iso14000-digest Thursday, January 21 1999 Volume 02 : Number 044
----------------------------------------------------------------------
Date: Wed, 13 Jan 1999 15:26:31 -0800
From: "Markku 'Mark' J. Saarelainen"
Subject: Re: Thanks
Hi Pedro and others,
just curious what the progress of ISO 14000 adoption is currently in
Portugal. I am sure that it is lacking behind ISO 9000 implementation, but
an estimate of those ISO 9000 implementations who have adopted ISO 14000
would be interesting.
Regards,
Mark
- ------------------------------------------------------------------
Markku 'Mark' J. Saarelainen
Email: waeg@ix.netcom.com
E-commerce River: http://pweb.netcom.com/~waeg/eriver.htm
DISCLAIMER:
No thought written in this message is a statement
of any organization by which I am employed or for
which I work.
" ..aren't we always discovering new worlds and environments?"
- -----------------------------------------------------------------
------------------------------
Date: Wed, 13 Jan 1999 15:44:39 -0500
From: Jean-Pierre Kiekens
Subject: SUSTAINABLE FORESTRY & CERTIFICATION WATCH
SUSTAINABLE FORESTRY & CERTIFICATION WATCH
an independent organisation to monitor forest certification worldwide
Montreal, Jan 13, 1999 (SFCW) - Sustainable Forestry & Certification Watch
has been established to monitor and report on forest certification worldwide.
SFCW is an independent, non-profit, non-governmental, international
organisation. Its mission is:
- - to enhance the understanding of forest certification and its
implications, particularly for sustainable forest management, international
forest policy, trade in forest products and consumer choice; and
- - to encourage the responsible stewardship of global forest resources by
facilitating the identification and adoption of effective approaches to
forest resource management and policy.
Forest certification is becoming an increasingly complex topic because of
the growing number of forest certification initiatives world-wide and the
intricate interplay amongst international environmental groups, forest
industries, traders and retailers of forest products, governmental agencies
and international organisations.
A key activity of SFCW is to publish the newsletter "Forest Certification
Watch" which monitors and reports on the development of the various forest
certification schemes world-wide; the effectiveness of certification as an
instrument to improve forest management; the information provided to the
general public and consumers through forest certification claims; the costs
and benefits of various forest certification options; the impact forest
certification can have on public forest policy, both domestically and
internationally; and the possible role of government in this voluntary,
market-driven, initiative.
The newsletter "Forest Certification Watch" is intended for forest owners,
the forest product industry, traders and retailers in forest products,
governments, environmental groups, indigenous groups, workers unions,
consumer associations and any other parties interested in staying abreast
of forest certification developments world-wide.
In addition to publishing its newsletter, SFCW conducts studies, surveys
and information sessions.
For further information, please contact us.
Sustainable Forestry & Certification Watch
tel: +1-514-273 5777
fax: +1-514-277 4448
e-mail: sfcw@sfcw.org
web site: http://www.sfcw.org
PO Box 48122,
Montreal H2V 4S8,
Qc, Canada
------------------------------
Date: Thu, 14 Jan 1999 09:51:48 -0700
From: Faye Bres
Subject: seeking clarification
Hi everyone,
I hope you may be able to help clear up a few points for me, any comments
on the following are welcome:
Question 1:
The scope of registration for a ISO 14001 3rd party registration (through a
registrar) for an organization requires the identification of: the
activity/ies; a location, and; management control (EAC G5). However,
clause
4.3.1 of ISO 14001 requires the organization to look at it's activities,
products or services. My question: Does the organization have to look at
the environmental aspects of it's products to get registered?
As an example, let's say that an organization produces widgets. They have
a modern manufacturing facility and have had an EMS in place for a number
of years. Their intended scope or registration is as follows "The
manufacture of widgets, at such and such a location by XYZ Corporation".
They are having difficulty understanding the exact meaning of "activities,
products or services" referred to in clause 4.3.1, as it relates to their
registration scope.
They have determined, to the best of their ability, all of the aspects and
impacts associated with the actual manufacture of the widget. They have
based this on the activities at the plant and believe that meets the
requirements for the scope of their registration.
1. Do they have to look at the aspects related to their widgets (actual
product and its use by customers)?
2. If they do, what level of detail would be acceptable for a registrar?
(Yes I know each registrar may have slightly different interpretations but
I am expecting that there will at least be a common theme).
Question 2:
The standard focuses on the organization's "activities, products or
services" and does not appear to address the potential for site
contamination from the activities of previous site owners, or the potential
for onsite migration of contaminants from neighboring properties. In my
experience assessing contaminated sites, it is not at all uncommon for
serious environmental problems to exist on a site which are unrelated to
the "activities, products or services" of the current owner. The owner of
the site may still be held liable for such contamination, and ignorance of
the presence of the contamination does not provide them with much legal
protection. Although addressing previous site contamination does not
constitute control of an organization's activities, it is an important part
of due diligence, in my opinion. Is there anything in the standard which
suggests that a contaminated site assessment may actually be required? Is
it standard practice among organizations developing ISO 14001 systems to
conduct basic contaminated site assessments on previously owned industrial
sites, or sites which neighbor other industrial properties?
(Note: such assessments do not require extensive sampling, but focus on
collecting readily available information on the site history: reviewing
land titles, analyzing historical air photographs for evidence of previous
dump sites or spills, inspecting the site for visible signs of
contamination, reviewing regulatory records on previous spills or other
non-compliances, and possibly interviewing neighbors and previous site
managers regarding past activities and practices on the site. The average
cost of such an assessment for an industrial site is generally in the order
of three days of a consultants fees, about $3000 Canadian.)
Thanks for your input.
Faye Bres
Principle, Simar Consulting
48 Wellington Place S.W.
Calgary, Alberta
Canada
fbres@biophilia.com
------------------------------
Date: Thu, 14 Jan 1999 16:54:52 -0500
From: "Connie G. Ritzert"
Subject: RE: seeking clarification
Reply to Faye Bres: A quick response, therefore, not comprehensive, but
....
Questions 1. Does the organization have to look at the environmental
aspects of it's products to get registered?
Yes - The organization must have and implement a procedure for determining
the environmental aspects of its activities , products, and services - but
note the qualification: "that it can control and over which it can be
expected to have an influence,.." For your example, don't eliminate
products from the aspects determination. Consider what potential product
related aspects are within the control or expected influence of the
management.
Questions 2: Does the ISO 14001 EMS cover site contamination from past
owners or external sources?
Contaminated media on a site managed by an organization with an ISO 14001
EMS should be at least considered in that EMS. There is no requirement in
the standard for a property assessment. That would be up to the
organization. If the site contamination is known by the organization, the
possibility of environmental impacts and the relationship of ongoing
operations on the site to those potential impacts should be considered.
Whether action is taken or not will depend upon the potential for impacts
from that contamination and their significance as defined by the
organization. You suggest that existing contamination may not be covered
because it is not the result of "activities" of the organization. I
believe you need to understand the word "activities" in its broadest sense
in using ISO 14001. Activities of the organization are merely actions or
functions of the organization and may include a number of things related to
simply operating the site (e.g. altering runoff patterns, driving vehicles
on the site, construction on the site, etc. ) .These may not have initiated
the contamination, but that doesn't mean that there should be no management
applied to the affected media. If nothing else, there may be a land or
water resource issue. There also may be legal obligations which dictate
action on existing site contamination, depending upon circumstances, and
legal obligations are covered in the EMS.
Just some quick thoughts.
Connie Glover Ritzert critzert@fyi.net
Meredith-EMC environmental management consulting
- -----Original Message-----
From: Faye Bres [SMTP:fbres@biophilia.com]
Sent: Thursday, January 14, 1999 11:52 AM
To: 'iso14000@quality.org'
Subject: seeking clarification
Hi everyone,
I hope you may be able to help clear up a few points for me, any comments
on the following are welcome:
Question 1:
The scope of registration for a ISO 14001 3rd party registration (through a
registrar) for an organization requires the identification of: the
activity/ies; a location, and; management control (EAC G5). However,
clause
4.3.1 of ISO 14001 requires the organization to look at it's activities,
products or services. My question: Does the organization have to look at
the environmental aspects of it's products to get registered?
As an example, let's say that an organization produces widgets. They have
a modern manufacturing facility and have had an EMS in place for a number
of years. Their intended scope or registration is as follows "The
manufacture of widgets, at such and such a location by XYZ Corporation".
They are having difficulty understanding the exact meaning of "activities,
products or services" referred to in clause 4.3.1, as it relates to their
registration scope.
They have determined, to the best of their ability, all of the aspects and
impacts associated with the actual manufacture of the widget. They have
based this on the activities at the plant and believe that meets the
requirements for the scope of their registration.
1. Do they have to look at the aspects related to their widgets (actual
product and its use by customers)?
2. If they do, what level of detail would be acceptable for a registrar?
(Yes I know each registrar may have slightly different interpretations but
I am expecting that there will at least be a common theme).
Question 2:
The standard focuses on the organization's "activities, products or
services" and does not appear to address the potential for site
contamination from the activities of previous site owners, or the potential
for onsite migration of contaminants from neighboring properties. In my
experience assessing contaminated sites, it is not at all uncommon for
serious environmental problems to exist on a site which are unrelated to
the "activities, products or services" of the current owner. The owner of
the site may still be held liable for such contamination, and ignorance of
the presence of the contamination does not provide them with much legal
protection. Although addressing previous site contamination does not
constitute control of an organization's activities, it is an important part
of due diligence, in my opinion. Is there anything in the standard which
suggests that a contaminated site assessment may actually be required? Is
it standard practice among organizations developing ISO 14001 systems to
conduct basic contaminated site assessments on previously owned industrial
sites, or sites which neighbor other industrial properties?
(Note: such assessments do not require extensive sampling, but focus on
collecting readily available information on the site history: reviewing
land titles, analyzing historical air photographs for evidence of previous
dump sites or spills, inspecting the site for visible signs of
contamination, reviewing regulatory records on previous spills or other
non-compliances, and possibly interviewing neighbors and previous site
managers regarding past activities and practices on the site. The average
cost of such an assessment for an industrial site is generally in the order
of three days of a consultants fees, about $3000 Canadian.)
Thanks for your input.
Faye Bres
Principle, Simar Consulting
48 Wellington Place S.W.
Calgary, Alberta
Canada
fbres@biophilia.com
------------------------------
Date: Fri, 15 Jan 1999 09:32:37 +0100
From: "Pedro Gonçalves"
Subject: Another clarification wanted
Hello all,
One doubt on "Preventive actions".
Let's say that a equipment of some sort had a major breakdown and the result
was a spillage of water. The source of the equipment's breakdown was
immediately repaired (a malfunctioning valve) and the spillage properly
cleaned up. Afterwards, the maintenance plan was reviewed and the timming
for the maintenance of that particular equipment was shortened (let's say,
from 4 times a year to 6 times a year). Can this review of the maintenance
plan be considered a preventive action? Or it is still only a corrective
action?
Thanks for your input!
Pedro Gonçalves
------------------------------
Date: Fri, 15 Jan 1999 12:15:12 -0500
From: "Connie G. Ritzert"
Subject: FW: seeking clarification
Got a message that this was not deliverable. Trying again. CGR
- -----Original Message-----
From: Connie G. Ritzert [SMTP:critzert@fyi.net]
Sent: Thursday, January 14, 1999 4:55 PM
To: 'fbres@biophilia.com'; 'iso14000@quality.org'
Subject: RE: seeking clarification
Reply to Faye Bres: A quick response, therefore, not comprehensive, but
....
Questions 1. Does the organization have to look at the environmental
aspects of it's products to get registered?
Yes - The organization must have and implement a procedure for determining
the environmental aspects of its activities , products, and services - but
note the qualification: "that it can control and over which it can be
expected to have an influence,.." For your example, don't eliminate
products from the aspects determination. Consider what potential product
related aspects are within the control or expected influence of the
management.
Questions 2: Does the ISO 14001 EMS cover site contamination from past
owners or external sources?
Contaminated media on a site managed by an organization with an ISO 14001
EMS should be at least considered in that EMS. There is no requirement in
the standard for a property assessment. That would be up to the
organization. If the site contamination is known by the organization, the
possibility of environmental impacts and the relationship of ongoing
operations on the site to those potential impacts should be considered.
Whether action is taken or not will depend upon the potential for impacts
from that contamination and their significance as defined by the
organization. You suggest that existing contamination may not be covered
because it is not the result of "activities" of the organization. I
believe you need to understand the word "activities" in its broadest sense
in using ISO 14001. Activities of the organization are merely actions or
functions of the organization and may include a number of things related to
simply operating the site (e.g. altering runoff patterns, driving vehicles
on the site, construction on the site, etc. ) .These may not have initiated
the contamination, but that doesn't mean that there should be no management
applied to the affected media. If nothing else, there may be a land or
water resource issue. There also may be legal obligations which dictate
action on existing site contamination, depending upon circumstances, and
legal obligations are covered in the EMS.
Just some quick thoughts.
Connie Glover Ritzert critzert@fyi.net
Meredith-EMC environmental management consulting
- -----Original Message-----
From: Faye Bres [SMTP:fbres@biophilia.com]
Sent: Thursday, January 14, 1999 11:52 AM
To: 'iso14000@quality.org'
Subject: seeking clarification
Hi everyone,
I hope you may be able to help clear up a few points for me, any comments
on the following are welcome:
Question 1:
The scope of registration for a ISO 14001 3rd party registration (through a
registrar) for an organization requires the identification of: the
activity/ies; a location, and; management control (EAC G5). However,
clause
4.3.1 of ISO 14001 requires the organization to look at it's activities,
products or services. My question: Does the organization have to look at
the environmental aspects of it's products to get registered?
As an example, let's say that an organization produces widgets. They have
a modern manufacturing facility and have had an EMS in place for a number
of years. Their intended scope or registration is as follows "The
manufacture of widgets, at such and such a location by XYZ Corporation".
They are having difficulty understanding the exact meaning of "activities,
products or services" referred to in clause 4.3.1, as it relates to their
registration scope.
They have determined, to the best of their ability, all of the aspects and
impacts associated with the actual manufacture of the widget. They have
based this on the activities at the plant and believe that meets the
requirements for the scope of their registration.
1. Do they have to look at the aspects related to their widgets (actual
product and its use by customers)?
2. If they do, what level of detail would be acceptable for a registrar?
(Yes I know each registrar may have slightly different interpretations but
I am expecting that there will at least be a common theme).
Question 2:
The standard focuses on the organization's "activities, products or
services" and does not appear to address the potential for site
contamination from the activities of previous site owners, or the potential
for onsite migration of contaminants from neighboring properties. In my
experience assessing contaminated sites, it is not at all uncommon for
serious environmental problems to exist on a site which are unrelated to
the "activities, products or services" of the current owner. The owner of
the site may still be held liable for such contamination, and ignorance of
the presence of the contamination does not provide them with much legal
protection. Although addressing previous site contamination does not
constitute control of an organization's activities, it is an important part
of due diligence, in my opinion. Is there anything in the standard which
suggests that a contaminated site assessment may actually be required? Is
it standard practice among organizations developing ISO 14001 systems to
conduct basic contaminated site assessments on previously owned industrial
sites, or sites which neighbor other industrial properties?
(Note: such assessments do not require extensive sampling, but focus on
collecting readily available information on the site history: reviewing
land titles, analyzing historical air photographs for evidence of previous
dump sites or spills, inspecting the site for visible signs of
contamination, reviewing regulatory records on previous spills or other
non-compliances, and possibly interviewing neighbors and previous site
managers regarding past activities and practices on the site. The average
cost of such an assessment for an industrial site is generally in the order
of three days of a consultants fees, about $3000 Canadian.)
Thanks for your input.
Faye Bres
Principle, Simar Consulting
48 Wellington Place S.W.
Calgary, Alberta
Canada
fbres@biophilia.com
------------------------------
Date: Fri, 15 Jan 1999 20:19:56 -0000
From: "Pete Thomas"
Subject: RE: Another clarification wanted
I have no major qualification for what I am about to say as I am still only
part way through our auditing process. We have had a system developing over
the last year and have had our Stage 1 certification audit.
The criterea I would apply would depend on why the valve failed. If it
failed because the maintenace period was too long then shortening it should
be considered as preventative. If it failed because of defecetive operation,
design or similar then I would expect to have to do something more.
Pete Thomas
Marley Floors and Waterproofing Ltd
Dickley Lane
Lenham
Kent ME17 2DE
UK
Opinions expressed are my own and are not necessarily shared by my employer
> -----Original Message-----
> From: owner-iso14000@quality.org [mailto:owner-iso14000@quality.org]On
> Behalf Of Pedro Gonçalves
> Sent: 15 January 1999 08:33
> To: ISO 14000
> Subject: Another clarification wanted
>
>
> Hello all,
>
> One doubt on "Preventive actions".
>
> Let's say that a equipment of some sort had a major breakdown and
> the result
> was a spillage of water. The source of the equipment's breakdown was
> immediately repaired (a malfunctioning valve) and the spillage properly
> cleaned up. Afterwards, the maintenance plan was reviewed and the timming
> for the maintenance of that particular equipment was shortened (let's say,
> from 4 times a year to 6 times a year). Can this review of the maintenance
> plan be considered a preventive action? Or it is still only a corrective
> action?
>
> Thanks for your input!
>
> Pedro Gonçalves
>
>
>
------------------------------
Date: Fri, 15 Jan 1999 17:52:39 -0800
From: "Robert B. Pojasek"
Subject: Re: Another clarification wanted
Spills represent a gray area for those involved in prevention. Most people
spend much time in preparedness - lowering the probablility for the spill
event and preparing to initiate the contingency in the most effective
manner. The Japanese have long promoted a program to PREVENT spills. It
goes under the title of Poka-Yoke. Translated into English this means
mistakeproofing. The literal translation is "idiot proofing." What it
promotes are engineering design changes that make it nearly impossible for
a spill to take place. An example would be a hose coupling that has a ball
embedded in both ends of the coupling. When the hose coupling is
unhitched, no leakage can take place. As you might expect, our engineer
design friends have not found ways to mistakeproof everything yet.
However, they have had wonderful success in preventing spills. Anyone who
seeks to implement "the prevention of pollution" in an ISO 14001 program
(beyond mentioning it in the policy) must become familiar with this topic.
There is a publishing firm in Portland (Oregon, USA) called Productivity
Press. They offer several books on Poke-Yoke including an excellent, and
inexpensive brief overview of the topic called "Mistakeproofing." These
techniques have been around in the United States for a long time now.
Environmental managers are usually unfamiliar with them. Quality managers
are more likely to use these techniques. I hope this was helpful to you.
At 09:32 AM 1/15/99 +0100, you wrote:
>Hello all,
>
>One doubt on "Preventive actions".
>
>Let's say that a equipment of some sort had a major breakdown and the result
>was a spillage of water. The source of the equipment's breakdown was
>immediately repaired (a malfunctioning valve) and the spillage properly
>cleaned up. Afterwards, the maintenance plan was reviewed and the timming
>for the maintenance of that particular equipment was shortened (let's say,
>from 4 times a year to 6 times a year). Can this review of the maintenance
>plan be considered a preventive action? Or it is still only a corrective
>action?
>
>Thanks for your input!
>
>Pedro Gonçalves
>
Bob
Dr. Robert B. Pojasek
Pojasek & Associates
P.O. Box 1333
E. Arlington, MA 02474-0071
(781) 641-2422
(617) 788-0288 (FAX)
http://www.PollutionPrevention.com
rpojasek@PollutionPrevention.com
------------------------------
Date: Mon, 18 Jan 1999 15:06:11 EST
From: DBurd52011@aol.com
Subject: Re: Another clarification wanted re: Corrective and Preventive actions
Dear Pedro Gonçalves,
You have raised an issue which has perplexed a lot of folks. Let me give you
my interpretation, based on a few years auditing, guidance from ISO 9001 and
interpretations from ISO 14004.
· Corrective Actions are actions which correct a problem permanently
· Preventive Actions are actions which keep a potential problem from
happening.
Using the above definition, I would call your action to increase maintenance
corrective action because the problem has occurred and you have taken action
to keep the problem from reoccurring.
Preventative actions, as I understand from ISO 9001, are typically monitoring
programs which look at areas of concern and take action when trends indicate
that there may be a problem, i.e. the trending of root causes of scrap
generation, or for ISO 14001, the monitoring of wells, emissions, root causes
of stakeholder complaints, etc.
Perhaps listing the sources of information that you use to monitor
environmentally significant and legally required aspects would be a start to
preventative actions. Then document the procedures used to monitor, including
frequency of review, etc. Next step is to develop procedures for actions to
take if things are deemed abnormal, including criteria for an action,
authority to act, etc. (This procedure may include establishing a team to
study the problem more (root cause analysis), shutting the process down,
opening valve X, etc.)
Hopes this helps. Will be looking forward to others opinions in order to gain
a deeper clarification of this controversial issue.
Sincerely
David Burdick
Quality and Environmental Management Systems
In a message dated 99-01-15 19:05:26 EST,catarinos@mail.telepac.pt (Pedro
Gonçalves) writes:
>Hello all,
>
>One doubt on "Preventive actions".
>
>Let's say that a equipment of some sort had a major breakdown and the result
>was a spillage of water. The source of the equipment's breakdown was
>immediately repaired (a malfunctioning valve) and the spillage properly
>cleaned up. Afterwards, the maintenance plan was reviewed and the timming
>for the maintenance of that particular equipment was shortened (let's say,
>from 4 times a year to 6 times a year). Can this review of the maintenance
>plan be considered a preventive action? Or it is still only a corrective
>action?
>
>Thanks for your input!
>
>Pedro Gonçalves
> >>
------------------------------
Date: Wed, 20 Jan 1999 11:01:00 -0800
From: "Robert B. Pojasek"
Subject: Re: Another clarification wanted re: Corrective and Preventive actions
I would like to modify one of your definitions slightly. Preventive
actions can come from performing root cause analysis within the corrective
action program and leads to the MISTAKE PROOFING of the process item that
lead to the original problem in such a way that it cannot happen again.
Corrective acctions in the sphere of environmental practice often add an
engineering control to prevent the consequence of the problem; e.g.,
providing adequate diking around a storage tank and nozzel vs. modifying
the nozzle so a spill is prevented not just contained - "prevented" from
getting into the sewer. Instead of increasing maintenance, you need to
increase DESIGN to mistake proof the equipment. Preventive actions
eliminate the need for monitoring programs that are non-value added for the
firm. Mistake proofing is well known in the quality field but is virtually
unknown in the environmental field. The concept of "the prevention of
pollution" is to eliminate significant aspects altogether, not to manage
them better within the EMS. I think we all need to be clear that
prevention needs to be practiced within an EMS and not be constrained to
the policy document.
At 03:06 PM 1/18/99 -0500, you wrote:
>Dear Pedro Gonçalves,
>
>You have raised an issue which has perplexed a lot of folks. Let me give you
>my interpretation, based on a few years auditing, guidance from ISO 9001 and
>interpretations from ISO 14004.
>
>· Corrective Actions are actions which correct a problem permanently
>
>· Preventive Actions are actions which keep a potential problem from
>happening.
>
>Using the above definition, I would call your action to increase maintenance
>corrective action because the problem has occurred and you have taken action
>to keep the problem from reoccurring.
>
>Preventative actions, as I understand from ISO 9001, are typically monitoring
>programs which look at areas of concern and take action when trends indicate
>that there may be a problem, i.e. the trending of root causes of scrap
>generation, or for ISO 14001, the monitoring of wells, emissions, root
causes
>of stakeholder complaints, etc.
>
>Perhaps listing the sources of information that you use to monitor
>environmentally significant and legally required aspects would be a start to
>preventative actions. Then document the procedures used to monitor,
including
>frequency of review, etc. Next step is to develop procedures for actions to
>take if things are deemed abnormal, including criteria for an action,
>authority to act, etc. (This procedure may include establishing a team to
>study the problem more (root cause analysis), shutting the process down,
>opening valve X, etc.)
>
>Hopes this helps. Will be looking forward to others opinions in order to
gain
>a deeper clarification of this controversial issue.
>
>Sincerely
>
>David Burdick
>Quality and Environmental Management Systems
>
>In a message dated 99-01-15 19:05:26 EST,catarinos@mail.telepac.pt (Pedro
>Gonçalves) writes:
>
> >Hello all,
> >
> >One doubt on "Preventive actions".
> >
> >Let's say that a equipment of some sort had a major breakdown and the
result
> >was a spillage of water. The source of the equipment's breakdown was
> >immediately repaired (a malfunctioning valve) and the spillage properly
> >cleaned up. Afterwards, the maintenance plan was reviewed and the timming
> >for the maintenance of that particular equipment was shortened (let's say,
> >from 4 times a year to 6 times a year). Can this review of the maintenance
> >plan be considered a preventive action? Or it is still only a corrective
> >action?
> >
> >Thanks for your input!
> >
> >Pedro Gonçalves
> > >>
>
Bob
Dr. Robert B. Pojasek
Pojasek & Associates
P.O. Box 1333
E. Arlington, MA 02474-0071
(781) 641-2422
(617) 788-0288 (FAX)
http://www.PollutionPrevention.com
rpojasek@PollutionPrevention.com
------------------------------
Date: Thu, 21 Jan 1999 12:22:56 +0100
From: "Pedro Gonçalves"
Subject: Corrective and Preventive actions
Dear David Burdick,
Thanks for you opinion. I must say that your input didn't clear my mind.
When I reapair the valve, I don't have any doubt that this is a corrective
action. As I don't want it happens again I'm going to review my maintenance
plan. You said that "...· Preventive Actions are actions which keep a
potential problem from
happening". As I don't want it happens again and apart other actions I could
take, isn't this review of the plan an action intended to reduce the risk of
a potential problem from happening?
Further down you say: "...I would call your action to increase maintenance
corrective action because the problem has occurred and you have taken action
to keep the problem from reoccurring". Well, if I took an action to keep a
problem from reoccurring, isn't this your definition of a preventive action?
(see above).
In my mind, I would call it a preventive action but I see there is some
debate about it, as you can see from the replies I got to my query!
Pedro Gonçalves
- -----Mensagem original-----
De: DBurd52011@aol.com
Para: Pedro Gon alves ; iso14000@quality.org
Data: segunda-feira, 18 de janeiro de 1999 21:30
Assunto: Re: Another clarification wanted re: Corrective and Preventive
actions
Dear Pedro Gonçalves,
You have raised an issue which has perplexed a lot of folks. Let me give
you
my interpretation, based on a few years auditing, guidance from ISO 9001 and
interpretations from ISO 14004.
· Corrective Actions are actions which correct a problem permanently
· Preventive Actions are actions which keep a potential problem from
happening.
Using the above definition, I would call your action to increase maintenance
corrective action because the problem has occurred and you have taken action
to keep the problem from reoccurring.
Preventative actions, as I understand from ISO 9001, are typically
monitoring
programs which look at areas of concern and take action when trends indicate
that there may be a problem, i.e. the trending of root causes of scrap
generation, or for ISO 14001, the monitoring of wells, emissions, root
causes
of stakeholder complaints, etc.
Perhaps listing the sources of information that you use to monitor
environmentally significant and legally required aspects would be a start to
preventative actions. Then document the procedures used to monitor,
including
frequency of review, etc. Next step is to develop procedures for actions to
take if things are deemed abnormal, including criteria for an action,
authority to act, etc. (This procedure may include establishing a team to
study the problem more (root cause analysis), shutting the process down,
opening valve X, etc.)
Hopes this helps. Will be looking forward to others opinions in order to
gain
a deeper clarification of this controversial issue.
Sincerely
David Burdick
Quality and Environmental Management Systems
------------------------------
Date: Thu, 21 Jan 1999 22:19:03 +0000
From: Teguh Sujatno
Subject: Corrective and Preventive actions
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>From: "Pedro Gonçalves"
>To: "ISO 14000" ,
>Subject: Corrective and Preventive actions
>Date: Thu, 21 Jan 1999 12:22:56 +0100
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Dear Pedro,
I have the same intrepretation with David Burdick so far. From my
understanding, preventive actions is actions taken for potensial problems
that could occur. Since your problems have occured, from my understanding,
it is considered corrective actions. Since I currectly consultants of ISO
9000, as well as QS-9000, in my opinion there are some tools in QS-9000
that we can use it to do preventive actions, such as Statistical Process
Control used in production area to monitor potential problem before
happening, Measurement System Analysis used to control variation of
appraiser and gage, Mistake proofing, etc.
>Dear David Burdick,
>
>Thanks for you opinion. I must say that your input didn't clear my mind.
>When I reapair the valve, I don't have any doubt that this is a corrective
>action. As I don't want it happens again I'm going to review my maintenance
>plan. You said that "...· Preventive Actions are actions which keep a
>potential problem from
>happening". As I don't want it happens again and apart other actions I could
>take, isn't this review of the plan an action intended to reduce the risk of
>a potential problem from happening?
>
>Further down you say: "...I would call your action to increase maintenance
>corrective action because the problem has occurred and you have taken action
>to keep the problem from reoccurring". Well, if I took an action to keep a
>problem from reoccurring, isn't this your definition of a preventive action?
>(see above).
>
>In my mind, I would call it a preventive action but I see there is some
>debate about it, as you can see from the replies I got to my query!
>
>Pedro Gonçalves
>
>
>-----Mensagem original-----
>De: DBurd52011@aol.com
>Para: Pedro Gon alves ; iso14000@quality.org
>
>Data: segunda-feira, 18 de janeiro de 1999 21:30
>Assunto: Re: Another clarification wanted re: Corrective and Preventive
>actions
>
>
>Dear Pedro Gonçalves,
>
>You have raised an issue which has perplexed a lot of folks. Let me give
>you
>my interpretation, based on a few years auditing, guidance from ISO 9001 and
>interpretations from ISO 14004.
>
>· Corrective Actions are actions which correct a problem permanently
>
>· Preventive Actions are actions which keep a potential problem from
>happening.
>
>Using the above definition, I would call your action to increase maintenance
>corrective action because the problem has occurred and you have taken action
>to keep the problem from reoccurring.
>
>Preventative actions, as I understand from ISO 9001, are typically
>monitoring
>programs which look at areas of concern and take action when trends indicate
>that there may be a problem, i.e. the trending of root causes of scrap
>generation, or for ISO 14001, the monitoring of wells, emissions, root
>causes
>of stakeholder complaints, etc.
>
>Perhaps listing the sources of information that you use to monitor
>environmentally significant and legally required aspects would be a start to
>preventative actions. Then document the procedures used to monitor,
>including
>frequency of review, etc. Next step is to develop procedures for actions to
>take if things are deemed abnormal, including criteria for an action,
>authority to act, etc. (This procedure may include establishing a team to
>study the problem more (root cause analysis), shutting the process down,
>opening valve X, etc.)
>
>Hopes this helps. Will be looking forward to others opinions in order to
>gain
>a deeper clarification of this controversial issue.
>
>Sincerely
>
>David Burdick
>Quality and Environmental Management Systems
>
>
>
>
>
>
>
>
------------------------------
Date: Thu, 21 Jan 1999 19:43:12 -0500
From: Susan Graff
Subject: Should you pursue ISO 14000?
ISO 14000: Should your Company Develop an Environmental Management System?
by Susan Graff
Environmental Resource Services, Inc.
http://www.envsource.com
Questions to Ask before investing company time & resources in EMS
development:
1. Are your customers and stakeholders likely to demand you have an
environmental management system in place?
2. What are the costs associated with your product that is lost to the
environment?
3. Are environmental impacts of your processes creating a liability that
put you or your company at risk?
- ------------------------------------------------------------------
More and more companies today are using environmental management systems
such as ISO 14000 to integrate environmental aspects into their business
plans. Thousands of companies worldwide have registered environmental
management systems in place, and many more are putting systems in place
without formal registration. "Environmental issues are business issues"
states the Southern Company, America^Òs largest producer of electricity, in
their Environmental Performance Strategy.
However, a forward thinking company, striving to maintain it^Òs market edge
into the 21st century, still has to answer some basic questions to evaluate
the environmental management system trend and decide how to respond: What
do my customers want? Will this approach improve my product and increase my
company^Òs market share? And truly progressive companies are looking
beyond their immediate customers to address the needs of stakeholders,
including future generations, as well.
- ------------------------------------------------------------------
Environmental Management Systems:
ISO 14000 Requirements
An environmental management system identifies the significant environmental
impacts of a company^Òs process and opportunities to conserve materials and
energy. The system also establishes linkage to your business planning
process. There are several different environmental management system models
to choose from: Sweden^Òs Natural Step (TM), the Chemical Manufacturer^Òs
Association Responsible Care (TM), and ISO 14000 are some examples.
The ISO 14000 environmental management system model was developed to meet
the demand for a single international standard, and it was developed
through consensus by an international technical advisory committee of
industry, government, consumer interest groups, and the general public.
ISO (the International Organization for Standardization), a worldwide
federation of national standards bodies, issued the final specification
standard in the fall of 1996. While 14000 is the series, 14001 is the
actual specification that companies either self-declare or register to
through 3rd party confirmation. Demonstration of successful implementation
of 14001 can be used by any organization to assure interested parties that
an appropriate environmental management system is in place.
The ISO 14001 environmental management system model follows a logical
progression of steps that begin with developing a company Environmental
Policy. The most prescriptive part of the model, 14001 requires the
environmental policy include commitments to prevention of pollution,
regulatory compliance, and continual improvement. Next Planning begins,
and the first step is critical - identification of significant
environmental impacts from the organization^Òs activities, products, or
services. Companies are using a variety of methods, from brainstorming to
risk ranking schemes, to prioritize these environmental impacts and plan
budgets and schedules to address the most significant. Legal and other
requirements the company complies with are also identified during Planning.
Objectives and targets are developed for the significant impacts, and an
action plan for accomplishing them is required. Implementation puts the
plan in action through alignment of resources and development of
documentation to minimize environmental impacts. Checking, Corrective
action, and Management Review further reinforce the Deming model of
Plan-Do-Check-Act that 14000 is based upon to ensure continual improvement.
ISO 14000 represents a marriage of quality systems with preventive
environmental management. Many companies that implemented an ISO 9000
quality system realized significant improvements but objected to the
burdensome documentation requirements. The authors of ISO 14000 have
taken this into account, requiring written documentation of policy and/or
procedures in only four or five instances in the model. In addition,
companies that are ISO 9000 registered have administrative elements such as
document control and record keeping systems already in place and are at a
major advantage in implementing 14000.
-----------------------------------------------------------------
Why Companies are Developing Environmental Management Systems
The major driver behind the environmental management system trend is the
marketplace. In a 1995 survey of 99 U.S. businesses considering 14001
implementation, 50% reported customer demand or a competitive advantage as
the reason for certification. Companies with a high percentage of sales
in Europe or Asian markets should investigate what their customers expect -
for example, China, the home for 20% of the world^Òs population, recently
adopted ISO 14000 as state policy. Xerox Corporation states customer
demand drove their decision to seek registration. On the U.S. front, the
"Big Three" auto manufacturers are expecting their Tier 1 suppliers to have
environmental management systems. Other global companies are making
similar demands on suppliers, including leaders in the pulp and paper
industry. According to one corporate manager of environmental affairs, the
supplier who inappropriately manages their environmental aspects or ignores
opportunities for pollution prevention may pass significant environmental
liability and a negative image on to their customer.
Improved risk management and the reduced liabilities are other important
reasons U.S. companies are implementing environmental management systems.
In 1996, U.S. EPA reported the highest level of enforcement activity in the
history of the agency. Over $172 million was collected in fines and
penalties. Furthermore, state and federal environmental agencies often use
corporate penalty structures that put the CEO and top management at risk
personally in the event of a release to the environment. Environmental
management systems are preventive, and several elements contain spill
prevention and emergency preparedness procedures that help manage risk and
influence liability. Companies have received monetary relief in federal
penalties for having certain environmental management system elements in
place such as self-audits. In a recent landmark case involving GTE, $2.3
million was reduced to $53,000 in penalties because the company conducted
self-audits. Companies are also receiving reductions in insurance premiums
- - Akzo Nobel Chemicals and Synthetic Industries reported premium reductions
after ISO registration.
Finally, internal efficiencies and waste reduction are driving the trend.
Product lost to the environment equates to dollars down the drain or up in
smoke. Unnecessary waste of natural resources is a major business concern
of progressive companies. For example, Southwire Company annually reports
significant cost savings from the pollution prevention programs essential
to implementing their environmental policy. Most often the best ideas come
from within, which also results in enhanced employee satisfaction.
Team-based management studies have shown that having input to and ownership
of company goals enhances employee job satisfaction and decreases the
likelihood of employee turnover.
- ------------------------------------------------------------------
What will an Environmental Management System Cost?
The cost of implementing an environmental management system is highly
variable, but often proportional to the size and complexity of the
operation. A range of costs between $15,000-$150,000 per site have been
reported. Formal registration adds to these costs as a 3rd party audit
program and surveillance are required to maintain the registration.
Companies are finding the major environmental management system development
cost is employee time. ISO requires all employees are informed about the
company^Òs environmental policy, and specialized knowledge among those whose
job may have a significant environmental impact. Training programs can be
resource intensive in time lost from production plus costs of instruction,
and it takes time to document procedures for certain critical operations.
Companies with high employee turnover or multiple sites may find knowledge
transfer intranet/extranet technologies and self-directed learning tools
effective to develop and maintain employee capabilities and minimize some
of these costs.
Capital costs of environmental management system development are relatively
small in comparison, assuming companies already have appropriate control
equipment and monitoring instrumentation in place to be in compliance with
federal, state, and local requirements.
The costs and benefits of environmental management systems can be difficult
to measure. How do you measure the value of a preventive system? The
costs incurred in the course of complying with regulations such as
monitoring and permit requirements are potentially hidden among other
items, such as overhead accounts. Intangibles such as enhanced consumer
response indeed have value, but that value may depend on how your company
is currently positioned on these issues and it^Òs goals.
- ------------------------------------------------------------------
Consider Stakeholder Concerns and Sustainable Development Needs
Environmental performance is important to many consumers and stakeholders.
Evidence is found by noting the push on parliaments and congresses around
the world to effect a culture change, or perhaps even a 2nd industrial
revolution, towards sustainable development. Simply put, sustainable
development is providing goods and services to meet the needs of current
generations without compromising the ability of future generations to meet
their own needs. The President^Òs Council on Sustainable Development was
appointed in 1993 to lay the groundwork for a national strategy. 25 leaders
from business, government, environmental, civil rights, and Native American
organizations are looking for new ways to achieve this goal through
performance-based solutions.
21st century manufacturers are looking at ways to reduce the consumption of
materials and energy in production processes, and recycle their waste
product into new product uses. Ray Anderson, CEO of Interface, Inc., a
major manufacturer of floor coverings, cites staggering figures in use of
raw materials: 1.2 billion pounds of materials extracted per year, with 2/3
of it burned up in fuel consumption. Ray and Interface are pioneering
changes in technology to become completely sustainable by the year 2000.
Use of solar energy, providing raw material needs by harvesting and
recycling carpet and other petrochemical products, and eliminating waste
and harmful emissions are all part of Interface^Òs strategy to attain this
goal.
Environmental management systems that employ tools such as life cycle
assessment and performance measures can be used to accomplish sustainable
manufacturing goals and report meaningful results to your key stakeholders.
- ------------------------------------------------------------------
Conclusions
The trend towards environmental management systems is well established.
While your company may already have a few key elements of a system in
place, many companies are finding considerable value added through
implementing a complete system that integrates environmental aspects into
business planning. As is true with other areas of industrial management,
planning and prevention on the front end may translate to significant gains
in the long run.
Think about your company^Òs goals, marketplace, and the bottom line . . .
numerous studies over the past few decades have shown a positive
correlation between financial and environmental performance. But also
think a few steps beyond today^Òs bottom line, and the needs of future
generations we all should be considerate of. The time is here to make an
informed business decision.
- ------------------------------------------------------------------
For Further Reference
ANSI/ISO 14000 Series Environmental Management Systems and Environmental
Auditing, American Society for Testing & Materials, American Society for
Quality Control, NSF International - the international series, some of
which have been finalized, including 14001, the final specification
standard for environmental management system development, 1996.
www.ISO14000.net - an Internet resource for information, training, and
online services; includes a list of companies who have registered to 14000;
some information requires subscription.
"Environmental Management Systems: An Implementation Guide for Small and
Medium Sized Organizations"; Stapleton, Cooney and Hix Jr., NSF
International, 1996 - a guidance document for any size organization
developing an EMS, 156 pages.
ISO 14000 Questions and Answers, Third Edition, Hemingway, CEEM Information
Services, 1997 - Simple straightforward answers to the most frequently
asked questions companies have regarding ISO implementation; 56 pages.
Susan Graff
President
Environmental Resource Services, Inc.
www.envsource.com
------------------------------
End of iso14000-digest V2 #44
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