great resource for your company. Besides helping to make the audit flow smoothly, a guide can note all questions asked by an auditor and the responses heard. These notes will later prove invaluable. For example, you can use them to make appeals on findings reported at the closing meeting. You can also use them to further the education of your internal audit team.

Step 10: Be audited and respond with corrective actions, if needed.

The last step in implementation is the actual registration audit. Sometime before this, the registrar should have sent a lead auditor to perform an initial visit of your site. This visit would help the lead auditor to understand your facilities and to meet some of your top managers. Also, sometime earlier, the lead auditor would have reviewed your level 1 documentation. This desk review of your documentation helps the registrar to better understand your company and assists in the creation of an audit plan.

Before the actual registration audit takes place you should receive the registrar's audit plan for your company.

Task 1- Take responsibility for hosting the registration audit. Getting ready for a registration audit requires communication between your company and the registrar. For example, the registrar will submit a proposed audit plan a few weeks before the audit. The management representative will serve as host for this audit. Therefore the management representative should review the proposed audit plan with the management team of your company. Changes should be made if necessary.

If you are the management representative, then as host you have several responsibilities. One is to greet the auditors when they arrive on site. Another is to introduce the auditors to your management team. You are responsible for arranging a meeting room for the opening and closing meetings of the audit. The auditors will need a private meeting room and food to be catered in. You will also have to be on site during most of the audit. Larger companies will discover that the auditors will want to check all three shifts. Therefore you should set up meetings with the auditors each day during each shift.

If a problem occurs during the audit the management representative will be contacted first. Also, if an auditor requests to file a complaint with your company president then as management representative you should escort the auditor to the president.

Task 2- Take corrective actions if needed. Once, the audit is completed the auditors will hold a closing meeting to list any corrective actions they feel are necessary for your company to demonstrate conformance. If such corrective actions are called for then you should meet with the steering committee to establish a written plan on how the corrective actions will be completed.

This corrective action plan should note the original problem, how the root cause will be determined, the person assigned the task of correcting the situation, and the timeline until completion. This written report should be prepared within a week of the audit. Then it should be forwarded to the registrar.

Task 3- Confirm all corrective actions and receive registration. Next your internal audit team leader will take responsibility for tracking and reporting on the success of the corrective action plan. This team leader must make sure that the people assigned the task of corrective action are carefully tracked for their progress. As each corrective action is completed, the team leader should note this and sign off on the corrective action plan.

Once all corrective action have been carried out, then the registrar should be informed. In most cases, the lead auditor from the registrar will want to visit your site again to confirm the corrective actions. Once confirmed, your company will be recommended for registration to ISO 14001.

Task 4- Use the registration to its maximum benefit. A commonly forgotten portion of implementation is to take advantage of the registration. Your registration seal indicates that your company has a confirmed environmental management system. Your management team should now disband the implementation steering committee. Next they should begin to actively address how the registration will be marketed to new and existing customers. They should also remember that a registered environmental management system with well-set targets will always be in conformance with regulations. Therefore, they should investigate opportunities for continuous improvement to continue the assurance of conformance to regulations and to increase the efficiency of the company. In the next chapter, we will examine some of the marketing benefits that can come from registration.

Reviewing Local, State, and Federal Regulations

Taking a queue from BS 7750, you should also begin creating a library of applicable regulations. These should be drawn from local, state, federal, and other government related sources. In addition, we recommend that you subscribe to a service that will keep your company up to date with changes in regulations and the issuing of new regulations.

When you use outside environmental consultants, be sure to inquire on which regulations will apply to your company. Feel free to ask them to create such a list. In this way you can obtain copies of the needed regulations. However, you should still investigate whether there are additional regulations for your company. The resulting library of regulations is used to help your management team to develop objectives and targets for your environmental management system.

Part of this library should also be the reports submitted after environmental audits by external and internal audit teams. This will allow you to tracked compliance to past and current requirements. In addition, you may want to review contracts with your sales and engineering staff to list out all customer requirements related to environmental issues. This will allow you to see the " big picture." In other words, all of the environmental requirements for your company would be in one place.

The existence of this library of information should be a known to all staff at your company. This would allow various people to access this information when they need it. For example, a plant engineer wishing to install a new ventilation system could consult the library to determine the local, state, and federal requirement for vent placement and air discharge allowable limits.

In a larger company or a company dealing with many environmental issues, there will be a need for a staff member with environmental knowledge. For example, an environmental engineer or technician. Such a person could maintain the library, create a monthly newsletter that updates all managers on changes in environmental regulations, and could take accurate samples for measuring environmental targets.

A Final Word About Liability

Finally, we should caution you above the issue of liability. With ISO 9000 there is the chance that someone will falsify a lab result or certificate of compliance to a product standard. This is fairly rare and usually delberate. In contrast, an improperly functioning ISO 14000 system can result in failures during audits that result in fines, restricted production, or legal penalties. Such failures can be unintentional, such as the result of a poorly understood procedure. Therefore, environmental systems tend to have a higher degree of risk.

In addition you will be dealing with environmental regulations that require some knowledge of chemistry or other technical subjects. You will need to have knowledge on site about hazardous chemical, air pollutants, water contaminants, noise sources, environmental countermeasures, and so on. For example, when attempting to neutralize a sulfur dioxide emission you cannot make guesses, you must have someone available that has knowledge and experience with the particular issue.

Thus, we strongly recommend that you seek out experts in the environmental field to meet your needs. The economic and market penalties for environmental mistakes are too high to allow you to design an inadequate environmental management system.

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