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  ISO 14001 And Other Environmental Specs
  Legal and other requirements relating to objectives and targets

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Author Topic:   Legal and other requirements relating to objectives and targets
mcj
unregistered
posted 16 July 2001 02:48 PM           Edit/Delete Message   Reply w/Quote
I've managed to run into a bit of a standstill regarding this requirement.
"Ensure that legal and other requirements are considered in setting environmental objectives and targets"
I interpret this in two ways. First, in every case where our organization does not comply with legal and regulatory requirements there should be a related objective and target. Second, where regulations are not followed with a corresponding objective, that we must be able to verify that there are programs, in existence, designed to maintain compliance.

The questions raised to me focus around the following situations: When (for example) on the occasion that an operator fails to initial a checklist, which would put us out of compliance, that we should at that point establish a “New” objective and target to address this. If, during an environmental audit, we discover that we are in violation of a particular regulation, should we generate an objective and target to address the violation?

When does the Objective and Target process give way to the Corrective and Preventive action process?

Many Thanks!!

mcj

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rrramirez
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Posts: 29
From:Caracas, Venezuela
Registered: May 99

posted 09 August 2001 10:37 PM     Click Here to See the Profile for rrramirez   Click Here to Email rrramirez     Edit/Delete Message   Reply w/Quote
See 4.5.1 Last Paragraph, may be help a bit.

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Randy
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Posts: 264
From:Barstow, CA, USA
Registered: Jun 1999

posted 09 August 2001 11:26 PM     Click Here to See the Profile for Randy   Click Here to Email Randy     Edit/Delete Message   Reply w/Quote
The establishment of Objectives and Targets have to do with managing your Significant Aspects and not with failing to use a checklist correctly.

The O&T relationship to regulations directly relate to their not being in conflict with the law. O&T, when established have to fall within mandated limits (you may be more stringent in your Targets than the law allows but not less), i.e., if you are required by law to reduce your VOC emissions by 200lbs a year, you may set a Target for a 300lb reduction, but not 150lbs.

I hope this helps.

[This message has been edited by Randy (edited 09 August 2001).]

[This message has been edited by Randy (edited 10 August 2001).]

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mcj
unregistered
posted 16 August 2001 03:08 PM           Edit/Delete Message   Reply w/Quote
I agree with what you’ve said, Randy…but still fuzzy about the following…

Let me put this in the following scenario…
We test our back-up generator weekly. This test must be conducted on days, classified by the DEP as, “low-ozone” days. Failure to test on “low-ozone” days can, potentially, be grounds to place our site into a different classification with the DEP and change our air-regulation status.
If the EE in charge of conducting that test fails to contact the DEP to determine that the test day was OK and tests the generator on a “high-ozone” day…does this issue need an objective and target assigned to it or is this an area handled by corrective/preventive actions.
In other words, if we are in compliance with our regulation…have verifiable programs in place to maintain compliance (but this particular regulatory requirement does not have an associated O&T with it) and, because of EE negligence, fall out of legal compliance…what do we do? Do we, at that time, establish an objective and target to address the issue…or should this become a corrective/preventive action.

Another angle to consider would be (for example) violations found during an outside air audit. Let’s say we failed to include an emissions source. Once we receive a written report from the auditor, historically we fix the violation accordingly. If this failure to report said emissions source places us in violation of our legal requirement…should this be a new O&T instead of a corrective action?

many thanks,

Marc

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Randy
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From:Barstow, CA, USA
Registered: Jun 1999

posted 16 August 2001 03:42 PM     Click Here to See the Profile for Randy   Click Here to Email Randy     Edit/Delete Message   Reply w/Quote
It sounds to me like the failure to perform the test in the appropriate manner is a procedural issue. Failure to follow procedures is a C/P Action item. What type of O&T would you set? "Our objective is to perform "X" on 2 out of 3 days correctly in accordance to DEP requirements".

I agree that you can have any type of O&T you want, but your Target should be something you can see and not just get a warm fuzzy over. Remember, "If you can't measure it, you can't manage it"

If you want to establish an O&T for every regulatory requirement you have, knock yourself out. The standard only requires that regulatory and other requirements be taken into consideration, not that they be acted upon when determining SA's.

As an auditor, I cannot tell you that you identified your SA's using an incorrect procedure, and consequently established inappropriate O&T's. I cannot tell you that your targets are not adequate and your Objectives are flawed. All I can do as an auditor is to ask some questions:
Is there a procedure to identify SA's? Yes No
Have SA's been identified? Yes No
Have O&T's been established for those SA's? Yes No
Have procedures been implemented to control O&T's? Yes No
Are O&T's consistant with the environmental policy? Yes No

Both cases you give are better suited to be addressed for C/P Action and not as O&T issues. IMMHO

Randy

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mcj
unregistered
posted 17 August 2001 09:54 AM           Edit/Delete Message   Reply w/Quote
Thanks Randy,

I agree entirely with what you’ve said. The members in our Implementation team were split on this with some believing that every violation, of the nature previously explained, warranted establishing an O&T to address it…others felt that it was a C/P Action process issue.

Thanks again for your insight and clarification.

Marc

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