EMS; SMS; ISO 14001; ISO 45001; environmental management system; safety management system; sustainability; corrective action; compliance audit; system audit

Overview of Management Systems For EHS Professionals

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Management Systems Overview for the Hazardous Materials Professional
CHMM Overview Workshop
March 22, 2018
Loren Larson, CHMM, CPEA
Caltha LLP

Management System – What is it?
The Five Components of an EMS/SMS
Potential Costs/Benefits of Implementing an EMS/SMS
Sustainability/Sustainable Development
So What Should Environmental Managers Really Do?

Environmental Management System (EMS)
Part of an organization’s management system used to develop and implement its environmental policy and manage its environmental aspects.
Old-Era EMS
U.S.A. Laws & Regulations
Any facility striving to meet environmental/ H&S regulations undoubtedly has some form of Management System
In most cases, management system is designed to respond to legal requirements, such as permits, federal or state regulations, etc. (i.e., very “compliance driven”)
Quality Models
 Say what you do
 Do what you say
 Prove it
 Prove that its effective!
 Continually improve
Five Key Elements of an EMS/SMS
1. Environmental / Safety policy
2. Planning
3. Implementation & operation
4. Checking & corrective action
5. Management review
ISO 14001
Written standard published by International Standards Organization (ISO)
Periodically reviewed and revised
Revised in 2015; prior revision was in 2004
Organizations can be registered as meeting a current version of the standard
Now ISO 14001:2015
When the standard is revised, organizations may need to revise their EMS to incorporate changes
For those registered to 2004 version, deadline is September 23, 2018
ISO 45001
Released in 2017
Replaces BS OHSAS 18001, Occupational Health and Safety Assessment Series, internationally applied British Standard for occupational health and safety management systems
OHSAS 18001 will be withdrawn and organizations currently certified to OHSAS 18001 have a three year period to migrate to ISO 45001.
Registration/Certification Under ISO 14001
ISO does not register organizations
Organizations have four options:
Making a self-determination and self-declaration, or
Seeking confirmation of its conformance by parties having an interest in the organization, such as customers, or
Seeking confirmation of its self-declaration by a party external to the organization, or
Seeking certification/registration of its environmental management system by an external organization
Why use ISO-14001 as Benchmark?
Most recognized
Most flexible
Based on international consensus
Based on well known predecessors
Can be verified (registered) by third party
ISO-14001 EMS Model
ISO-14001 Specification
Structure and Core Elements
§1. EMS Scope
§3. Definitions
§4.2 Environmental policy
§4.3 Planning
§4.4 Implementation & operation
§4.5 Checking & corrective action
§4.6 Management review
§ 4.2 Policy
“The Management System Driver”
Management’s declaration of commitment to the environment
Relevant to environmental impacts of organization’s activities, products and services
Framework for environmental objectives and targets
Available to interested parties (Internal & External)
Commitment to:
Legal Compliance
Prevention of Pollution, and
Continual Improvement
§ 4.3 Planning
Legal requirements
Goals, objectives, targets
Environmental Aspects
Consider for operations, products, services:
Air emissions
Water effluents
Solid/hazardous waste generation
Contamination of land
Noise, vibration and odor
Land use, energy use, water use
Raw material and resource use
Positive environmental impacts
Significant Aspects
Establish and maintain procedures to identify your environmental aspects in order to determine those which can have a significant impact on the environment.
Rank aspects and impacts in order to assess their significance
Significant Environmental Aspects require management within EMS:
Written procedures
Contractor Requirements
Legal Environmental Requirements
Setting legal framework for the EMS
Identify and access legal requirements and “other requirements”
Keep up-to-date
Communicate to the right people
Objectives & Targets
Establish and maintain environmental objectives and targets.
Could include commitment to:
reduce waste
reduce or eliminate release/spill of a pollutant
design product/operations to minimize environmental impact in production, use, and disposal.
§ 4.4 Implementation & Operation
Structure and responsibility
Training, awareness & competence
Operational controls
Emergency preparedness & response
Training, Awareness & Competence
Must to identify training needs
All employees and contractors must be aware of basic EMS structure
Environmental policy
Significant environmental aspects
Need to evaluate and document employees and contractors are trained and are competent to perform tasks which involve Significant Environmental Aspects
Operational Controls
Activities involving Significant Environmental Aspects
Activities must be planned and have documented procedures
• Standard Operating Procedures (SOP)
• Written work instructions
§ 4.5 Checking and Corrective Action
Similar to ISO-9001
Monitoring and measuring
Nonconformance/Corrective actions
Compliance audits
EMS audits
Monitoring and Measuring –
How are you doing?
Establish procedures to monitor and measure key Environmental Performance Metric
Track how well the system is working
Analyze and correct root causes of problems
EMS Internal Auditing
System auditing
Compliance auditing
Corrective And Preventive Action (CAPA)
Root Cause Analysis – “5 Why”
Example of a “5 Why” Root Cause Analysis:
Theoretical Issue: Ruptured hydraulic line resulting in oil spill on the ground
Why #1: Because hydraulic line was worn and brittle
Why #2: Because current maintenance management system does not include this equipment for scheduled preventive maintenance
Why #3: Because maintenance management system was not updated when new machine was installed
Why #4: Because person assigned to update system has been backlogged with other projects
Why #5: Because only one person has been trained to update system
§ 4.6 Management Review
Review information to evaluate EMS
• Results of audits
• Performance relative to key metrics
• Other
Top level review to ensure EMS is:
• Suitable
• Adequate
• Effective
Consider changes needed – return to Planning phase
Costs & Benefits of Implementing an EMS
Benefits According To ISO:
protecting the environment by preventing or mitigating adverse environmental impacts;
mitigating the potential adverse effect of environmental conditions on the organization;
assisting the organization in the fulfilment of compliance obligations;
enhancing environmental performance;
controlling or influencing the way the organization’s products and services are designed, manufactured, distributed, consumed and disposed by using a life cycle perspective that can prevent environmental impacts from being unintentionally shifted elsewhere within the life cycle;
achieving financial and operational benefits that can result from implementing environmentally sound alternatives that strengthen the organization’s market position;
communicating environmental information to relevant interested parties.
Costs & Benefits of Implementing an EMS
Depends on approach and if external resources are needed
Depends on approach to “certification”
External registration is most costly and requires reoccurring costs to maintain registration
Starting from typical compliance-based EMS, constructing an ISO 14001-compliant EMS will take a minimum of 6-months, and more likely 1-2 years to become registered.
Sustainability/Sustainable Development
Sustainability: “The possibility that human and other forms of life on earth will flourish forever”
John Ehrenfeld, Professor Emeritus, MIT
Sustainable Development: “Meeting the needs of the present generation without compromising the ability of future generations to meet their own needs”
Bruntland Commission, 1987
Sustainable Development: “Enough – For All – Forever”
African Delegate to Johannesburg (RIO+10)
Basic Elements of Sustainability
Reduce energy consumption
Reduce water consumption
Reduce waste/increase legitimate recycling
Includes internal processes, products & services
Many companies and government agencies will have:
sustainability policy (or similar)
sustainability program
sustainability objectives and targets
Sustainable or Not?
What Should Manager/Consultant/Agency Staff Do?
Business EHS professional
Identify the elements of an EMS you currently have
Consider improvements to existing programs
Consider addressing gaps
How can existing EMS support sustainability initiatives?
EHS Consultant
Be aware of client’s EMS and objectives
Consider how your work can integrate into existing systems
Environmental agency staff
Identify the elements of an EMS you currently have
Recognize different EMS/Compliance management systems


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