ISO is the International Organization for Standardization, which is made up
of representatives of more than 140 countries. Its mission is to facilitate
the international exchange of goods and services. For example, an ISO International
Standard determines the optimal thickness of a credit card so that people can
use the same card worldwide. Using the ISO standards increases the reliability
and effectiveness of goods and services used globally.
ISO 14000 is a standard concerned with environmental management and the way
an organization goes about minimizing its harmful effects on the environment.
ISO 14001, more specifically, is an environmental management system based on
ISO 14000 standards. Used proactively as a management tool, it allows an organization
of any size or type to control the impact of its activities, products or services
on the environment. It can also be used to support what an organization claims
about its own environmental policies, plans and actions.
As with ISO 9001 standards, the key to a successful ISO 14001 EMS (Environmental
Management System) lies in having documented procedures that are implemented
and maintained so that environmental goals are achieved successfully. An EMS
provides a framework for finishers to systematically identify, prioritize, manage,
mitigate and document the environmental aspects and impacts of its operations.
ISO 14001 standards require companies to document and make available to the
public their environmental policy. Procedures must be established for an ongoing
review of the environmental policy and the impacts of products, activities and
services. Based on these environmental aspects and impacts, environmental goals
and objectives are established that are consistent with the policy. Then programs
are established to implement these activities. Internal audits ensure that nonconformance
to the system is identified and addressed. The management review process must
ensure that top management is integrally involved.
The United States Environmental Protection Agency (U.S. EPA) recently endorsed
the ISO program, issuing the following statement, “EPA will encourage the
use of recognized environmental management frameworks, such as the ISO 14001
standard, as a basis for designing and implementing Environmental Management
Systems (EMS) that aim to achieve the outcomes aligned with the nation’s
environmental policy goals and the principles of this position statement.”
There are plenty of benefits to implementing an EMS plan as a basis for ISO
14001 certification, including:
- Identifying areas for reduction in energy and other resource consumption.
- Reducing environmental liability and risk.
- Lowering insurance rates.
- Helping maintain consistent compliance with legislative and regulatory
requirements.
- Preventing pollution and reducing waste.
- Maintaining good relationships with customers, the community and shareholders.
- Demonstrating a commitment to high quality.
- Improving work conditions for employees.
- Improving process control and monitoring trends.
An EMS is a logical way to begin ISO 14001 implementation.
Ruben Angel, regulatory compliance manager of Artistic Plating in California
stated, “The EMS gave Artistic Plating a better general awareness about
the environment. It helped us look at the cost of different aspects and at ways
of reducing not only the cost, but the amount of hazardous materials used. We
are more aware of where to look for substitutes.”
Filomena Bundang, environmental manager of Crown City Plating in California
agreed with Mr. Angel, noting, “The EMS program helps achieve compliance
and at the same time improves our bottom line. We set our objectives and targets
and raised our level of awareness and our team efforts in areas like pollution
prevention. It gave us tools to communicate our progress, successes and the
hurdles to our objectives.”
ISO 14001 is a completely voluntary international standard; however, many federal,
state and local regulatory agencies endorse it. Many global corporations now
require that suppliers comply with this standard as a condition of doing business.
Introducing an EMS
A metal finishing EMS template (See Figure 1) has four modules, each consisting
of one or more elements. These four modules include the following:
- Policy—environmental policy
- Planning—environmental aspects and impacts, compliance, objectives
and targets
- Implementation—roles and responsibility, communications, training,
EMS document control and emergency response and preparedness
- Review and Improvement—measurement and monitoring, EMS nonconformance
and corrective action, records, audits, management review.
Embarking on an EMS and ISO 14001 certification requires a broad spectrum of
support from the organization and a strong internal commitment from its employees,
particularly management. The ISO 14001 standard specifically requires a facility
to have a cross-functional team in place to implement the standard. Before beginning,
companies should identify an environmental manager and form an EMS team that
includes process supervisors, platers, wastewater treatment operators and others
familiar with the company’s processes. Also, having at least one team member
proficient in spreadsheet skills (e.g., Microsoft Excel) will help streamline
measurement charting.
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Specialized ISO 14001 Certification
Program
August Mack Environmental has developed a specialized program
for ISO 14001 certification called eCAP. All eCAP programs
are designed exclusively to allow the client to meet its specific
requirements. The program follows five steps.
1. Environmental and safety compliance audit.
This establishes which regulatory programs apply to your facility
and where you stand. It includes a records review and on-site
inspection.
2. Compliance review and planning.
The company meets with your management team to review your
current compliance status and plan for the future.
3. Site inspections.
The company routinely inspects your facilities with trained
personnel using customized compliance audits.
4. Electronic record keeping and reporting.
The company creates a customized system that manages your
compliance activities, reporting requirement and more. You
also have real-time access to your data.
5. 24-hour technical support.
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In addition to management, all employees should be knowledgeable about the EMS
and their input should be encouraged. Steve Deisher, director of marketing and
sales for TechMetals, Dayton, OH, explained how his company handled its ISO
registration. “We have about 100 employees here, some with more than 20
years on the job. We realized we would be dealing with many different perceptions.
Anytime you go to someone and tell them that you want to know what they are
doing, how they are doing it and ask them to show you exactly how it is done,
it makes them uneasy. We found, however, if you take the time to explain why
we are doing it, that it is meant to get a consistent product out for the customer
without unnecessary steps, they understand. We also explain that it makes it
easier for a person who takes over during a vacation or if the person gets a
promotion. Demonstrating the value of doing this has been the most effective
approach with employees.”
A preliminary review of the company’s environmental system should identify
current environmental management practices that can evolve into EMS elements
as well as missing EMS elements. Tim Aish, director of compliance for TechMetals
found that flowcharts can be particularly helpful with this phase of an EMS
as well as with all business operations at a finishing facility. “Developing
a flowchart for your processes, including waste treatment, makes it easy to
determine who is responsible for what. Flowcharts allowed us to see the redundancy
we had built into various operations. It allowed us to streamline many operations.”
During the preliminary review, it is important to quantify baseline environmental
conditions for comparison to future conditions. It will help measure improvement
or areas that need improving.
When developing an EMS for ISO 14001 certification, avoid reinventing procedures
for the EMS. Facilities can adapt existing training programs to include environmental
training or model EMS documentation and control procedures on existing quality
system document control. This is where a consultant can be particularly helpful;
however, be sure the consultant you hire is familiar with the metal finishing
industry.
When TechMetals decided to pursue ISO certification, it hired a consultant that
initially led the company down the wrong path. Fortunately, it realized the
problem early enough that it hired another consultant and was able to achieve
certification. “If you have well-established business practices and your
business is successful, the consultant should not come in and completely turn
the business upside-down,” commented Mr. Deisher. “The first thing
to do is write down your business practices and see where the standard fits
into your system. It is not about making a major change in how you do things.”
Environmental Policy
An environmental policy states an organization’s commitment to continuous
improvement in environmental performance. A strong, clear environmental policy
can serve as both a starting point for developing the EMS and eventual ISO 14001
certification and as a reference point for maintaining continuous improvement.
Ongoing evaluations and modifications are necessary to reflect changing environmental
priorities. The policy must address three issues: 1) Commitment to compliance;
2) Pollution prevention and 3) Continuous improvement.
Planning
Environmental Impacts and Aspects. The fundamental purpose of the EMS and ISO
14001 certification is to control and reduce the environmental impacts of a
facility’s processes and products; therefore, environmental aspects and
impacts associated with a facility must be identified and prioritized.
One approach to accomplishing this is to use the experience and judgment of
employees familiar with company’s environmental processes to identify the
top five environmental issues currently facing the facility. These issues and
their specific aspects and impacts need to be summarized.
A second approach uses detailed, structured matrices to list and prioritize
environmental aspects and impacts according to five categories:
- Wastewater
- Air emissions
- Hazardous and solid waste
- Raw materials
- Water and energy
For each aspect and impact, score each criterion on a scale of 1-5, with 1
meaning very important and 5 meaning unimportant or irrelevant. Add the scores
for all criteria for each aspect. This number indicates the relative priority
of the aspect compared to other aspects and impacts in the same category. The
lower the total score, the higher the priority.
Compliance. Because metal finishing operations generate a variety of wastes
in various forms, it is critical that companies develop and implement a structured,
comprehensive approach to compliance. To do this, a company must know what the
regulations are (federal, state, local and permit conditions) and implement
procedures and install equipment to comply with those regulations. Other environmental
elements may include customer specific codes, standards in locations where you
sell products, the Strategic Goals Program and other industry codes or programs
to which your company may voluntarily subscribe.
Objectives and Targets. An objective is a facility goal that is consistent with
the company’s environmental policy, priority environmental aspects and
impacts and applicable environmental regulations. A target is a more detailed
performance requirement related to and supporting a specific objective. Specific
targets must be met for an objective to be achieved. For example, an objective
may be to reduce hazardous wastewater treatment sludge (F006) generation. The
target would be to reduce dragout from the nickel plating baths by 25% within
18 months. Targets should be quantitative, realistic, linked to a source and
measurable.
Implementation
Roles and Responsibilities. For an EMS and ISO 14001 certification, roles and
responsibility for environmental management need to be clearly defined. Management
should designate an employee to establish the EMS for ISO 14001 certification
who will report its performance to management as well as work with others to
modify it when necessary. Again, using a flowchart to determine who reports
to whom will help establish this hierarchy. Responsibilities should include
internal and external communication and emergency response communications.
Training. This is one of the most important aspects when implementing an EMS
and ISO 14001 certification, because it can be used to communicate to all employees
the environmental impacts of their activities; the company’s environmental
policy; roles, responsibilities and procedures and methods and actions for reducing
waste generation and meeting EMS objectives and targets.
Mr. Deisher noted, “Many seem to think that ISO certification is a quality
department issue, when it isn’t. If you can get past that hurdle, it is
much easier, because it is not about quality, it is about how you run your business.
It is an issue the entire company is involved in.”
The program needs to address training topics—which employees should receive
training, when it should be given and the training method. There are various
training methods, including internal trainers, consultants, educational institutions,
suppliers, trade associations, self-study and computer-based training. Training
is necessary when a new employee is hired, job responsibilities change, procedures
change, new processes are developed, materials or equipment are introduced and
when new regulations are promulgated.
EMS and ISO 14001 Document Control. Document control ensures that the facility
creates and maintains documents in a manner to the extent necessary to implement
the EMS. Documents should be easily located, periodically reviewed and updated
and removed when obsolete.
Emergency Response and Preparedness. Most finishers have experienced some type
of emergency. An effective emergency response and preparedness program should
provide for the following:
- Assessing the potential for accidents and emergencies.
- Preventing incidents and their associated environmental impacts.
- Responding to incidents.
- Easing impacts associated with these incidents.
The program should describe the personnel responsible for completing emergency
preparations and incident reviews and how and when the tasks will be completed.
There are many overlapping requirements in local, state and federal regulations
concerning emergency response and preparedness. Helpful documents include process
flow diagrams, plant maps, drainage plans and design codes and standards.
Review and Improvement
Measurement and Monitoring. If the goal of the EMS and ISO 14001 certification
is to improve environmental performance through consistent compliance and waste
reduction, there must be measurable parameters that reflect environmental performance
trends. These measurements and monitoring results form the objectives and targets
discussed earlier in the article.
EMS Nonconformance and Corrective Action. EMS audits and self-inspection will
reveal deficiencies in the EMS or activities that do not conform to ISO 14001.
When nonconformance is identified, corrective action must be taken to address
and rectify the causes of nonconformance in a timely manner as established by
the EMS representative.
Corrective and Preventive Action for Compliance. Regulatory compliance audits,
self-inspections and measurement and monitoring activities reveal noncompliance
with regulations or situations that are contrary to targets and objectives.
When such situations occur, corrective action must be taken to address and rectify
the causes of the noncompliance or realign actions to meet specific objectives
and targets. For example, if wastewater discharge monitoring shows a steady
increase in metals concentration that approaches the discharge limit, preventive
action needs to be taken to ensure that the wastewater treatment system is operating
correctly. Measurements need to be taken to ensure that preventive actions have
been implemented and are working to correct the noncompliance.
When taking corrective and preventive action, describe the problem and how it
is inconsistent with specific targets, the likely cause of the problem, possible
solutions, implemented solution and results.
Records. Record management enables a facility to prove that it is actually implementing
the EMS and ISO certification process as designed. Focus on records that add
value and keep them accurate and complete. Consider combining the record management
system for environmental and health and safety. Use a computer to maintain records
and documents and make it available to employees. Consider the need for security
(i.e. Should access to some records be limited? Should duplicates of some be
maintained elsewhere?)
Audits. To identify and resolve EMS and ISO 14001 deficiencies, a company must
seek them out. This is accomplished using an audit. In finishing companies,
audits are particularly relevant since managers are often so close to the work,
they may not see problems or bad habits developing. Periodic audits establish
whether or not all requirements of the EMS and ISO 14001 standard are implemented
properly.
For ISO 14001 certification, there is a Phase I and a Phase II audit that cannot
be performed more than three months apart, and yearly audits are required after
that. Internal audits should be conducted at least annually. At TechMetals,
internal audits are conducted twice a year and scheduled at least six months
in advance to ensure that they occur.
An audit should focus on objective evidence of conformance. This can be certified
through interviews, document review and observation of work practices. During
the actual audit, auditors should resist evaluating why a procedure was not
followed. That step follows the audit.
If possible, train at least two employees as internal auditors. Also, before
embarking on an audit, be sure to tell employees in the affected area about
the audit’s scope, schedule and other pertinent information.
Management Review. These reviews are key to continuous improvement and to ensure
that the EMS will continue and ISO 14001 certification is successful. The management
review should assess how changing circumstances might influence the suitability,
effectiveness or adequacy of your EMS. Changing circumstances may be internal
to your organization or they may be external factors such as new regulations.
Some questions that may be helpful during a management review include the following:
- Did we achieve our objective and targets? (Why or why not?)
- Are roles and responsibilities clear and
do they make sense?
- Are the procedures clear and adequate?
- Do changes in laws or regulations require us to change some of our approaches?
- What effects have changes in materials, products or services had on our
EMS and its effectiveness? Does it affect ISO 14001 certification?
- What else can we do to improve?
For many companies, establishing an EMS and conforming to the ISO 14000 series
of standards may be a contractual requirement of customers. Also, because ISO
14000 is a continuation of the ISO 9000 Product Quality standards, it is expected
that ISO 14001 will become a requirement for attaining ISO 9002 recertification.
Many companies are setting goals to establish an environmental management system
that conforms to ISO 14001 guidelines in order to remain competitive in the
global marketplace. For companies that have already obtained ISO 9002 registration,
the ISO 14001 registration is a logical next step because it is very similar
to ISO 9001.
