contractor management and iso 14001:2004 2008 ems conference, roanoke, virginia october 8, 2008 dr....

Contractor Management and ISO 14001:2004

2008 EMS Conference, Roanoke, Virginia October 8, 2008

Dr. Victor Gray CVGray & Associates LLC

[email protected]

mailto:[email protected]

http://www.cvgray.org/

Contractor Management and ISO 14001:2004 Outline

What is ISO 14001:2004ISO 14001:2004 RequirementsImportance of Contract

Management Control Application of Operations Control

(Clause 4.4.6)

What is ISO-14001:2004

What Are ISO Environmental Management StandardsEMS helps an organization to establish and meet

its own policy goals through objectives and targets, organizational structures and accountability and management controls and review functions - all with top management oversight. EMS does not set requirements for environmental compliance, nor do the standards establish requirements for specific levels of pollution prevention or performance.

The Environmental Management Systems’ Specification Document calls for environmental policies which include a commitment to both compliance with environmental laws, and prevention of pollution.

What Are ISO Environmental Standards

ISO's Environmental Standards (EMS) are a series of voluntary standards and guideline reference documents which include:

• Environmental Management Systems, • Eco-labeling, • Environmental auditing, • Life cycle assessment, • Environmental performance evaluation, • Environmental aspects in product standards.

The focus on management “distinguishes these standards from performance" standards.

ISO 14001: EMS Specification Standard

Environmental Management Systems - Specification with guidance for use.

This standard is the main management systems specification document in the ISO 14000 series. It contains the required elements that must be satisfied by an organization seeking registration or certification for its Environmental Management Systems to the standard. It’s the only standard to which an organization can be audited.

ISO-14001 EMS Specification Standard

• Is not a Product standard;• Is not a Performance standard;• Does not establish levels for Pollutants or

Performance;• Does not establish Test Methods;• Does not require initial Performance Testing;• Does not require or establish a Final Performance

Goal;• Does not require the meeting of Zero Emissions; • Does not mandate Best Practice Technology;• Does not require the disclosure of Performance

Levels;• Does not require the disclosure of Audit Results.

What ISO-14001:2004 is Not and Does Not:

An environmental policy supported by top management, Identification of environmental aspects and significant impacts, Identification of legal and other requirements, Environmental goals, objectives, and targets that support the policy, An environmental management program, Definitions of roles, responsibilities, and authorities, Training and awareness procedures, Processes for communication of the EMS to all interested parties, Documentation and operational control procedures, Procedures for emergency response, Procedures for monitoring and measuring operations that can have a significant impact on the environment, Procedures to correct nonconformance, Record management procedures, A program for auditing and corrective action, Procedures for management review.

The ISO 14001:2004 EMS Standard Contains Requirements for the

Following:

ISO-14001:2004 Background

The ISO-14000 series: An evolving family of environmental management standards.The International Organization for Standardization (ISO) was founded in 1946 in Geneva, Switzerland, with its key mission to promote trade by developing international voluntary consensus standards.

The ISO 14000 series is a voluntary set of standards intended to encourage organizations to systematically address the environmental impacts of their activities. The Standards have been developed by ISO under the TC 207 committee. The goal of the TC 207 committee is to develop a common approach to Environmental Management Systems that is internationally recognized. ISO 14001 was adopted in 1996 as an International Standard for guiding the development of Environmental Management Systems.


The ISO 14001 EMS is defined as:"that part of the overall management system that includes organizational structure, planning activities, responsibilities, practices, procedures, processes, and resources for developing, implementing, achieving, reviewing and maintaining the environmental policy" (ISO 14001: 1996).The current version (2004) is the second version which updates and replaces the 1996 version.


continued

ISO-14001:2004 Requirements

The Plan, Do, Check, Act Continual Improvement

Cycle

ISO-14001 Requirements

Environmental planning takes into account the following paragraphs of Section 4.3 PLANNING:

4.3.1 Environmental aspects4.3.2 Legal and other requirements4.3.3 Objectives & targets

The “Planning” phase of the continual improvement cycle requires that plans are formulated to fulfill the Environmental Policy's Objectives and Targets.

ISO-14001 RequirementsThe implementation (Do) and operation of your E.M.S.

takes into account the following paragraphs of Section 4.4 Implementation & Operation:4.4.1 Resources, Roles Responsibility and Authority4.4.2 Competence, Training and Awareness 4.4.3 Communication4.4.4 Environmental Management Systems Documentation4.4.5 Document Control4.4.6 Operational Control4.4.7 Emergency preparedness & response

The “Do” phase of the continual improvement cycle requires the development of capabilities to support the implementation and on-going operations of the organization in support of the E.M.S.


Environmental Checking takes into account the following paragraphs of Section 4.5 Checking .4.5.1 Monitoring & Measuring4.5.2 Evaluation of Compliance4.5.3 Nonconformity, Corrective and Preventive Action4.5.4 Control of Records4.5.5 Internal Audit

Monitoring and measuring ensures the success of your environmental performance and that its meeting stated objectives and targets.


Environmental system management review takes into account the following paragraphs of Section 4.6 Management Review:

4.6 Management Review

The entire Environmental Management System should be continually monitored, and be subject to periodic reviews.

Importance of Contract Management Control

Importance of Contract Management Control on your site (Clause 4.4.6 Operational Control)

Your EMS should require that any person performing work or services on your site, who has the potential to cause a significant environmental impact should be aware of the requirements and importance of the EMS and are competent to perform the job assigned.

For Contractors performing an operation or activity that has the potential where environmental impacts are significant, these controls should take the form of documented procedures.

Application of Contract Management Control

Application of Contract Management Control on your site

What forms can these controls take?

Procedure(s) for 4.4.6 and contractor management

Develop Operating Criteria

Documented instructions for Contractors on site

Videos of safety and environmental actions needed

Training prior to coming on campus

Completed form (which becomes a record of agreement when it is signed) “Environmental Briefing Contractor Methods Statement” can be a technique used to inform contractors of your requirements.

Environmental Management Basics Example• The environmental manager is : _____________ (contractor signs off on each

point) • Supplier / Contractor understands the importance of compliance with relevant

environmental legislation and regulations, and the consequences of non-compliance.

• All Suppliers / Contractors working at the facility are required to comply with and ensure their employees and any Suppliers / Contractors or agents comply with the facility’s Environmental Management System (EMS) and environmental policy.

• All Suppliers / Contractors acknowledge receiving or were made aware of the facility’s environmental policy, as well as applicable system procedures and work practices.

• Suppliers / Contractors shall not discharge anything to drains and/or sewers without the prior approval from the facility’s environmental manager.

• Spills and other releases to the environment must be immediately reported to the environmental manager.

• Suppliers / Contractors shall provide adequate spill release prevention, as approved by the environmental manager.

• Suppliers / Contractors shall immediately notify the environmental manager of any abnormal conditions found during work at the facility.

• Suppliers / Contractors shall properly label, store, and dispose of all their waste materials used in-site in accordance with facility procedures and all legal requirements.

• If facility personnel are required to work with potential hazardous materials brought on-site by a contractor, prior approval of that material by the environmental manager is required.

• Suppliers / Contractors shall minimize the efforts of noise, order, light, fugitive dust emissions, and traffic movement on and/or adjacent to facility property.

• Suppliers / Contractors shall obtain, prior to commencing work, all necessary environmental approvals or permits and present copies of such permits to the environmental manager.

• Suppliers / Contractors were informed of actions to be taken during an actual emergency situation.

• The Suppliers / Contractors understand that the facility may interrupt Supplier / Contractor activities that violate policies and/or all legal requirements.

All ISO 14001:2004 EMS actions in regard to Contractor Management should be:

DocumentedPart of plan of facility operational controlActions recordedPart of initial Contract negotiationsPart of the Internal Audit process