4.5 Checking

4.5.1 Monitoring and measurement

This procedure describes the process for the scheduled monitoring and measurement of key characteristics of the organization’s environmental management system activities. It also addresses collection of environmental data associated with operations and activities that have the potential to have a significant environmental impact. The procedure addresses collection of environmental data associated with operations and activities that have the potential to have a significant environmental impact.

a) The department head is responsible for submitting a monthly operating report (MOR) which describes the key characteristics of the EMS and the status of the objectives and targets and associated improvement programs.

b) The department supervisor(s) are responsible for generating environmental monitoring and measurement data to be submitted in the Monthly Operating Report (MOR).

c) Executive management shall review the monthly operating reports to assure continuing suitability and effectiveness of the EMS.

Procedure

1. Monthly Operating Report (MOR)

A monthly report shall be established for department heads/supervisors to submit monitoring and measuring information to support performance of the EMS. The report is to be structured as a minimum to:• Provide status of environmental management programs designed to fulfil environmental

objectives and targets,• Provide status of performance indicators as related to targeted timeframes,• Provide compliance status of environmental operating permits issued by environmental

regulatory agencies.

2. Performance Tracking

Environmental data collected to reflect environmental performance is to be maintained in such a manner to allow the evaluation of progress toward realizing environmental objectives and targets.

4.5.2 Evaluation of Compliance

The purpose of this procedure is to describe the method by which Idex Corp will periodically evaluate its compliance with applicable legal and other requirements to which Idex Corp subscribes, and record the results of these evaluations.

Head of Quality and Environment Compliance is responsible for communicating relevant and pertinent information about the requirements to the President and Chief Operating Officer (COO). The Director of Quality and Environmental Compliance shall, at a minimum, keep the COO informed of foreseen, potential, and/or current nonconformities with the requirements.

The Environmental Manager is responsible for ensuring that all activities and obligations i.e. Track changes to the requirements; and communicate relevant and pertinent information about the changes to the requirements, to management and employees.

Procedure

Periodically evaluating compliance with the requirements and communicating to management and employees

• All provincial/state and federal requirements will be reviewed on a monthly basis. Idex Corporation receives monthly alerts and updates of amendments to state/provincial and federal environmental legislation and the passing of new state/provincial and federal environmental legislation from a reliable legislative service.

• Municipal environmental by-laws will be reviewed on a monthly basis to identify amendments to municipal by-laws or the passing of new municipal by-laws.

• Non-regulatory requirements will be reviewed to identify amendments to nonregulatory requirements or the passing of non-regulatory requirements. The frequency of reviews will depend on ACME Co.'s level of commitment, possible liabilities, and the ranking of the associated significant aspect

• All required components of Idex Corps EMS will be updated within an appropriatetime frame, to ensure compliance with the amendment(s) or the new requirement(s).

4.5.3 Nonconformity, corrective action and preventive action

This procedure describes a controlled process for initiating corrective and preventive action in response to externally or internally reported non-conformances pertaining to the EMS of Idex Corporation

Department staff are responsible for bringing suspected non-conformances to the attention oftheir assigned Section Managers, or to the EMR.

The Environment Management Representative is responsible for evaluating potential non-conforming conditions noted in internal or external communications, EMS audits, management review, or third-party registrar audits and surveillance activities, and for initiating the Corrective and Preventive Action Request (C/PAR) process where non-conformances are determined to exist. The EMR shall actively participate in the resolution of the non-conformance and shall work with the responsible Section manager or section supervisor to identify appropriate corrective and preventive actions. The EMR is responsible for preparing corrective and preventive action requests, verifying completion, and logging of the issuance and closure. The EMR shall prepare and present a report to management on a monthly basis identifying the current status and resolution of all C/PAR’s.

Section Managers or Supervisors determined to have primary responsibility for a non-conformance shall participate with the EMR in the evaluation of the non-conformance, determination of the root cause of the non-conformance, determination of appropriate measures to be taken to correct the immediate situation, and the determination of appropriate preventive measures that could reasonably be taken to reduce or preclude the likelihood for recurrence of the non-conformance. It is the responsibility of the Section Manager, Supervisor or assigned management to ensure these corrective and preventive actions are completed within the determined time frame or report the progress and the revised completion dates to the EMR, prior to the original completion date.

Procedure

Steps to follow for investigating, correcting and preventing non-conformance include:1. Identifying the root cause of the non-conformance,2. Identifying and implementing the necessary corrective action,3. Implementing new or modifying existing controls to prevent a recurrence of the non-

conformance,4. Reviewing the effectiveness of corrective and preventive actions,5. Recording changes to procedures resulting from the corrective and preventive action6. Documenting all steps

4.5.4 Control of records

This procedure describes policies for identification, maintenance and disposal of Idex Corporations Environmental Management System records. This procedure covers all environmental records, both hardcopy and electronic or other media form, required for effective operation of this facility’s Environmental Management System. These records are managed at the department level and at the facility level. Records include but are not limited to: forms (when filled in), reports, training, audit results, inspection results, maintenance and calibration records, emergency response records, information on significant environmental aspects, and management reviews.

It is the responsibility of the Environmental Office to identify environmental records and retention periods required by environmental regulations for environmental records that are maintained for the facility.

It is the responsibility of the Department Head or designee to identify and maintain environmental records, and their retention times, specific to the department's significant environmental aspects.

It is the responsibility of the EMR Designee to identify and maintain records associated with the EMS at the facility level. The EMR Designee identifies retention times for these records.

Procedure

1. The Environmental Office maintains a documented procedure for the identification, collection, indexing, access, filing, storage, maintenance, and disposition of facility level environmental records.

2. Departments maintain a process for the identification, collection, indexing, access, filing, storage, maintenance, and disposition of department level environmental records.

3. All environmental records are legible, retrievable, and maintained in a suitable environment to prevent deterioration, damage, or loss.

4. Retention of records is in accordance with regulatory requirements unless otherwise specified in the procedure producing the record.

5. Obsolete records are disposed of by the record owner or designee.6. Appropriate security and backup controls are in place to ensure the reliability, security, and

availability of electronic environmental records for which no hard copy is retained.

4.5.5 Internal Audit

This procedure establishes minimum requirements for planning, performing, and documenting periodic internal audits of the ISO 14001-based environmental management system (EMS) established for Idex Corporation

The Environmental Management Representative (EMR) is responsible for establishing audit schedules and for designation or selection of Lead EMS Auditors who are independent of the day-to-day management of the plant functions to be audited. The EMR shall also review and approve EMS audit plans and reports.

The Lead EMS Auditor is responsible to the EMR for the organization, planning, and direction of EMS audits, as well as the selection, training, and supervision of the audit team. The Lead EMS Auditor prepares audit plans and reports, and is responsible for evaluating and recommending any required corrective and preventive action responses resulting from audit findings.

Auditors are responsible for assisting in audit preparation, conducting audit investigations, and reporting results in compliance with this procedure, under the direction of the Lead EMS Auditor. When requested, audit observers shall assist in audit preparation and in conducting audit activities in areas in which they have specific expertise.

Section Managers of audited section or group shall provide time, work space, and personnel as necessary to support the performance of EMS audits, and are responsible for supervising the prompt and effective resolution of any audit findings.

Procedure

The audit process is described in the following steps:1. Audit Scheduling, to be conducted at least annually.2. Audit Notification, the Lead auditor must notify the relevant people at least 10 days prior to

the audit about the projected audit date.3. Audit Plan prepared by the Lead Auditor detailing the audit number, objectives, date of

audit, team members and their assigned roles etc.4. Audit Checklist Preparation, as per the ISO 14001 standards5. Opening Meeting, prior to the audit convened by the Lead Auditor in presence of the Audit

Team and representatives of the Audited section. Discussions on the audit process and communication channels are to be established

6. Conducting the audit, as per the ISO 14001 standards using the Audit Checklist7. Closing Meeting, post the audit to share a draft list of findings and observations with the

audited section. Clarification of misunderstandings may take place.8. Audit Report Preparation9. Review of Corrective/Preventive Action Responses by the lead auditor, once this is approved

by the lead auditor, it is communicated to the EMR and the Audit is considered closed.10. Audit Documentation, to be done once the Audit is closed, by the lead auditor.