iso14000-digest Thursday, July 2 1998 Volume 02 : Number 036
----------------------------------------------------------------------
Date: Sun, 21 Jun 1998 22:02:27 +0200
From: "Pepper, John"
Subject: RE: ISO14001 and airlines
Two to my knowledge are both in Korea. I was part of the audit team for
BVQI for the UKAS ISO 14001 audit of Asiana Airlines way back in
December 1995. Korean Air also achieved certification last year under
the RvA scheme with DNV Certification Services
Regards
John Pepper
Lead EMS Auditor
Det Norske Veritas Quality Assurance Ltd
Palace House
3 Cathedral Street
London SE1 9DE
United Kingdom
( + 44 (0) 171 357 6080 (Main Switchboard)
* (E-mail) john.pepper@dnv.com
- -----Original Message-----
From: Sinisa M Djordjevic [SMTP:SDJORDJ@prodigy.net]
Sent: Thursday, June 18, 1998 1:31 PM
To: Paul Reed; 'ISO14000 list'
Subject: Re: ISO14001 and airlines
> Following on from the theme of airports and ISO14001 - I wonder if
anyone
knows of any AIRLINES which
> have implemented such a system ?
> Paul Reed
> Environmental Adviser,
> RCC, Stavanager, Norway.
Its not clear whether Swissair has achieved ISO 14001 registration but
they
certainly seem ready. Please see
the following site.
http://www.swissair.com/aboutus/swissair/environment.htm
Sinisa Djordjevic
DJINDECO Consulting
------------------------------
Date: Tue, 23 Jun 1998 23:53:15 -0400 (EDT)
From: "Bill Casti (System Admin)"
Subject: Non-member submission from [Reinaldo Ramirez ] (fwd)
NOTE: Respond *both* to the poster's address (see BELOW line reading
"Forwarded Message") and to the list's posting address, NOT to me.
=============================================================================
Bill Casti, CQA Email: help@quality.org
Domain Owner, QUALITY.ORG Pager: +1 800 604 6149
=============================================================================
- ---------- Forwarded message ----------
Date: Tue, 23 Jun 1998 10:15:24 -0400 (EDT)
To: Percy Garcia
CC: iso14000@quality.org
Subject: Re: Multinational Corporations and ISO14000
Percy Garcia wrote:
> Hello to everyone!
>
> I am doing a research on multinational corporations and the
> implementation of ISO14000 within them. Does anyone have information
> about the number of multinationals currently operanting under ISO14000,
> and information about the process of implemention?
>
> Thank you very much your attention!
>
> Percy L. Garcia
> The University of Calgary
> Faculty of Environmental Design
Chrysler of Venezuela is implementing a EMS based in ISO 14001 standard.If
you wish to know the address of Chrysler in Venezuela search it at
http://www.chevere.com/.
------------------------------
Date: Thu, 25 Jun 1998 15:04:20 +0100
From: "Aleksander Mortensen"
Subject: Second call for help
I refer to my message from a couple of days ago and repeat our pleed for
assistance.
Institute of Environmental Management, Associate Membership Exam, June 1998
Assessment, Question 3:
You have identified a number of environmental impacts generated by your
organisation's activities. How would you go about evaluating which of these
were significant?
Other questions are contained in my last posting to the group, we appreciate
any comments.
Regards,
Class of '98
BSc(hons) Environmental Management
University of Dundee
E-mail: aleksander@aleksander.com
Web: http://home.sol.no/~siljam/
------------------------------
Date: Thu, 25 Jun 1998 11:17:15 EDT
From: Dmhunterjr@aol.com
Subject: Re: Second call for help
In a message dated 98-06-25 10:48:37 EDT, aleksander@aleksander.com writes:
<< Institute of Environmental Management, Associate Membership Exam, June 1998
Assessment, Question 3:
You have identified a number of environmental impacts generated by your
organisation's activities. How would you go about evaluating which of these
were significant?
>>
Test number one--are these impacts controlled by governmental actions either
through statutes or regulations; if so, these governmental requirements will
determine whether the impacts are significant. That is, if the impact exceeds
the govewrnment's threshold, then it is a significant impact. This definition
may not appeal to everyone since it links significance to compliance but it is
hard for me to accept that the reverse is true.
Test number two--do such impacts have to potential for polluting an
environmental resource to a degree that would prevent the resource from
fulfilling its pre-pollution use. This definition links significance to
irreversible harm.
Dennis M. Hunter, Jr.
The Derado Group
------------------------------
Date: Thu, 25 Jun 1998 11:51:42 -0400
From: hboyter@cstone.net (Henry Boyter Jr.)
Subject: Re: Second call for help
This is an opened ended question that depends on many factors. The first thing to decide is the
definition of impact and significant. Everything humans do have an impact and I suspect you have more
information on what is meant. Significant can mean several things:
1:1000000 chance of humans getting cancer
immediate danger to human health
immediate danger to wildlife
chronic danger to wildlife
bioaccumulation in sediments
etc,etc
I think the question is asking you to formulate how you would create these definitions and what factors
are involved.
Dr. Henry Boyter, Jr. Ph.D. Chemist
The opinions of Dr. Boyter are provided for informational purposes only and should not be used as
advice. No warranty or expression of professionalism is implied.
- -----Original Message-----
From: Aleksander Mortensen
To: iso14000@quality.org
Date: Thursday, June 25, 1998 10:51 AM
Subject: Second call for help
I refer to my message from a couple of days ago and repeat our pleed for
assistance.
Institute of Environmental Management, Associate Membership Exam, June 1998
Assessment, Question 3:
You have identified a number of environmental impacts generated by your
organisation's activities. How would you go about evaluating which of these
were significant?
Other questions are contained in my last posting to the group, we appreciate
any comments.
Regards,
Class of '98
BSc(hons) Environmental Management
University of Dundee
E-mail: aleksander@aleksander.com
Web: http://home.sol.no/~siljam/
------------------------------
Date: Thu, 25 Jun 1998 12:11:03 -0500
From: Salvador Lucar Lucar
Subject: RE: Second call for help/SLucar
> In a message dated 98-06-25 10:48:37 EDT, aleksander@aleksander.com
> writes:
>
> << You have identified a number of environmental impacts .... How would
> you go about evaluating which of these were significant?
>>
To determine significant environmental impacts, I would take into
account environmental and business considerations such as:
Environmental >>Severity, Likelihood, Amplitude, Duration of the
impact.
Business >> Cost, potential regulatory problems, effect on other
processes, relationship with stakeholders, etc. resulting from the impact.
This considerations would be called Significance Criteria.
Then, I would use a matrix like the following:
Impact | Frecuency | Significance Criteria |
Significant?
- ----------------------------------------------------------------------------
- ---------
| A | B
| C | D | E |
- ----------------------------------------------------------------------------
- ---------
H2SO4 | S | H | L | H | M | L |
Yes!
spilling
- ----------------------------------------------------------------------------
- ---------
Where Frecuency could be: C: Continuous, S: sporadic, A: accidental
The significance criteria could be measured as H:High M:Medium L:
Low
Then WE could make up a simple rule to determine which impact is
significant, e.g.
two Highs and a Continuous is Significant; one High and an sporadic
is significant, etc.
It is important to clear out that regulatory requirements are not
the only source of information
to determine Environmental impact significance, specially in
countries where environmental legislation is incipient.
I would like to see more answers on this.
Salvador Lucar
GMD S.A.
slucar@gmd.com.pe
------------------------------
Date: Thu, 25 Jun 1998 14:55:51 EDT
From: Dmhunterjr@aol.com
Subject: Re: Second call for help/SLucar
Salvador Lucar,
Apologies, but my system made a mess of your matrix. Please restate what the
rows and columns would be. Also, a question--how do you differentiate the
difference between "high", "medium" and "low".
Dennis Hunter
------------------------------
Date: Thu, 25 Jun 1998 16:34:20 -0700
From: "Bert P. Krages"
Subject: Effectiveness of Environmental Policies
One of the cornerstones of ISO 14001 and other environmental management
systems is the adoption of environmental policies. Although the literature
on environmental management systems seems to take the issue of policies for
granted, I was curious whether anyone on this list is aware of actual
studies (such as in the psychology or business literature) that have
evaluated whether organizational policies are effective and if so then what
factors contribute to effectiveness.
Bert P. Krages II
Environmental Law and Mediation
900 S.W. Fifth Avenue, Suite 1900
Portland, Oregon 97204
Law:
Mediation:
------------------------------
Date: Fri, 26 Jun 1998 08:37:39 -0500
From: Salvador Lucar Lucar
Subject: RE: Second call for help/SLucar
Guys,
I am sending the matrix in this attachment:
<>
Salvador Lucar
GMD S.A.
Slucar@gmd.com.pe
> -----Original Message-----
> From: Dmhunterjr@aol.com [SMTP:Dmhunterjr@aol.com]
> Sent: Jueves 25 de Junio de 1998 1:56 PM
> To: SLucar@gmd.com.pe; aleksander@aleksander.com; iso14000@quality.org
> Subject: Re: Second call for help/SLucar
>
> Salvador Lucar,
> Apologies, but my system made a mess of your matrix. Please restate what
> the
> rows and columns would be. Also, a question--how do you differentiate the
> difference between "high", "medium" and "low".
> Dennis Hunter
begin 600 Impactsmatrix.txt
M26UP86-T"7P@1G)E8W5E;F-Y"0E\(%-I9VYI9FEC86YC92!#
Subject: Non-member submission from [Fran Martin ] (fwd)
NOTE: Respond *both* to the poster's address (see BELOW line reading
"Forwarded Message") and to the list's posting address, NOT to me.
=============================================================================
Bill Casti, CQA Email: help@quality.org
Domain Owner, QUALITY.ORG Pager: +1 800 604 6149
=============================================================================
- ---------- Forwarded message ----------
Date: Mon, 29 Jun 1998 09:42:26 -0400 (EDT)
To: iso14000-digest@quality.org
From: Fran Martin
Subject: OSHA Chemical / Solvent Safety CD-ROMs
FYI,
List members responsible for chemical safety and compliance may find the
OSHA Chemical Safety and the Solvent Safety Databases on CD-ROM useful
reference tools.
The PDF format offers instant search / retrieval and page-for-page accuracy.
See http://www.env-sol.com/#ChemRefs for further information.
Fran Martin
FM Research & Consulting
------------------------------
Date: Tue, 30 Jun 1998 04:38:27 -0400 (EDT)
From: "Bill Casti (System Admin)"
Subject: Non-member submission from [Greg Loftus ] (fwd)
NOTE: Respond *both* to the poster's address (see BELOW line reading
"Forwarded Message") and to the list's posting address, NOT to me.
=============================================================================
Bill Casti, CQA Email: help@quality.org
Domain Owner, QUALITY.ORG Pager: +1 800 604 6149
=============================================================================
- ---------- Forwarded message ----------
Date: Tue, 30 Jun 1998 02:12:10 -0400 (EDT)
From: Greg Loftus
To: "'ISO14000 Infoline'"
Dear All,
Once again thankyou to all those who responded to my last query a couple
of months ago. I now have a new plea for information / direction. I am
giving a lecture in a couple of weeks on 'Information Technology in EMS'
has anyone come across any articles or information relating to this topic
in recent months? If so, I would love to hear from you.
Thanks in avance, Greg Loftus
GregLoftus@ermsydney.erm.com.au
------------------------------
Date: Tue, 30 Jun 1998 18:57:21 -0400
From: "Connie G. Ritzert"
Subject: Regulated Aspects
Dear colleagues: At the TC207 meeting in San Francisco a week or so ago,
I happened to talk with several other delegates about a subject near and
dear to our hearts - namely, environmental aspects. In particular, I found
that there is considerable controversy around the relationship between
"significance" and regulated aspects. If we who have been so close to this
subject for the last 5 years are not in agreement on this, there are
probably many other diverging opinions among those implementing or auditing
ISO 14001. The point of contention is: Should all environmental
aspects / impacts which are regulated by governmental bodies be considered
"significant" in an ISO 14001 EMS ?
Since this is an important point, it would be interesting to get some
input from those of you who subscribe to this list. I will refrain from
giving my opinion until some other voices are heard.
What do you think . . . and why?
Connie Glover Ritzert critzert@fyi.net
Meredith-EMC environmental management consulting
Mars, PA USA
------------------------------
Date: Tue, 30 Jun 1998 22:41:12 -0400
From: Rick Gehrke
Subject: Re: Regulated Aspects
Connie G. Ritzert wrote:
> Dear colleagues: At the TC207 meeting in San Francisco a week or so ago,
> I happened to talk with several other delegates about a subject near and
> dear to our hearts - namely, environmental aspects. In particular, I found
> that there is considerable controversy around the relationship between
> "significance" and regulated aspects. If we who have been so close to this
> subject for the last 5 years are not in agreement on this, there are
> probably many other diverging opinions among those implementing or auditing
> ISO 14001. The point of contention is: Should all environmental
> aspects / impacts which are regulated by governmental bodies be considered
> "significant" in an ISO 14001 EMS ?
There is no requirement, as far as registration goes, for organizations to
consider all regulated aspects significant. It has been the practice of some
organizations to automatically consider any regulated aspect as significant.
Doing this does not release the organization from evaluating those aspects to
determine if they have or can have significant impacts on the environment, in
accordance with ISO 14001 section 4.3.1. The procedure(s) and criteria used
for determining significance must be applied to all aspects, regulated or not.
In my experience, organizations which have classified regulated aspects as
significant regardless of their relative impact have done it so they could use
the EMS as a systematic method of maintaining compliance, and helping them to
support the environmental policy's commitment to comply with relevant
environmental legislation and regulations. From an implementation and
usefulness perspective, automatically classifying regulated aspects as
significant may be quite useful. With regard to formal registration of an EMS,
I don't think there's any advantage to be gained by requiring it.
Rick Gehrke
AWM ISO 14000 Registration Services
http://www.awm.net/iso/
------------------------------
Date: Tue, 30 Jun 1998 23:52:53 -0400
From: Diana Baldi
Subject: Regulated Aspects
Connie,
Thanks for opening a worthwhile dialog on an essential topic Here's one
opinion: to automatically count anything regulated as significant can be
useful for companies that are still quite occupied in having surprise
non-compliance issues that keep the organization spiraling into
fire-fighting and reactive modes of operation. For companies where
non-compliance is rare, to make everything regulated as significant is
non-value added. For many compliant companies this is a very difficult
concept because they do not want to pursue the bunny and tree hugging
stance and potentially shift attention away from staying in
compliance.....and get into having surprise compliance problems. For
compliant companies, to make all regulated things significant can:
a) drive the EMS to remain reactive to compliance and miss opportunities to
be proactive and focused on business benefits
b) may overwhelm the system with relatively non-significant issues that
happen to be regulated and mask those higher risk issues that don't happen
to be regulated (we can still remember when legal activities became
Superfund sites, right??)
c) generate an overall internal impression that this NEW EMS is the same
ol' same ol'
When compliance is focused on Legal and Other and Operational Control
clauses and significance is aligned with the company's policy, values, and
priorities, the resulting EMS can generate outstanding results for the
company, including financial benefits.
I'm looking forward to lots of additional views being expressed on this
topic....
Diana Baldi
------------------------------
Date: Wed, 1 Jul 1998 08:19:36 -0400
From: Jim Smith
Subject: RE: Regulated Aspects
I too am curious about the question of whether or not significant aspects includes regulated aspects. I first heard this assertion made at a seminar put on last February by one of the U.S. TAG Experts to TC207.
I do not agree with it. ISO14001 clearly separates significant aspects and regulated aspects. To begin with, paragraph 4.3.1 is about identifying environmental aspects. Paragraph 4.3.2 is then about identifying legal and other requirements. Reading o
n down in the standard, paragraph 4.3.3 states "When establishing and reviewing its objectives, an organization shall consider the legal and other requirements, its significant environmental aspects, its...." Whoever wrote this was certainly considering
the two to be separate. And those of us who voted on it were also considering the two to be separate.
If you read ISO14001 all the way through, you will note that it is fairly consistent on this point. Interestingly, the seminar I attended had an exercise for determining significant aspects of a mock company. In the exercise, not all regulated aspects
met the criteria for significant aspects as spelled out in the exercise. So even though the course facilitator was advocating the position that all regulated aspects are significant aspects, the documentation he provided with the seminar said just the op
posite. From the standpoint of how ISO14001 is written, I believe that the course documentation was correct. Regulated aspects are NOT necessarily significant aspects.
James L. Smith
MEGA-TECH Program Manager
(703)-534-1629
jlsmith-1@mgtech-world.com
- ----------
From: Connie G. Ritzert[SMTP:critzert@fyi.net]
Sent: Wednesday, July 01, 1998 7:48 AM
To: 'iso14000@quality.org'
Subject: Regulated Aspects
Dear colleagues: At the TC207 meeting in San Francisco a week or so ago,
I happened to talk with several other delegates about a subject near and
dear to our hearts - namely, environmental aspects. In particular, I found
that there is considerable controversy around the relationship between
"significance" and regulated aspects. If we who have been so close to this
subject for the last 5 years are not in agreement on this, there are
probably many other diverging opinions among those implementing or auditing
ISO 14001. The point of contention is: Should all environmental
aspects / impacts which are regulated by governmental bodies be considered
"significant" in an ISO 14001 EMS ?
Since this is an important point, it would be interesting to get some
input from those of you who subscribe to this list. I will refrain from
giving my opinion until some other voices are heard.
What do you think . . . and why?
Connie Glover Ritzert critzert@fyi.net
Meredith-EMC environmental management consulting
Mars, PA USA
------------------------------
Date: Wed, 01 Jul 1998 08:36:31 -0400
From: "Neil G. Vander Linden"
Subject: Significant & regulated aspects
My response to Connie Ritzert's message concerning significant and
regulated impacts is quite simple. The standard requires that an
organization establish and maintain procedures to identify aspects and in
order to determine significant aspects. The organization decides what
this procedure will be. If it weights regulated activities with a higher
score and these end up being the significant aspects, so be it. Hopefully,
however, there will be at least some significant aspects above and
beyond that which is regulated. Whether or not the organization
describes its regulated activities as significant aspects, however, the
standard in section 4.3.3 requires legal requirements as well as
significant aspects to be considered in setting objectives and targets.
The bottom line for me is that the organization decides. It is not up to
auditors or consultants to tell as organization how to define significant
aspects.
>From discussions with colleagues I have discovered that in most
organizations the significant aspects are mostly regulated aspects.
Neil Vander Linden
ngvande@westvaco.com
"Dear colleagues: At the TC207 meeting in San Francisco a week or so
ago,
I happened to talk with several other delegates about a subject near and
dear to our hearts - namely, environmental aspects. In particular, I found
that there is considerable controversy around the relationship between
"significance" and regulated aspects. If we who have been so close to
this
subject for the last 5 years are not in agreement on this, there are
probably many other diverging opinions among those implementing or
auditing
ISO 14001. The point of contention is: Should all environmental
aspects / impacts which are regulated by governmental bodies be
considered
"significant" in an ISO 14001 EMS ?
Since this is an important point, it would be interesting to get some
input from those of you who subscribe to this list. I will refrain from
giving my opinion until some other voices are heard.
What do you think . . . and why?
Connie Glover Ritzert critzert@fyi.net
Meredith-EMC environmental management consulting
Mars, PA USA"
------------------------------
Date: Wed, 1 Jul 1998 20:56:10 +0200
From: "Pepper, John"
Subject: RE: Regulated Aspects
Dear All
This is an issue that has been around from the very beginning of
certification. I can give you some feedback based on our certification
experience in the UK. There is no doubt that most if not all companies
use the question "Is the aspect addressed by legislation?" as one of
the criterion for determining significance. We have no problems with
this - it is a logical and sound basis for helping the organisation
focus on areas where they may be at risk.
On a number of occasions, we have come across the situation where an
aspect is controlled by legislation, but was not (initially)
considered significant. The conversation usually goes something like
this:
DNV "Can you explain why hazardous waste disposal is not a significant
aspect of your operations?"
Environmental Manager "Because we have it really well managed"
DNV "Why do you have it really well managed?"
EM "Because its important, we don't want to be prosecuted"
Replace important with "significant" and the loop is closed!
The point here is that the system must be capable of delivering legal
compliance. If something is not significant, then there is no
requirement for that activity to be part of the EMS. I have yet to
come across a logical reason why activities should be excluded if they
are control by legislation. Of course, different criteria will be need
for resource based issues and we would expect to see this. If the
methodology for determining significance is not logical and sound we
would raise a nonconformity against the standard.
I can however, appreciate that this criterion may not act as an
effective "filter" in an organisation with a large number of permits -
i.e. every activity comes out the evaluation ranked as "significant".
I would expect that the organisation has in place operational control
(or another method of management) over all activities that could
impact on legal compliance, so this may well be the logical answer.
Another management decision may be required as to which aspects can
be addressed by setting improvement objectives, and here there is
nothing to stop the organisation introducing different degrees of
"significance" to help them prioritise aspects.
Hope this helps.
John Pepper
Lead EMS Auditor
Det Norske Veritas Quality Assurance Ltd
Palace House
3 Cathedral Street
London SE1 9DE
United Kingdom
Tel + 44 (0) 171 357 6080 (Main Switchboard)
(E-mail) john.pepper@dnv.com
- -----Original Message-----
From: Connie G. Ritzert [SMTP:critzert@fyi.net]
Sent: Tuesday, June 30, 1998 11:57 PM
To: 'iso14000@quality.org'
Subject: Regulated Aspects
Dear colleagues: At the TC207 meeting in San Francisco a week or so
ago,
I happened to talk with several other delegates about a subject near
and
dear to our hearts - namely, environmental aspects. In particular, I
found
that there is considerable controversy around the relationship between
"significance" and regulated aspects. If we who have been so close to
this
subject for the last 5 years are not in agreement on this, there are
probably many other diverging opinions among those implementing or
auditing
ISO 14001. The point of contention is: Should all environmental
aspects / impacts which are regulated by governmental bodies be
considered
"significant" in an ISO 14001 EMS ?
Since this is an important point, it would be interesting to get some
input from those of you who subscribe to this list. I will refrain
from
giving my opinion until some other voices are heard.
What do you think . . . and why?
Connie Glover Ritzert critzert@fyi.net
Meredith-EMC environmental management consulting
Mars, PA USA
------------------------------
Date: Thu, 2 Jul 1998 12:34:49 +0100
From: "Entropy International"
Subject: RE: Regulated Aspects
Dear all,
We here at Entropy are intrigued by your current conversation on aspects and
significance. We have worked with this issue for the last two years.
All recent correspondents bring up interesting, but different points.
Connie - Should all regulated aspects be significant - good question
Dianne - comments about proactive and reactive: very sound
Rick - feeling that regulated must be apart of a significance assessment:
agreed
Neil - must maintain a procedure for identifying...: true
John - a combination of these is often applied: exactly
Having encountered the problem of assessing and prioritizing aspects during
EMS implementation, we have developed a methodology and a software tool,
'The Significance Wizard', that helps assesses significance based on a
number of factors (one of which is in fact regulation, the others being
related to quantity, frequency, relation to global environmental problems,
stakeholder views and severity of environmental impact). As consultants we
use the Wizard and have successfully implemented a number of certified and
certifiable EMS using the methodology.
More information on the Significance Wizard can be found at:
http://www.entropy/ndirect.co.uk/sigwiz/index.htm
As all of us seem to agree, a "significance test" is conducted to determine
what environmental aspects are the most important to manage and improve.
But.... The evaluation will always be subjective and it will vary from
organization to organization. Furthermore, the evaluation need not reflect
the level of control of an aspect, why the hazardous waste in John's example
could very well be considered significant. To control a significant aspect
can involve minimizing the environmental impact without necessarily
addressing the aspect itself. Even when controlled and minimized the aspect
can still be significant. Only when the cause of the effect (the aspect
itself) is addressed or even eliminated, it can be taken of the "significant
list". On the other hand, legislation per se need not be a reason to
automatically consider an aspect significant. Significance can depend on
several factors such as applicable legislation, environmental impact,
quantity, frequency, cost, possibility of savings and views of interested
parties. Since commitment to compliance with environmental legislation is a
requirement of ISO 14001 most organizations choose to consider regulated
status when prioritizing environmental aspects but as we perceive it, there
is no absolute requirement to do so.
We would be most interested in comments from any or all and hope that The
Significance Wizard may make what can be quite a complicated matter easier
and less complicated for the average environmental manager confronted with
this.
P.S. As other certification bodies have 'endorsed' the Significance Wizard,
we would be particularly interested in your thoughts.
Kind regards,
Hewitt Roberts
Agneta Gerstenfeld
------------------------------
Date: Thu, 2 Jul 1998 17:35:14 +0100
From: "Entropy International"
Subject: discussion on aspects
This is a multi-part message in MIME format.
- ------=_NextPart_000_0004_01BDA5DF.C5639610
Content-Type: text/plain;
charset="iso-8859-1"
Content-Transfer-Encoding: 7bit
Sorry about the broken link regarding the discussion on aspects.
You should find that the correct link is
http://www.entropy.ndirect.co.uk/sigwiz/index.htm
Sincerely
Hewitt & Agneta
- ----------------------------------------------------------------------
Entropy International
Suite 8, Church House
96 St. Mary's Gate
Lancaster, LA1 1TD
United Kingdom
Ph: +44 (0)1524 389385
Fax: +44 (0)1524 389386
http://www.entropy-international.com
------------------------------
Date: Thu, 02 Jul 1998 22:49:55
From: "Jup van 't Veld"
Subject: Re: Regulated Aspects
Dear Connie and other listers,
Frankly, I have a problem seeing the problem.
An EMS must address all significant environmental aspects, which may or may
not be (explicitly) regulated. For example, in many countries there is
hardly any regulation on carbon dioxide emissions, which may however be a
dominant aspect in certain industries.
At the same time, an EMS must address all relevant legal requirements,
which may or may not be about environmental aspects. For example, in the
Netherlands there is a legal requirement to consult works councils on
environmental programmes, investment decisions etc. This is very relevant
for the system, but is not an environmental aspect.
So if an activity has a certain environmental aspect which happens to be
regulated, it must be identified either because it is significant or
because regulations require it, or both.
I have tried, but I cannot think of an example where a regulated
environmental aspect would not be identified, yet the certifying body
would not write a non-conformity. So what exactly is the point I am missing?
Jup van 't Veld
TU env. exp.
------------------------------
Date: Wed, 01 Jul 1998 13:27:50 +0000
From: Gabor Doka
Subject: Re: Regulated Aspects
Connie G. Ritzert wrote:
>
> Dear colleagues: At the TC207 meeting in San Francisco a week or so ago,
> I happened to talk with several other delegates about a subject near and
> dear to our hearts - namely, environmental aspects. In particular, I found
> that there is considerable controversy around the relationship between
> "significance" and regulated aspects. If we who have been so close to this
> subject for the last 5 years are not in agreement on this, there are
> probably many other diverging opinions among those implementing or auditing
> ISO 14001. The point of contention is: Should all environmental
> aspects / impacts which are regulated by governmental bodies be considered
> "significant" in an ISO 14001 EMS ?
For single organisations it can be very useful to restrict EMS to a few significant
environmental problems, namely the ones where impact is big and reduction results in
relatively large environmental benefits (as opposed to inefficiently focussing
activities on small impacts or hardly changable activities). But to know what a
"significant problem" is, a prior study is necessary, which screens problems for
their relative importance and identifies the "best candidates for action". This can
happen by analysing a specific organisation or looking at typical data for the
corresponding branch. Various methods of valuating various environmental effects
against each other are available from Life-Cycle Assessment (LCA) methodology.
It is clear that significant problems in the above sense can be regulated ones, as
well as non-regulated ones. Important is, that the major problems from an
environmental perspective are not missed.
Having said that, I would also like to point out, that in my personal opinion
environmental sensitivity should encompass as many effects as possible. The above
restraint applies only if for practical reasons monitoring of many effects results
in a not accoplishable amount of work. But looking into the future it is worthwhile
noting that the dynamics of environmental problems always start by dismissing a
certain problem as "being not important", thus allowing it to grow unchecked and
consequently become a important problem. This has happened with all known
environmental problems.
- --
..........................................................
: :
: Gabor Doka Tel. ++41 +1 463 16 08 :
: Stationsstrasse 32 Faxmodem auf Anfrage :
: CH - 8003 Zürich faxmodem on request :
: e-mail: doka@logon.ch :
: :
: ............................................. :
:.....: My web page on Life Cycle Assessment :......:
: : http://www.logon.ch/users/doka.htm :
: :...........................................:
:
:..Switch to 8-bit ISO-8859-1 (= Western, Latin1)
encoding, to see correct accented characters
in this mail (like umlauts etc. äöü).
------------------------------
Date: Thu, 02 Jul 1998 16:21:03 -0700
From: "Bert P. Krages"
Subject: Re: Regulated Aspects
A straightforward construction of ISO 14001 indicates that organizations
must consider separately their regulated aspects and their significant
environmental aspects. In other words, regulated aspects must be
identified and incorporated into the environmental management system
irrespective on whether they are considered significant whereas
environmental aspects must be considered only if they are significant. I
base this on the following:
1. The initial step in establishing an environmental management system is
to define the organization's environmental policy. Section 4.2 of ISO
14001 requires that the environmental policy include a commitment to comply
with relevant environmental legislation and regulations.
2. The planning aspect of ISO 14001 requires the organization to establish
procedures to identify its significant environmental aspects and to
consider them in setting its environmental objectives (section 4.3.1).
3. The planning aspect also requires the organization to establish
procedures to identify and have access to legal requirements. Section
4.3.2 does not distinguish between significant and insignificant legal
requirements.
Note also that the guidance in ISO 14004 refers to organizations
identifying "all legal . . . requirements" but refers only to knowing the
"significant environmental impacts." (Sections 4.3.2 and 4.3.3).
Similarly, the guidance in Annex A to ISO 14001 states without
qualification that the policy must reflect the commitment of top management
to comply with applicable laws but provides a fair amount of discretion in
how organizations determine what environmental aspects are significant.
In short, the ISO 14000 policy development and planning process does not
reflect that organizations can dismiss legal requirements as insignificant
although the exercise of such judgment is provided with respect to
environmental impacts. Allowing organizations to deliberately ignore legal
requirements they feel are insignificant would conflict with the policy
requirement since that the policy includes a commitment to comply with
relevant environmental legislation.
Connie, thanks for starting an interesting discussion.
At 06:57 PM 6/30/98 -0400, "Connie G. Ritzert" wrote:
>
>Dear colleagues: At the TC207 meeting in San Francisco a week or so ago,
>I happened to talk with several other delegates about a subject near and
>dear to our hearts - namely, environmental aspects. In particular, I found
>that there is considerable controversy around the relationship between
>"significance" and regulated aspects. If we who have been so close to this
>subject for the last 5 years are not in agreement on this, there are
>probably many other diverging opinions among those implementing or auditing
>ISO 14001. The point of contention is: Should all environmental
>aspects / impacts which are regulated by governmental bodies be considered
>"significant" in an ISO 14001 EMS ?
>
>Since this is an important point, it would be interesting to get some
>input from those of you who subscribe to this list. I will refrain from
>giving my opinion until some other voices are heard.
>
>What do you think . . . and why?
>
>
>Connie Glover Ritzert critzert@fyi.net
>Meredith-EMC environmental management consulting
>Mars, PA USA
>
Bert P. Krages II
Environmental Law and Mediation
900 S.W. Fifth Avenue, Suite 1900
Portland, Oregon 97204
Law:
Mediation:
------------------------------
End of iso14000-digest V2 #36
*****************************