| Incorporating Prevention into your EMS
As Yogi Berra is credited with saying "It
ain't over till it's over" certainly remains a truism when it comes to
approval of the proposed revisions to the ISO 14001 Standard. Currently
the Standard is winding through the tedious process of approval for the
first revisions to the Environmental Management Systems (EMS)
specifications and supporting guidance documents since it was initially
issued in 1996. Most experts concede that by and large, the changes will
be more in the realm of clarification of “gray” areas of the Standard,
rather than adding new elements or creating a radical departure with the
current framework of an EMS.
Some changes will call
for requirements such as monitoring of compliance with regulations
currently included in element 4.5.1 to be broken out as a separate
element. Other proposed changes have been more controversial, such as
relating environmental aspects to the corresponding regulatory
requirements. It is also anticipated that there will be a greater
emphasis on preventive actions, which is the focus of this article. Our
experience with a variety of client’s EMS has indicated that preventive
actions can be infused into several different elements in a system.
The majority of systems
we have worked with to date have had a significantly greater emphasis on
corrective actions rather than prevention of negative environmental
impacts. This is most likely due to the fact that most of our work as
consultants has been geared towards assisting clients with developing and
implementing an EMS. When a system is first implemented, it is natural
that it must go through a period of “shake-down” when system or regulatory
compliance weaknesses are discovered through audits and subjected to the
corrective action process. As a system begins to mature, it can be
anticipated that the number of corrective actions begins to decrease,
assuming an effective root-cause analysis process has been integrated into
the system. Element 4.5.2 of ISO 14001:1996 has always required
procedures for corrective and preventive action, but most organizations
have emphasized correction rather than prevention and subsequently may
have missed opportunities.
There are several viable
methods for including prevention in your system. One of the most basic
systems approaches is to factor in some form of risk analysis when
determining environmental aspects and impacts. By considering risk
factors, potential impacts such as spills or releases into the environment
can be considered and prevented. Another method is to deal proactively
with issues, such as wastewater effluent monitoring results, that may be
in compliance but are trending towards non-compliance. By taking action
prior to exceeding a discharge limit, these clients have avoided the
trouble of having to deal with a regulatory agency on a non-compliance
issue and approach improving their treatment system without the added
pressure of oversight by the local authority. Some of our clients have
expanded their preventive maintenance (PM) programs to embrace not only
pollution control equipment, but also many of the daily activities
associated with operations related to significant environmental impacts.
PM programs are typically found within the realm of those organizations
responsible for keeping the facility or production equipment running
properly, but we have witnessed many examples when they have been
successfully integrated into the EMS.
Employee suggestion
programs offer an opportunity to both improve internal communication and
receive ideas from employees that can be preventative. Typical ideas that
originate from employees are how to improve process steps, minimize use of
raw materials, energy, or other resources. Implementation of these ideas
can lead to prevention of waste generation, improved product quality, and
other viable benefits to the organization. Suggestion programs have been
around for a considerably longer period than the ISO 14001 Standard, yet
many organizations have yet to integrate this common business practice
into their EMS.
It has
been suggested that when the revised ISO 14001 Standard becomes effective,
current certificate holders will not be granted the full 3 years to come
into conformance, but rather will be granted a shorter period, such as 18
months to factor in the changes into their system. In my opinion, if
organizations were given more time to update their system, procrastination
would set in, as happened with the transition to ISO 9001:2000. By
considering integrating a range of preventive actions into your system,
you will be able to realize the many benefits these approaches can bring
even before the updated ISO 14001 Standard becomes reality. You will also
be able to accumulate the evidence required to satisfy auditors who will
ask you for proof that you have included prevention in your system.
For more information please call Lisa Wilk at 508-970-0033 ext. 112
or Email
lwilk@capaccio.com.
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