iso14000-digest Monday, February 16 1998 Volume 02 : Number 026
----------------------------------------------------------------------
Date: Thu, 5 Feb 1998 17:03:21 -0500 (EST)
From: "Bill Casti, CQA (System Administrator)"
Subject: Non-member submission from [Michael Snider ] (fwd)
NOTE: Respond *both* to the poster's address (see BELOW line reading
"Forwarded Message") and to the list's posting address, OR as directed in
the posting, but definitely NOT to me.
Thank you for your cooperation.
Bill
=============================================================================
Bill Casti, CQA Email: help@quality.org
Domain Owner, QUALITY.ORG Pager: +1 800 604 6149
=============================================================================
- ---------- Forwarded message ----------
Date: Thu, 5 Feb 1998 08:18:39 -0500 (EST)
To: iso14000@quality.org
From: Michael Snider
Subject: Re: Audit Follow-up Processes
On 02/03 3:02 PM , Doug Foster wrote:
I am currently drafting the terms of reference for an audit to assess
management processes for the development, implementation and subsequent
tracking and monitoring of corrective action plans...
I would be interested in hearing from anyone who has had experience with
this topic, or who might have some comments.
We have performed two major process improvements (and a lot of little tweaks) on this portion of our auditing program over the last five years. In my experience, it is one of the most neglected aspects of an auditing program. Too often, the focus of a p
rogram becomes auditing rather than improving. Its like climbing a ladder well, but not being able to make sure the roof gets fixed right once you get up there. In brief:
- - Paper-based systems are quickly overwhelmed by the volume of issues identified in a comprehensive auditing program.
- - Systems that focus on tracking audits or corrective actions rather than the issues identified (findings) tend to hamper long term management and risk reduction.
Tracking audits: If audits are tracked, there's seldom enough detail in the system to determine where resources should be focused. Once the audit is done, its a completed activity (besides the report) and doesn't need to be managed: its the issues that c
ontinue to live on.
Tracking corrective actions: It doesn't tell you what was wrong, only what's being fixed. The difference is important because you eventually will want to:
1. Prioritize issues to determine which ones should be addressed first, and how quickly.
2. Improve your abilities to identify and address root cause so that the issue doesn't recur.
Tracking corrective actions obscures root cause and will not provide guidance for future audit planning.
Our system is computer-based, and allows us to track the activity(audit), the issues identified in that activity, and the actions taken to correct that issue. We're able to manage response time for:
- completing audits and audit reports
- identifying and agreeing on issues and root causes between auditors and auditees
- timely completion and verification of corrective actions
If Doug (or anyone) would like more detail or guidance I would be glad to help. I can also provide a brief checklist of generic items to assess in an audit/corrective action plan tracking system.
Michael Snider
e-mail: sniderm@wv.doe.gov
Tel: 716-942-2024
Fax: 716-942-2000
West Valley Nuclear Services
MS-AOC-16
10282 Rock Springs Road
West Valley, NY 14171-0191
------------------------------
Date: Fri, 6 Feb 1998 15:39:42 -0500 (EST)
From: "Bill Casti, CQA (System Administrator)"
Subject: Non-member submission from [Michael Snider ] (fwd)
Don't respond to me.
Bill
- ---------- Forwarded message ----------
Date: Fri, 6 Feb 1998 10:27:33 -0500 (EST)
From: Michael Snider
To: iso14000@quality.org
Subject: aspects register
I'm not aware of any guidance on cutoff points for aspects registers. It
seems to me that cutoffs, thresholds, weightings, rankings and so forth
would be unique to a given company or facility. What such tools do is
provide a basis for discussion on how much attention an aspect should
receive. They shouldn't be expected to guarantee uniform management of
the aspects based on a score, precisely because scoring systems cannot be
expected to contain all relevant information. In other words, the
apparent precision of numerical weighting systems should be taken with a
grain of salt.
Michael Snider
e-mail: sniderm@wv.doe.gov
Tel: 716-942-2024
Fax: 716-942-2000
West Valley Nuclear Services
MS-AOC-16
10282 Rock Springs Road
West Valley, NY 14171-0191
Michael Snider
e-mail: sniderm@wv.doe.gov
Tel: 716-942-2024
Fax: 716-942-2000
West Valley Nuclear Services
MS-AOC-16
10282 Rock Springs Road
West Valley, NY 14171-0191
------------------------------
Date: Tue, 10 Feb 1998 09:22:13 -0500 (EST)
From: "Bill Casti, CQA (System Administrator)"
Subject: Non-member submission from [Donald Sutherland ] (fwd)
NOTE: Respond *both* to the poster's address (see BELOW line reading
"Forwarded Message") and to the list's posting address, OR as directed in
the posting, but definitely NOT to me.
Thank you for your cooperation.
Bill
=============================================================================
Bill Casti, CQA Email: help@quality.org
Domain Owner, QUALITY.ORG Pager: +1 800 604 6149
=============================================================================
- ---------- Forwarded message ----------
Date: Tue, 10 Feb 1998 09:10:22 -0500 (EST)
To: iso14000@quality.org
From: Donald Sutherland
Subject: ISO14000 and Financial Environmental Accounting
Wednesday
February 10, 1998
Dear ISO14000 chat group,
I would like to submit my commentary on ISO14000 for discussion.
I look forward to your comments.
Best Wishes,
Donald Sutherland
Consultant on Environmental Management Systems
1228 South Mason Road
St.Louis, Missouri 63131
phone: 314-434-3861
fax: 314-434-1873
email: donaldsutherland-iso14000@worldnet.att.net
Member of the U.S.Technical Advisory Group to TC207 on ISO14000
ISO 1400, regulatory reinvention: will business be ready?
By Donald Sutherland
Research on corporate environmental performance reporting and accounting
systems in the U.S. shows that the field, which provides much of the basis
for regulatory reinvention and the new, business-linked approach to
environmental protection, is still very much in the developmental stage. I
have been researching environmental performance reporting and accounting
systems for over a year, and have not yet developed a comprehensive
analysis of overall corporate capacity for the new approaches. However, my
early findings seem to indicate more work in the area is needed.
Here is a quick summary of my findings on the topic:
Most companies do not have a formal environmental management system to
proactively monitor and account for environmental performance and due
diligence.
Most companies do not view environmental performance as integral with
overall performance.
There are emerging corporations (mostly multinational) who do view
environmental performance as integral to overall performance and are
positioning themselves with formal environmental management systems
(ie.BS7750, EMAS,& ISO14000) to manage environmental costs and secure
market access with a green label.
ISO 14000 does not provide transparency of corporate due diligence to
environmental laws, but does audit for conformance (not compliance) to a
formalized system. ISO14000 also has no provisions for full-disclosure
accounting systems.
Corporate environmental accounting is currently divided into two
categories, internal and external. Internal corporate environmental
accounting is not codified, but relies on internal audits to apply
benchmarks to environmental contingencies (i.e., waste streams, energy use,
recycling) for financial audits to corporate boards. Activity Based Costing
(ABC) of environmental contingencies integrates accounting (instead of
isolating and departmentalizing), and allows projections to be made on
future or planned corporate environmental performance.
External corporate environmental accounting is codified by either
government or private sector accounting bodies, and audits for primarily
past environmental liabilities - not future or planned corporate
environmental performance projections.
External corporate environmental accounting allows for a market-based
comparable analysis of environmental performance audits, but requires a
uniform, enforced playing field.
In the U.S., publicly traded companies on the stock exchanges are required
to file annual financial reports using generally accepted accounting
principles (GAAPs) drawn up by private sector membership organizations (the
American Institute of Certified Public Accountants - AICPA, and the
Financial Accounting Standards Board - FASB), and are enforced by the U.S.
Securities and Exchange Commission. On Dec.15, 1996, FASB approved
environmental GAAP SOP 96-1 (Environmental Remediation and Liability) to
complement the 1975 Statement of Financial Accounting Standards (SFAS) No.5
for liability accounting.
While the SEC requires publicly traded corporations to file "significant
environmental material expenses" using a threshold reporting limit of 10%
of total corporate assets (and/or more than $100,000) for corporate fines
owed to a government body on a SEC 10-K form, the SEC has only once in
twenty years enforced the issue, and has a policy of confidentiality for
internal environmental corporate audits.
Most foreign countries I've contacted don't have government enforced
external environmental accounting models (GAAP), and are not providing
stakeholders with a financial accounting of environmental contingencies
with codified accounting models. In other words, it's an open field for
rhetoric, misinformation, and semantical analysis of environmental
performance reporting. Those corporations who are making the investments in
environmental stewardship are unable to be recognized in this uncodified,
unenforced atmostphere of environmental performance accounting.
(Donald Sutherland is a consultant on environmental management systems and
member of the U.S.Technical Advisory Group to TC207 on ISO14000. He can be
reached at 314.434.3861, or by e-mail at
donaldsutherland-iso14000@worldnet.att.net.)
------------------------------
Date: Wed, 11 Feb 1998 14:02:47 -0500
From: Catherine.Duchock@stn.siemens.com
Subject: Environment and Safety
I am interested in feedback on combining Health and Safety issues into the
Environmental Management System - ISO 14000. Has this been done? EH&S
seem to go hand in hand in many instances. It seems to make sense so as
not to re-invent programs that could satisfy both Environmental and Safety
Regulations. Is there some reason NOT to incorporate my Health and Safety
programs under the ISO format?
------------------------------
Date: Wed, 11 Feb 1998 18:42:56 EST
From: JBSGS@aol.com
Subject: Re: Environment and Safety
Catherine,
Almost all of our clients at SGS ICS are combining H & S into their
environmental management systems - as you say, it is 'common sense' to do so.
The ISO 14001 standard is ambiguous on the inclusion or exclusion of some H &
S issues (ISO 14001 introduction, versus the definition of 'environment' in
section 3.2). Our view is that although we do not certify the H & S elements
of a management system, we will certainly consider during an audit the
potential internal impacts/controls etc. where they relate to an element which
would be construed as an 'environmental aspect' if the pathways and receptors
were (or could also be) "beyond the four walls" of the facility. For example:
Worker Exposure to heavy metal elements in the product. We do not, however,
presently consider H & S issues which could not be construed as environmental,
for example: confined space requirements, electrical wiring etc., although we
would not discourage companies from taking common-sense steps to incorporate
such elements under the 'umbrella' of their EMS.
To many in the USA, (probably wrongly and probably based upon the division of
regulatory enforcement here) this issue is black and white. To qualified
professional auditors there is certainly a gray line and we apply sound
technical judgement and our own common sense. To us, humans within the
facility can certainly be 'environmental receptors' and we also strongly
believe that they are 'interested parties' as defined in ISO 14001.
I would be happy to discuss this issue further if you are interested.
John Brookes
Sr. VP, SGS International Certification Services, Rutherford, New Jersey
(International Registrar and Training Organization)
------------------------------
Date: Thu, 12 Feb 1998 09:33:44 -0500
From: "Robert Clifford, Jr."
Subject: re: Environment and Safety
Catherine wrote:
>I am interested in feedback on combining Health and Safety
>issues into the Environmental Management System - ISO 14000.
>Has this been done? EH&S seem to go hand in hand in many instances.
>It seems to make sense so as not to re-invent programs that could
>satisfy both Environmental and Safety Regulations.
>Is there some reason NOT to incorporate my Health and
>Safety programs under the ISO format?
Combining health & safety with environmental management has been done
before -- particularly by my small business clients that develop (for cost
efficiency purposes) a single QMS for business, environment, health &
safety. In addition, organisations of many sizes have traditionally
combined EH&S administratively within one department and, in some cases, as
one individual's job function, because of the similarities in technical
discipline (science and engineering) and regulatory structure (EPA and
OSHA) that apply to each. Therefore, it makes sense to structure your
quality program that way.
There are other reasons. Registered companies (e.g. Cooper Auto Components
in Illinois) have cited the overlapping "requirements" under both OSHA and
ISO 14001, e.g. hazard communication, hazardous chemical identification,
control of hazardous energy sources, emergency evacuation, and secondary
labeling. An EMS could be used as a basis for a company to participate in
the Voluntary Protection Program. And OSHA's Safety and Health Program
Guidelines (54 FR 3904, January 26, 1989), which it continues to advocate
for employers wishing to prevent occupational injuries and illnesses,
contains elements remarkably consistent with an ISO 14001-conformant EMS.
Here in New York State, we're preparing an ISO 14001 seminar for small
businesses later in the spring. Our early feedback strongly indicated
interest in combining health & safety into the EMS; as a result, we've
included an OSHA representative in the seminar. He was happy to
participate and understood the links between an EMS and health & safety.
Finally, during EMS audits I've seen excellent H&S procedures and programs.
These programs equated safety in the home with safety in the workplace, in
order to make the message more relevant for workers. In addition, H&S
incident investigation procedures seemed more rigorous and strived for root
cause analysis -- possibly because of external drivers like OSHA
inspections and insurance issues. I felt these could have been easily
applied to environment (and for the same reasons) but weren't.
I hope you can avoid these inefficiencies. Good luck with your combined
program...
Robert Clifford, Jr., Vice President
ISO Environmental Consultancy, Inc.
1103 Glenwood Blvd.
Schenectady NY 12308-2503
518-393-3392
clifford@quality.org
------------------------------
Date: Fri, 13 Feb 1998 07:19:46 -0500 (EST)
From: "Bill Casti, CQA (System Administrator)"
Subject: Non-member submission from [Rick Gehrke ] (fwd)
NOTE: Respond *both* to the poster's address (see BELOW line reading
"Forwarded Message") and to the list's posting address, OR as directed in
the posting, but definitely NOT to me.
Thank you for your cooperation.
Bill
=============================================================================
Bill Casti, CQA Email: help@quality.org
Domain Owner, QUALITY.ORG Pager: +1 800 604 6149
=============================================================================
- ---------- Forwarded message ----------
Date: Thu, 12 Feb 1998 10:22:25 -0500 (EST)
Date: Thu, 12 Feb 1998 10:22:23 -0500
From: Rick Gehrke
To: Catherine.Duchock@stn.siemens.com
CC: iso14000@quality.org
Subject: Re: Environment and Safety
Catherine.Duchock@stn.siemens.com wrote:
> I am interested in feedback on combining Health and Safety issues into the
> Environmental Management System - ISO 14000. Has this been done? EH&S
> seem to go hand in hand in many instances. It seems to make sense so as
> not to re-invent programs that could satisfy both Environmental and Safety
> Regulations. Is there some reason NOT to incorporate my Health and Safety
> programs under the ISO format?
Dear Catherine:
The vast majority of our ISO 14001 registration clients have successfully
combined Health and Safety issues with their Environmental Management Systems.
In general, the same departments and management staff have been responsible for
environmental compliance, safety and health, and the EMS. We have seen many
EHS type programs expanded or modified to cover ISO 14001 requirements (e.g.
emergency preparedness and response, internal auditing (both system and
compliance), training, operational control, document control, communications,
etc.). One of the things you'll need to consider is clear definition of the
relationships between your EMS and your safety and health programs (e.g.
responsibilities, document control issues, etc). Any reasons for NOT
incorporating your Health and Safety programs with your EMS would be internal
to your organization. There is nothing in ISO 14001 or in the ANSI-RAB
National Accreditation Program for ISO 14001 registrars which would cause you
problems with combining the two systems.
- --
Rick Gehrke
VP Operations
AWM
http://www.awm.net
------------------------------
Date: Fri, 13 Feb 1998 07:49:20 -0500 (EST)
From: "Bill Casti, CQA (System Administrator)"
Subject: Non-member submission from [Arthur Costa de Souza ] (fwd)
NOTE: Respond *both* to the poster's address (see BELOW line reading
"Forwarded Message") and to the list's posting address, OR as directed in
the posting, but definitely NOT to me.
Thank you for your cooperation.
Bill
=============================================================================
Bill Casti, CQA Email: help@quality.org
Domain Owner, QUALITY.ORG Pager: +1 800 604 6149
=============================================================================
- ---------- Forwarded message ----------
Date: Fri, 13 Feb 1998 06:50:10 -0500 (EST)
From: Arthur Costa de Souza
Organization: ArtSim
To: iso14000@quality.org
Subject: iso14000/bs8800
Dear Sir,
I'm a journalist in Brazil and for four years I have been interviewing
companies certified by ISO 9000 standards.
However, now I have to interview one company that has just been
certified by BS 8800 and I cannot find anyting about this standard to
help me.
I'd be grateful if you could send me any information on BS 8800.
I take this oportunity to ask you to send me the number of certified
companies by ISO 14000 and BS 8800 all over the world.
I look forward to reading from you.
My e-mail is: artsim@uol.com.br
I thank you very much for your help.
Yours sincerely
Simone Martins Souza
------------------------------
Date: Fri, 13 Feb 1998 21:19:44 -0500 (EST)
From: "Bill Casti, CQA (System Administrator)"
Subject: Non-member submission from ["Chris E. Erker" ] (fwd)
NOTE: Respond *both* to the poster's address (see BELOW line reading
"Forwarded Message") and to the list's posting address, OR as directed in
the posting, but definitely NOT to me.
Thank you for your cooperation.
Bill
=============================================================================
Bill Casti, CQA Email: help@quality.org
Domain Owner, QUALITY.ORG Pager: +1 800 604 6149
=============================================================================
- ---------- Forwarded message ----------
Date: Fri, 13 Feb 1998 16:51:06 -0500 (EST)
From: "Chris E. Erker"
To: iso14000@quality.org
Greetings everyone. I am an attorney/consultant assisting a major U.S.
construction contractor with implementing an EMS based on ISO 14000. I
am presently drafting Operating Procedures (a.k.a. Level 3 documents)
for those activities that have significant environmental aspects. My
question to this experienced group is this: with the incredibly detailed
regulations and permit requirement that many U.S. facility operations are
subject to, how is the drafter of Operating Procedures supposed to
come to a happy medium between Procedures that are straightforward,
brief and to the point, and user-friendly, yet detailed enough to satisfy
regulatory requirements?
I know that ISO 14000 is not supposed to be a device that ensures
regulatory compliance, but if one drafts procedures that leave out
important regulatory or permit requirements, that person will be
institutionalizing a procedure that may fall short of what the government
(federal, state, and local) requires. The environment may be happy, but
the President of the company will not when (1) s/he realizes that the
procedures you drafted did not include those detailed requirements and
(2) some regulator nonetheless hits the company with an administrative
penalty because an employee's complete following of your Operating
Procedures was not enough to satisfy the regulatory or permit
requirements. Stated another way, why not just post any permits and
applicable regulations and say to the line employees, "here are your
operating procedures: know them and follow them!" Obviously this
approach would not be user-friendly, but it at least covers everything.
Being an attorney, I simply fear writing down what employees need to do
if what they really need to do is more.
Any thoughts or comments would be greatly appreciated. Thank you in
advance! Christopher Erker: CEE@GREENSFELDER.COM
------------------------------
Date: Sat, 14 Feb 1998 11:54:47 -0500
From: "Connie G. Ritzert"
Subject: Re: Chris Erker's question
Chris Erker asked for input on reconciling the ISO 14001 requirement for
operational control procedures with regulatory compliance requirements.
The way in which the questions was posed indicates there may be a couple
of misconceptions about ISO 14001.
In his message, Mr. Erker states:
"I know that ISO 14000 is not supposed to be a device that ensures
regulatory compliance, but . . "
Actually, ISO 14001 is intended to help an organization ensure regulatory
compliance. It does not demand demonstration of full compliance at any
given time ( e.g. in the certification audit), but several ISO 14001
provisions are specifically directed toward ensuring compliance, for
example:
- - the requirement that the environmental policy contain a commitment to
regulatory compliance and the requirement to implement that policy
- - the requirement in clause 4.3.2 for a procedure to identify and have
access to legal requirements
- - the requirement in clause 4.3.3 to consider legal requirements in
setting objectives and targets, and then to carry out plans to meet those
objectives
- - the requirement in clause 4.5.1 to periodically evaluate compliance using
documented procedures
These are explicit provisions that bear on compliance. There are many
implicit requirements that support measuresto comply, as in the corrective
action program, training, etc.
The problem of how to meet both ISO 14001 and regulatory requirements,
therefore, is really one problem - the two are not driving in different
directions.
Another clarification about ISO 4001 intentions - the requirements for
operational control procedures ask you to examine your processes and
determine what needs to be done to operate them to achieve your own
criteria and objectives. Since your objectives will include regulatory
compliance, you can read that requirement as : examine your processes and
determine what needs to be done to operate them to achieve regulatory
compliance and meet any other internal criteria. Keeping work
instructions simple and do-able is a practical necessity, whether for
regulatory requirements or others. With or without ISO 14001, there is a
challenge to convert complicated regulations into procedures that
individuals can use to stay in compliance. ISO 14001 simply provides some
structure for that effort and asks you to look not just at regulatory
requirements but also at other aspects that may need to be managed.
That being said, I agree that translating regulatory requirement into
simple and usable instructions is, indeed, a difficult task. That task is
present with or without ISO 14001. Hopefully, ISO 14001 will facilitate,
not complicate the process.
Connie G. Ritzert critzert@fyi.net
Meredith-EMC environmental management consulting
------------------------------
Date: Mon, 16 Feb 1998 11:43:40 +0100
From: "Dawes, Simon"
Subject: [none]
Catherine Duchock raised a question regarding the integration of OHS and
environmental systems,
It is a definite plus for ease of operational use to integrate OHS and
EMS requirements into the one management system. It is quite clear that
ISO14001 adopts an identify>control>monitor approach to the management
of environmental risk, and that OHS can be implemented with a similar
approach. A generic risk management approach to the control of system
outcomes (regardless of the system or the outcomes under control) can be
used as the basis of managing quality, safety and environmental risk.
For those companies developing systems for certification/registration,
it should be the responsibility of the certification/registration body
to adopt their approach to your system implementation, and not the other
way around.
Quality systems to ISO9000 have been in use in Australia for many years
now, and those companies who have been operating systems for a number of
years are consistently aiming to operate integrated systems. I prepared
an article describing the integration of quality, environmental and
safety systems using a risk based approach that was published in the
Quality Magazine of the Quality Society of Australasia which is
available to those who are interested.
Best Regards
Simon Dawes
DNV Certification Pty Ltd
Ph: +61 2 9900 9537
Fx: +61 2 9929 8792
Mb: +61 4 1820 0513
email: Simon.Dawes@dnv.com
Best Regards
Simon Dawes
DNV Certification Pty Ltd
Ph: +61 2 9900 9537
Fx: +61 2 9929 8792
Mb: +61 4 1820 0513
email: Simon.Dawes@dnv.com
>-----Original Message-----
>From: Catherine.Duchock@stn.siemens.com
>[SMTP:Catherine.Duchock@stn.siemens.com]
>Sent: Thursday, February 12, 1998 6:03 AM
>To: iso14000@quality.org
>Subject: Environment and Safety
>
>
>
>I am interested in feedback on combining Health and Safety issues into the
>Environmental Management System - ISO 14000. Has this been done? EH&S
>seem to go hand in hand in many instances. It seems to make sense so as
>not to re-invent programs that could satisfy both Environmental and Safety
>Regulations. Is there some reason NOT to incorporate my Health and Safety
>programs under the ISO format?
>
------------------------------
Date: Mon, 16 Feb 1998 07:52:17 -0800
From: "Bert P. Krages"
Subject: Re: Chris E. Erker Question Regarding Procedures and Legal Req'ts
The issue of drafting operating procedures to ensure compliance with legal
requirements can be difficult but does not necessarily have to be. The
easiest, and most effective means, of doing this for most facilities and
projects is to prepare a summary of the legal requirements that must be
followed instead of setting out the universe of requirements and expecting
people to memorize in their spare time. Often, procedures can be compacted
by setting forth circumstances in which employees must contact a designated
person with the expertise needed to evaluate and handle the situation
properly. For example, instead of setting forth all the regulations
applicable to working with asbestos containing materials, the procedures
could instruct employees on a demolition job who find insulation that does
not bear an asbestos-free label to contact "Mr. Insulation" before
proceeding further. The contacted person would then be responsible for
evaluating whether the insulation contained asbestos and setting up
whatever procedures needed to be followed to comply with legal requirements.
>Date: Fri, 13 Feb 1998 16:51:06 -0500 (EST)
>From: "Chris E. Erker"
>To: iso14000@quality.org
>
>Greetings everyone. I am an attorney/consultant assisting a major U.S.
>construction contractor with implementing an EMS based on ISO 14000. I
>am presently drafting Operating Procedures (a.k.a. Level 3 documents)
>for those activities that have significant environmental aspects. My
>question to this experienced group is this: with the incredibly detailed
>regulations and permit requirement that many U.S. facility operations are
>subject to, how is the drafter of Operating Procedures supposed to
>come to a happy medium between Procedures that are straightforward,
>brief and to the point, and user-friendly, yet detailed enough to satisfy
>regulatory requirements?
>
>I know that ISO 14000 is not supposed to be a device that ensures
>regulatory compliance, but if one drafts procedures that leave out
>important regulatory or permit requirements, that person will be
>institutionalizing a procedure that may fall short of what the government
>(federal, state, and local) requires. The environment may be happy, but
>the President of the company will not when (1) s/he realizes that the
>procedures you drafted did not include those detailed requirements and
>(2) some regulator nonetheless hits the company with an administrative
>penalty because an employee's complete following of your Operating
>Procedures was not enough to satisfy the regulatory or permit
>requirements. Stated another way, why not just post any permits and
>applicable regulations and say to the line employees, "here are your
>operating procedures: know them and follow them!" Obviously this
>approach would not be user-friendly, but it at least covers everything.
>Being an attorney, I simply fear writing down what employees need to do
>if what they really need to do is more.
>
>Any thoughts or comments would be greatly appreciated. Thank you in
>advance! Christopher Erker: CEE@GREENSFELDER.COM >
Bert P. Krages II
Environmental Law and Mediation
900 S.W. Fifth Avenue, Suite 1900
Portland, Oregon 97204
Law:
Mediation:
------------------------------
Date: Mon, 16 Feb 1998 11:41:01 -0500
From: Michael Snider
Subject: re: Operating Procedures
Chris, one thing we've done is to flowchart the procedure, and then expand upon the flow chart with references to a detailed guide for involved steps. For example, one "bubble" might say "Determine need to contact agency", and detailed instructions would
be in the referenced guide. That way the procedure is kept clean, yet enough detail is accessible to handle all the permutaions in the process. If the flowchart is drawn so that the sheet is divided vertically into columns, each column can represent a d
epartment or group. Then the procedure can also convey responsibilities and points of communication.
- ---------- Forwarded message ----------
Date: Fri, 13 Feb 1998 16:51:06 -0500 (EST)
From: "Chris E. Erker"
To: iso14000@quality.org
Greetings everyone. I am an attorney/consultant assisting a major U.S.
construction contractor with implementing an EMS based on ISO 14000. I
am presently drafting Operating Procedures (a.k.a. Level 3 documents)
for those activities that have significant environmental aspects. My
question to this experienced group is this: with the incredibly detailed
regulations and permit requirement that many U.S. facility operations are
subject to, how is the drafter of Operating Procedures supposed to
come to a happy medium between Procedures that are straightforward,
brief and to the point, and user-friendly, yet detailed enough to satisfy
regulatory requirements?
Michael Snider
e-mail: sniderm@wv.doe.gov
Tel: 716-942-2024
Fax: 716-942-2000
West Valley Nuclear Services
MS-AOC-16
10282 Rock Springs Road
West Valley, NY 14171-0191
------------------------------
Date: Mon, 16 Feb 1998 13:09:18 -0500
From: "Robert Clifford, Jr."
Subject: Re: Chris Erker's Question
Chris Ercker wrote:
>... with the incredibly detailed regulations and permit requirement (sic)
> that many U.S. facility operations are
>subject to, how is the drafter of Operating Procedures supposed to
>come to a happy medium between Procedures that are straightforward,
>brief and to the point, and user-friendly, yet detailed enough to satisfy
>regulatory requirements?
This is one of the more common problems reported by ISO-implementation
teams: how to take the U.S.C., 40 CFR, and reams of agency guidance, and
distill it down to simple English (or, in some cases, Spanish / French /
etc.). Remain mindfull of ISO-axiom #1 -- does everyone know his/her role
in the environmental management system, and have the resources available to
carry-out that role -- and consider the following:
1. Don't re-invent the wheel. Find out how the company is presently
complying with its permits and regulatory requirements. Is any of that
written down ? If so, you've got your level 3 documentation (for now) --
move on to something else. One of the great things about ISO is you can
always go back to something. (One of the bad things about ISO is that you
must continually go back to something !!)
2. Idea good -- paper bad. Avoid putting together a big honking binder
with all of your permits and other environmental paperwork and labeling it
"ISO". I'm not saying that's your current undertaking, I'm just
suggesting that your focus be on developing your EMS system / manual, not
your compliance system / manual. Remember, documentation is "required" for
only eight elements of ISO 14001and procedures (usually documented at level
2) for only ten elements. These are system elements, not elements of 40
CFR.
3. Writing operating instructions can be part of your system, not a
prelude to your system. Again, nothing in ISO says that one of your first
objectives (of your registered system) can't be an overhaul of your
compliance operating instructions, particularly if compliance is a
significant environmental aspect that your company is having problems with.
Developing operating instructions takes time and care and is, in my
opinion, a worthy first-objective of an EMS.
4. Permits make lousy operating instructions. Yes, I've seen
organizations where environmental permits are posted at the work stations
of involved employees -- but it's more to give them a sense of awareness
than to use as operating instructions. The level of responsibility for
compliance varies within an organization, as I'm sure you know. Rather
than attaching permit requirements to everyone's work instructions, so that
you "cover everything", spend more time with the procedure to address
training, awareness and competance (4.4.2) so that everyone can better
understand how what they do impacts those "detailed requirements" in the
regulation. The former seems like a reactive "legal" fix -- the latter is
a proactive "system" fix.
Robert Clifford, Jr.
ISO Environmental Consultancy, Inc.
clifford@quality.org
------------------------------
End of iso14000-digest V2 #26
*****************************