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    Environmental Management

    System Auditing

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    Training Objectives:

    Understand the goals of an Environmental

    Management System (EMS) audit

    Understand the ISO14001 requirements forinternal auditing

    Provide information on each clause of the

    standard

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    ISO14001 Structure

    4.2 Policy

    4.3 Planning

    4.3.1 Environmental Aspects 4.3.2 Legal and Other Requirements

    4.3.3 Objectives and Targets

    4.3.4 Environmental management Programs

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    ISO14001 Structure

    4.4 Implementation and Operation

    4.4.1 Structure and Responsibility

    4.4.2 Training, Awareness and Competence

    4.4.3 Communication

    4.4.4 EMS Documentation

    4.4.5 Document Control

    4.4.6 Operational Control 4.4.7 Emergency Preparedness and Response

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    ISO14001 Structure

    4.5 Checking and Corrective Action

    4.5.1 Monitoring and Measurement

    4.5.2 Non-conformance and corrective and

    Preventive Actions

    4.5.3 Records

    4.5.4 EMS Audit

    4.6 Management Review

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    Purpose of Audits

    An EMS audit has two goals:

    Determine if the EMS conforms to the

    requirements of the ISO14001 clauses and

    other environmental requirements that may be

    unique to the organization. This is typically

    audited through a review of documentation.

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    Purpose of Audits

    Determine if the EMS program is understood

    and being properly implemented. This involves

    verifying that what is stated on paper is

    practiced. This is typically audited through acombination of interviews, sampling and direct

    observations to ensure that procedures are being

    followed.

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    ISO14001 Auditing

    Requirements

    ISO14001 requires that we have programs

    and procedures in place for auditing the

    Environmental Management System(EMS).

    The audits should be conducted on a

    periodic basis and results presented to

    management as part of evaluating the

    overall environmental performance of the

    facility.

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    4.5.4 EMS Audit

    Requirements:

    Clause 4.5.4 requires that the organization

    establish and maintains programs andprocedures to conduct audits to determine if

    the EMS:

    conforms with planned arrangements (thiswould include at a minimum the specific

    requirements of IOS14001

    is properly implemented and maintained

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    4.5.4 EMS Audit (Requirements)

    The results of the audits must be provided

    to top management.

    The EMS audit procedures should establishthe following:

    the scope of the audit

    how often the audits will be conducted the methodologies to be used

    who is responsible for conducting the audits

    and reporting audit results

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    4.5.4 EMS Audit (Requirements)

    The EMS audit program should reflect the

    results of any previous audits and the

    severity of the environmental impactsinvolved.

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    4.2 Policy

    Policy must be documented

    Policy statement is meant to be a guide, it is

    not a law or rule that can never be broken Clause 4.2 specifically requires that top

    management be responsible for developing

    and defining the environmental policy Top management may consist of an

    individual or group of individuals with

    executive responsibilities

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    Requirements:

    the organization must have an

    environmental policy

    the policy must be defined by topmanagement

    the policy must meet the following

    requirements:be appropriate to the nature and scale of the

    environmental impacts of its activities, products

    or services;

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    Requirements:

    contain commitments to continual

    improvement, prevention of pollution and

    compliance with relevant environmental

    legislation and regulations, and with otherrequirements to which the organization

    subscribes;

    provide a framework for setting and reviewing

    environmental objectives and targets;

    documented, implemented and maintained

    communicated to all employees

    available to the public

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    4.3.1 Environmental aspects

    The intent of clause 4.3.1 is for the

    organization to develop a more complete

    understanding of how its actions mayaffect the environment.

    One of the most important clauses of the

    standard, as it will define many of the EMS

    programs and processes the organization

    develops.

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    4.3.1 Environmental aspects

    The Policy must reflect the identified

    aspects

    Objectives and targets must be developedwith consideration to the significant aspects

    Management programs and monitoring and

    measurement programs will be shaped bythe aspects.

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    Requirements:

    Clause 4.3.1 sets out three requirements

    governing environmental aspects;

    The organization must establish a procedureto:

    Identify the environmental aspects associated

    with its operations and

    Evaluate which aspects have a significant

    impact on the environment

    o

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    Requirements:

    The aspects related to significant impacts

    must be considered in setting environmental

    objectives The organization must have a system for

    keeping the identified environmental

    aspects up to date. That is the aspects must

    be reviewed periodically and re-evaluated in

    the light of the current circumstances of the

    organization

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    4.3.2 Legal and Other

    Requirements

    Clause 4.3.2 is to ensure that the

    organization is fully aware of all its legal

    and other obligations. This awareness is achieved through

    obtaining copies of relevant material,

    analyzing how it applies and understanding

    the requirements.

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    Requirements:

    4.3.2 requires the organization to have

    procedures to identify and have access to

    two types of requirements: Environmental legal requirements (e.g.

    governmental regulations)

    Other requirements that the corporation or site

    has adopted and that apply to facility operations

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    4.3.3 Objectives and Targets & 4.3.4

    Environmental Management Programs

    In order to monitor and improve its

    environmental performance an organization

    must have a systematic process to establish and

    maintain objectives and targets.

    Goals are useless unless there is an underlying

    program to achieve them.

    4.3.3 requires documented objectives andtargets and 4.3.4 requires that there are

    programs in place specifying actions to take to

    achieve the objectives and targets.

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    4.3.3 Objectives and Targets & 4.3.4

    Environmental Management Programs

    The intent of 4.3.3 is for the organization to

    establish specific and measurable

    documented objectives and targets thataddress its most significant environmental

    issues.

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    Requirements:

    Clause 4.3.3 requires that documented

    objectives and targets are established and

    maintained by the organization. The objectives and targets should be:

    established at the various functions and levels

    within the organization (line operations through

    management)

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    Requirements:

    developed with consideration being given to:

    the organizations legal and other requirements

    significant environmental aspects

    technological options

    financial, operational and business requirements

    the views of interested parties such as stockholders,

    community groups, regulatory agencies and

    environmental groups

    consistent with the environmental policy, with

    specific consideration given to prevention of

    pollution

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    Requirements:

    Clause 4.3.4 takes 4.3.3 one step further by

    requiring the organization to establish and

    maintain programs to achieve the goals

    Clause 4.3.4 contains specific requirements

    for these programs:

    identify who within the organization will be

    responsible and accountable for achieving thestated objectives and targets

    establish how and when the objectives and

    targets are to be achieved

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    4.4.1 Structure and

    Responsibility

    Clause 4.4.1s function is to ensure that:personnel involved in environmental activities,

    including management, have a clear understanding

    of their roles and responsibilities within the EMS.

    top management is kept informed of the

    performance of the EMS so they can improve th

    system if necessary.

    The goal of 4.4.1 is for the organization todevelop the capabilities and support

    mechanisms necessary to achieve its policy

    and established objectives and targets.

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    Requirements:

    Roles, responsibilities and authorities of

    those involved in the EMS must be defined,

    documented and communicated

    Management must provide the necessary

    resources to ensure the proper functioning

    of the EMS

    Top management must assign a

    management representative with specific

    duties with respect to the EMS

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    4.4.2 Training, Awareness and

    Competence

    The intent of 4.4.2 is to ensure that all

    employees at all levels understand the goals

    and principles of the EMS and how their

    jobs may impact the environment and

    achieving the goals of the EMS

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    Requirements:

    identify the knowledge and skills necessary

    to achieve environmental objectives

    (training needs analysis)

    - implement training to provide the

    appropriate knowledge and skills

    ensure that employees doing work that mayhave significant impact on the environment

    are competent

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    Requirements:

    The clause explicitly requires that the

    training result in employee awareness of:

    the importance of conforming with the EMS significant environmental aspects associated

    with work activities within the organization

    specific roles and responsibilities involved in

    the EMS

    potential consequences of not following

    established EMS procedures

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    Requirements:

    Although not specifically stated, clause

    4.4.2 also addresses regulatory required

    training.

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    4.4.3 Communication

    Clause 4.4.3 focuses on the communication

    of the organizations EMS and significant

    aspects.

    The function of the clause is to support the

    achievement of the policy and objectives

    and targets and the functioning of the EMS

    in general.

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    Requirements:

    Development of procedures governing

    internal and external communication of

    environmental issues.

    Procedures to facilitate internal

    communication between employees at all

    levels and functions

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    Requirements:

    With respect to external communications

    the clause requires two specific actions:

    Establish a procedure to handle communicationreceived from external interested parties

    Decide whether and how to communicate

    significant aspects to interested parties. This

    decision must be documented.

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    4.4.4 EMS Documentation

    The intent of the EMS documentation

    requirement is that the organization be able

    to demonstrate the existence of the EMS

    and explain how it functions.

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    Requirements:

    The organization possesses information that

    describes the core elements of its EMS and

    how they interact.

    This information should be cited in related

    documentation and can be in paper or

    electronic form

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    4.4.5 Document Control

    Clause 4.4.5 requires that document control

    procedures be established and maintained

    The goal of such procedures is to ensurethat all critical documents are available to

    all personnel who rely on them and that

    obsolete documents are removed and not

    used in error

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    Requirements:

    The organization must have procedures governing

    the control of documents specifically required by

    the ISO14001 standard.

    The document control process must ensure thatonly correct and current documents are used and

    available.

    The process of creating, modifying and updatingthese documents must be formalized and

    controlled.

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    Requirements:

    There are also specific requirements relating to the

    presentation and format of the documents to be

    controlled.

    Documents must be:

    legible

    dated (with revision dates)

    readily identifiable

    maintained in an orderly manner and retained for a

    specified period

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    4.4.6 Operational Control

    Clause 4.4.6 requires the organization to identify

    specific operations associated with its significant

    aspects and ensure these operations are managed

    in accordance with the policy and thatenvironmental objectives and targets are met.

    The planning must involve developing and

    documenting procedures that stipulate operating

    criteria.

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    Requirements

    Clause 4.4.6 contains 2 major requirements

    Identify operations and activities associated

    with their significant aspects and

    Plan these operations and activities to ensure

    that:

    Documented procedures are developed for

    operations and activities where the absence of suchprocedures could lead to environmental impacts that

    are not in accordance with the policy or the

    objectives and targets

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    Requirements

    The procedures developed include operating criteria

    that specify the desired outcome of the procedure

    (that is how the success of the procedure will be

    measured)

    Procedures (not necessarily documented) are

    developed to address significant aspects related to

    goods and services supplied by contractors

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    4.4.7 Emergency Preparedness

    and Response

    Clause 4.4.7 requires the organization to

    have procedures for identifying and

    managing emergency situations.

    These procedures must be periodically

    tested and revised where appropriate, after

    the occurrence of accidents or emergency

    situations

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    Requirements

    Clause 4.4.7 requires organizations toestablish and maintain procedures toaddress the following issues:

    Identifying potential accidents and emergencysituations

    Preventing and mitigating the environmentalimpacts that might result from such events

    Responding o accidents and emergencysituations when they do occur

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    Requirements

    The organization is also required to review

    and revise their emergency preparedness

    and response procedures, as appropriate,

    based on actual incidents, and that the

    procedures be periodically tested

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    4.5.1 Monitoring and

    Measurement

    Clause 4.5.1 requires that the organization have

    documented procedures for monitoring and

    measuring its operations and activities that can

    have significant environmental impacts. The intent is to track performance, assess

    implementation and effectiveness of operational

    controls and evaluate achievement of objectives

    and targets and compliance with regulations.

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    Requirements

    The clause states that monitoring and

    measuring should include recording of

    information to track the following:

    performance ( of the EMS in controlling

    environmental impacts)

    conformance with operational controls

    progress towards achieving objectives and

    targets

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    Requirements

    The clause also requires that any monitoringequipment be calibrated and records withrespect to this maintained.

    The standard does not require documentedprocedures for such calibration andmaintenance.

    The clause also requires a documentedprocedure to evaluate compliance toenvironmental regulations

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    4.5.2 Non-Conformance and

    Corrective and Preventive Actions

    Clause 4.5.2 requires the organization to have a

    process, which includes defined roles,

    responsibilities and authorities to investigate and

    address non-conformances within the EMS Correctives and preventive actions should be

    appropriate to the magnitude of the problem and

    take into consideration the environmental impacts

    caused

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    Requirements

    Clause 4.5.2 requires a systematic action plan to

    fix problems identified during monitoring and

    measurement and the EMS audit.

    This action plan is the follow up for the regulatoryand audit findings.

    The primary requirement is that the organization

    establish procedures that define roles andresponsibilities for the following activities:

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    Requirements

    The primary requirement is that the

    organization establish procedures that

    define roles and responsibilities for the

    following activities:

    Investigate non-conformances

    Mitigate any impacts caused

    Implementing and completing corrective and

    preventive actions

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    4.5.3 Records

    Clause 4.5.3 requires that records

    management procedures be established and

    maintained to ensure that records that

    support the EMS are retained, accessible

    and maintained

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    Requirements

    Clause 4.5.3 requires the organization to

    have procedures governing the

    identification, maintenance and disposition

    of environmental records necessary to

    demonstrate conformance to ISO14001

    In addition to the procedures, the clause

    contains specific requirements about how

    records should be presented and maintained

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    Requirements

    The records must be:

    Legible

    Identifiable

    Traceable to the activity, product or serviceinvolved

    Easily retrievable

    Protected from damage or loss Held for specified and documented retention

    times

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    4.6 Management Review

    Clause 4.6 requires the organizations top

    management conduct periodic documented

    reviews of the EMS to ensure that the EMS

    is effectively addressing the organizations

    environmental issues.

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    Requirements

    The general requirement of clause 4.6 is that top

    management periodically review the EMS to

    ensure that it is adequate and effective in allowing

    the organization to meet its stated environmentalgoals and fulfill its environmental policy.

    This general requirement is supported by an

    additional requirement that the organization

    collect the necessary information to ensure that the

    reviews are meaningful and useful.

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    Requirements

    The reviews should include:

    consideration of the need to change EMS elementsbased on EMS audit results, changes in circumstances,and the commitment to continual improvement.

    the possible need for changes in the organizationsenvironmental policy and environmental objectives.

    The clause also requires that management reviewsbe documented. This means that there must be

    written records of the management reviewprocess.