ISO 14001:2015 Overview Charlie Parrish charles parrish@ncsu

ISO 14001:2015 Overview Charlie Parrish charles [email protected] (919) 515-4266

What is ISO 14001? 2

ISO 14001 - 2004 4.1 General 4.6 Management Review 4.5 Checking Continual Improvement 4.2 Environmental Policy 4.5.1 Monitoring and Measurement 4.3 Planning 4.5.2 Evaluation of Compliance 4.5.3 Nonconformity, Corrective Action and Preventive Action 4.5.4 Control of Records 4.3.1 Environmental Aspects 4.3.2 Legal/Other Requirements 4.3.3 Objectives, Targets and Programs 4.5.5 Internal Audits 4.4 Implementation & Operation 4.4.1 Resources, Roles, Responsibility & Authority 4.4.2 Competence, Training & Awareness 4.4.3 Communication 4.4.4 Documentation Red Identifying Env. Issues Blue Managing Env. Issues 4.4.5 Control of Documents 4.4.6 Operational Control 4.4.7 Emergency Preparedness/Response 3

ISO 14001 - 2015 10 Improvement 10.1 General 10.2 Nonconformity and corrective action 10.3 Continual improvement 9 Performance evaluation 9.1 Monitoring, measurement, analysis and evaluation 9.1.1 General 9.1.2 Evaluation of compliance 9.2 Internal audit 9.2.1 General 9.2.2 Internal audit program 9.3 Management review 8 4 Context of Organization Continual Improvement 4.1 Understanding the organization and its context 4.2 Understanding the needs & expectations of interested parties 4.3 Determining the scope of the EMS 4.4 Environmental management system 5 Leadership 5.1 Leadership and commitment 5.2 Environmental policy 5.3 Organizational roles, responsibilities and authorities Operation 8.1 Operational planning and control 8.2 Emergency preparedness and response 7 Support 7.1 7.2 7.3 7.4 Resources Competence Awareness Communication 7.4.1 General 7.4.2 Internal communication 7.4.3 External communication Documented information 7.5.1 General 7.5.2 Creating and updating 7.5.3 Control of documented information 7.5 6 Planning 6.1 6.2 Actions to address risks and opportunities 6.1.1 General 6.1.2 Environmental aspects 6.1.3 Compliance obligations 6.1.4 Planning action Environmental objectives and planning to achieve them 6.2.1 Environmental objectives 6.2.2 Planning actions to achieve environmental objectives 4

How Does ISO 14001-2004 Work? What are the Environmental Issues? How are they managed? How are they checked? How are “issues” fixed and improved? Legal Requirements 4.3.2 Significant Aspects 4.3.1 Targets & Objectives 4.3.3 EMS Audits 4.5.5 Training Programs 4.4.2 Monitoring & Measurement 4.5.1 Corrective / Preventive Action 4.5.3 Operational Controls 4.4.6 Potential Emergencies 4.4.7 Emergency Response Plans 4.4.7 Compliance Evaluations 4.5.2 Emergency Drills 4.4.7 Management Review 4.6 5

How Does The New ISO14001-2015 Work? What are the Environmental Issues? Outsourced Processes 8.1 Planned or Unplanned Changes 6.1.2 Env Aspects w/ Product Life Cycle (transportation, end of life, disposal) 6.1.2, 8.1 Risks & Opportunities - General 6.1.1 Significant Aspects 6.1.2 Legal Requirements 6.1.3 Potential Emergencies 8.2 & 6.1.2 How are they managed? Communicate Req’ts to - outsourced processes - contractors - other (re: stages of LC) Env requirements for Procurement Env Req’ts for the Design & Development of product/ service Competence 7.2 & Awareness 7.3 Operational Controls 8.1 Planning Action (to Address 6.1) 6.1.4 Targets & Objectives 6.2.1/6.2.2 Emergency Response Plans 8.2 How are they checked on? Compliance Evaluations 9.1.2 Monitoring & Measurement 9.1.1 EMS Audits 9.2 Emergency Drills 8.2 How are “issues” fixed and improved? Corrective / Preventive Action 10.1 Management Review 9.3 6

The New ISO 14001 Standard http://www.iso.org/iso/home/store/ catalogue tc/catalogue detail.htm? csnumber 60857 The revised ISO 14001 was published on Sept 2015. Some changes are: From 5 pages to 11 pages Elements (clauses) from 18 to 32 Structure same as ISO 9001 & other Management System Standards (MSS) incorporating High Level Structure format Context, Leadership, Planning, Support, Operation, Performance, Improvement 7

The New ISO 14001 Standard (1 of 2) 8

The New ISO 14001 Standard (2 of 2) http://asq.org/quality-press/display-item/?item T986E http://www.iso.org/iso/home/standards development.htm 9

8 Big Changes (1 of 3) 1) 4.1- Understanding the Organization and its context - by determining – A) External circumstances – political, regulatory, international, national, etc. B) Internal characteristics (i.e., strategic direction, culture, capabilities) C) Environmental conditions – that could affect the organization (climate, natural resource availability, etc.) 2) 4.2 - Understanding the Needs of Interested Parties. Who are the interested parties relevant to the EMS, What are their needs and expectations 3) 5.1 - Leadership and Commitment. Top Management must demonstrate its commitment to the EMS for a list of items, none of which are required to be documented or recorded (but it may help) 10

8 Big Changes (2 of 3) 4) 6.1.1 - Actions to address Risks and Opportunities – Must be “determined” on issues surrounding “context” as per 4.1 and “interested parties” as per 4.2, as well as for aspects and legal requirements 5) 6.1.2 - Environmental Aspects of Products – Considering life-cycle perspective. (i.e., environmental issues associate with design, use, end of life and disposal 6) 8.1 - Operational Controls - for product design and development for life cycle stages AND provide information about potential significant impacts on product delivery, use, end-of-life and disposal AND Environmental requirements for purchasing 11

8 Big Changes (3 of 3) 7) 10.2 - No Preventive Actions formally required (it’s all corrective action) 8) 7.5 - No mention of the word records (it’s all documented information) 12

4.1 Understanding the organization and its context (1 of 4) Determine the internal and external issues relevant to the EMS. Include environmental conditions being affected or capable of affecting the organization THIS IS - A HIGH LEVEL UNDERSTANDING - INCLUDE IMPORTANT ENVIRONMENTAL TOPICs - INCLUDE CHANGING CIRCUMSTANCES 13

4.1 Understanding the organization and its context (2 of 4) Understanding Aspects & Impacts is “extremely one dimensional” when compared to Understanding the Context if the organization*. Understanding includes the organization’s - direct and indirect environmental consequences - legal requirements - effects on your stakeholders by the EMS * John Nolan (google search) 14

4.1 Understanding the organization and its context (3 of 4) Examples include: Env. Conditions – Climate, Air & Water Quality, Land Use, existing contamination, natural resource availability, biodiversity, etc. External cultural, social, political, legal, regulatory, financial, technological, economic, natural and competitive circumstances, whether international, national, regional, or local Internal characteristics or conditions of the organization such as activities, products and services, strategic direction, culture and capabilities (i.e. people, knowledge, processes and systems 15

4.1 What does it look like ? (4 of 4) Document the context in the EMS manual – or document meeting minutes where these issues are discussed (i.e. Management Review, etc.) 16

4.2 Understanding the needs and expectations of interested parties This appears to be a duplicate requirement for listing compliance obligations (i.e. interested parties regulatory agencies) Interested parties could be sponsors of voluntary requirements (contractual, trade associations, etc.) Corporate Management Community Members Others 17

4.3 Determining the Scope of the EMS Similar to the 2004 standard (4.1 General Requirements) Consider External and internal issues (as per 4.1) Compliance obligations (as per 4.2) Organizational units, functions and physical boundaries Activities, products and services Control and Influence How many times will we reference 4.1 and 4.2 in this standard ? 18

4.4 Environmental Management System A general, overall requirement stating the org. must : - establish, implement maintain and continually improve an EMS that meets ISO 14001 - consider the knowledge gained in 4.1 - Understanding the organization and its context 4.2 – Understanding the needs and expectations of interested parties References 4.1 and 4.2 - #2 19

5.1 Leadership and Commitment Top Management shall demonstrate leadership and commitment by - taking accountability for the effectiveness of the EMS - ensuring policy and objectives are established - integrating EMS with business plan - ensuring resources - communicating the importance of EMS - ensuring the EMS meets "intended outcomes" - directing and supporting persons in the EMS - promoting continuous improvement - supporting other management roles 20

5.2 - The Three Pillars (commitments) of Your Environmental Policy: Company Policy Statement Compliance Protection of the Environment Continual Improvement 21

5.3 / 7.1 - Organizational Roles, Responsibilities, and Authorities / Resources Roles, responsibilities, and authorities must be Assigned, documented, communicated Determine and provide resources needed (7.1) Top Management must assign responsibilities for reporting on the performance of the EMS 22

6.1.1 Actions to address risks and opportunities Determine risks and opportunities associated with: - aspects - legal obligations - consider 4.1 and 4.2 (Ref’s - #3) - Determine potential emergencies (to be used in 8.2) 23

6.1.2 Environmental Aspects & Impacts Air Emissions Air Pollution Packaging Land Fill Space Energy Use Fossil Fuel Depletion Metal Chips Minerals Depletion Stormwater Water Pollution Transportation Air Pollution Wastewater Water Pollution 24

6.1.2 Significant Aspects 6.1.2 by using established criteria 25

6.1.2 Env. Aspects – Life Cycle determine the environmental aspects considering life cycle perspective for activities, products and services THAT IT CAN CONTROL OR INFLUENCE taking into account: - changes (MOC) - emergencies 26

6.1.3 – Compliance Obligations Determine compliance obligations Have access to them Determine how they apply Take them into account 27

Example Legal Requirements Legal Req’t Code Hazardous Waste 40 CFR 261 Management Air Quality Permit 15A NCAC 2Q.0100 Storm Water 15A NCAC Exclusion 2H.0126 Municipal Thomasville Wastewater Code Aspect Haz Waste Disposal Air Emissions Stormwater Run-off Wastewater Discharges 28

6.1.4 – Planning Action Organization Shall Plan: Significant environmental aspects Compliance obligations Risk and opportunities 29

6.2.1 & 6.2.2 – Objectives and Planning Actions Objectives—Result to be Achieved: - Consistent with Environmental Policy - Considering Sig Aspects, Legal Req’ts & Risks/Opportunities Planning Actions (Programs): What will be done, Resources, responsible party & Due Date 30

Example Objective & Plan Activity/ Product or Service Maint. Work Area Objective: Revision Date: Noise Minimization Project Plan Title: Aspect 2/20/2003 Significant (S) / Legal (L) / Emergency (E) Impact(s): Noise (from Compressor) Environmental Noise S/L Decrease noise to below 80 dBA Responsibility Target(s) Employee Title Date Due 1 Build wall around work area. Roy Maintenance Jun-03 2 Purchase low noise compressors. Roy Maintenance Aug-03 Task # Other Tasks - Description 1-1 Qet Quote on Wall 1-2 Select Vendor, Get apporved and Award Bid 1-3 Build Wall 1-4 2-1 Qet Quote on Compressors 2-2 Select Vendor, Get apporved and Award Bid 2-3 Install Compressors 2-4 Investigate replacing all other "High Noise" Compressors Responsibility Employee Title Date Due Date Completed Date Completed The term “Target” Not used.

7.2 & 7.3 Competency and Awareness 7.2: Determine 1) the necessary competence 2) ensure competence 3) training needs 4) take action to acquire competency 7.3: Ensure persons are aware of 1) the environmental policy 2) Significant Aspects of their work 3) Benefits of improved personal performance 4) Implications of NOT conforming to the EMS (including compliance obligations) 32

Specifying Environmental Training Needs 33

7.2 & 7.3 - Competency and Awareness 34

DH 7.4, 7.4.2, & 7.4.3 - Communication: Internal and External Develop procedure for Internal & External communication Document External Communications such as Regulatory agencies Community Complaints Sustainability Issues w/ Customers Others Decide if AND how to communicate externally about significant aspects 35

7.5 - Documentation Information 7.5.1 General - What ever is required by ISO 14001 - What ever is needed for EMS effectiveness 7.5.2 Creating and Updating - Ensure identification EMS - Format Manual - review and approval Procedures 7.5.3 Control of Documented Info - available, suitable, protected, Work - distribution, access, retrieval, use Instructions - storage, preservation, change control, Records retention & disposition - external documents 36

Documented Information - Procedures - The 2015 std has replaced requirements for “procedures” w/ requirements for “processes” 37

Documented Information - Records - The term “Records” is not used in 2015 standard - However, the org. must still present “evidence” to show they have Determined . Identified Developed Plans (more of a “procedure”) 38

ISO 14001:2015 - Docs and Records (1 of 5) 39

ISO 14001: 2015 - Docs and Records (2 of 5) 40

ISO 14001: 2015 - Docs and Records (3 of 5) 41

ISO 14001: 2015 - Docs and Records (4 of 5) 42

ISO 14001: 2015 - Docs and Records (5 of 5) 43

8.1 - Operational Planning & Control Establish processes needed to meet the EMS, 6.1 and 6.2 by: 1) establishing criteria for processes, and 2) implementing control of processes to meet criteria. i.e., Haz Waste Storage Boiler Operation Paint Booth Maintenance Storm Water Sampling Air Permit Etc. 44

8.1 - Operational Planning & Control New Pieces of the puzzle for 8.1: - Control planned changes, consequences of unintended changes and mitigate the environmental impacts (MOC also is in 6.1.2) - ensure outsourced processes are controlled or influenced (as stated in the EMS) - Address Life Cycle (LC) perspective by establishing env. controls in the design and development process for each LC stage Env. Requirements for procurement Communicating env. requirements to contractors Consider providing info on env. impacts of the different life cycle stages of product 45

8.2 Emergency Preparedness Re: potential emergencies identified in 6.1.1 Develop emergency preparedness & response plans Include plans for mitigating “environmental impacts” Test emergency plans (fire drills) Others 46

Example - List of Potential Emergencies # Potential Emergencies or Accidents 1 Floods Water Pollution from vehicles and machines EWI-001 2 Hurricanes Loss of Human Life EWI-001 3 Tornadoes Loss of Human Life EWI-001 4 Fire Air Pollution, Loss of Human Life EWI-002 5 Chemical Spillssmall Employee Exposure (irritants mostly) EWI-003 6 Chemical Spillslarge Employee exposure, Water Pollution EW-003 7 Waste Water Tote Soil / Ground Water Contamination. Spills Potential Impact Emergency Response Plan to be Used EWI-004 47

9.1.1 – Monitoring, Measurement, Analysis, and Evaluation - General Determine - Performance metrics and comparison criteria - monitoring methods, when, where, etc. - evaluation of metrics (trends) - effectiveness of the EMS Conduct Calibrations or Verifications Communicate performance data as per communication process 48

9.1.1 – Monitoring, Measurement, Analysis, and Evaluation - General 49

9.1.2 – Evaluation of Compliance ------ The 2nd Audit Program ------ Conduct an EoC against compliance obligations (6.1.3; used to be Legal & Other Environmental Requirements) Develop a process for EoCs wrt frequency Conduct the EoC and Take Action if needed Maintain knowledge and understanding of its compliance status 50

Example Compliance Evaluation Report 51

9.2.1 & 9.2.2 – Internal Audit (1 of 2) To Determine if EMS meets: ISO 14001 EMS Procedures & Programs 52

9.2.1 & 9.2.2 – Internal Audit (2 of 2) Establish an audit program for - frequency, methods, responsibilities & reporting - Define audit criteria and scope - select auditors for objectivity and impartiality - Ensure audit results are reported to Management NO REAL CHANGES FROM 2004 53

9.3 – Management Review Involve Top Management Determine if EMS is Continuingly Suitable Adequate Effective BOTTOM LINE: Determine if EMS needs to be CHANGED Follow required Inputs and Outputs Req’d Docs/Records: - Management Review Schedule - Documented Minutes 54

10.2 – Nonconformity and corrective action Control and correct the NC Mitigate environmental impacts (immediacy) Determine causes & action needed so that it does not recur (actual nonconformities) occur (potential nonconformities) 55

10.1 – Improvement - General Determine opportunities for improvement (see also 6.1.1; 9.3 Implement necessary actions to achieve “intended EMS outcomes” 10.3 – Continual Improvement Continually improve the suitability, adequacy and effectiveness of the EMS to enhance environmental performance 56

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Auditing Tips Good Auditors Take Time To develop Audit Experience more important than training class Develop Your Audit Program For Your Needs (Use Specific Questions) Don’t Waste Resources on Duplicating other inspections or audits Audit Management for “ISO “ – Audit NonManagement for “their” requirements Reward Auditors for their Efforts 58

Thea Dunmire’s 6 Potential Pitfalls to ISO 1) There is legal liability that could be uncovered by ISO 14001. 2) 14001 designates Top Management as responsible. This could connect TM to potential legal issues. 3) Treat audit findings and related confidentially especially with external auditors, registrars, etc. 4) Correct identified problems or there maybe potential – “willful violations.” 5) Written procedures can over-complicate EMS and create additional legal obligations. 6) Realize that records can implicate. “Get a handle” on all records “floating around”. www.enlar.com 59

The Newly Proposed ISO 14001 - BLOG http://www.ies.ncsu.edu/news-center/blog/the-new-dis14001-2014-is-it-too-late-to-clean-it-up 60

ISO.org Revision Fact Sheet http://www.iso.org/iso/home/standards/managementstandards/iso14000/iso14001 revision.htm 61

Similarities 18001 with 14001 62

How’s Does OHSAS 18001 Work What are the OHS Issues How are they managed ? Objectives & Programmes 4.3.3 How are they checked on ? OHS MS Audits 4.5.5 How are “issues” fixed and improved 63 Legal Requirements 4.3.2 JHAs and Risks 4.3.1 Training Programs 4.4.2 Incident Investigation 4.5.3.1 Operational Controls 4.4.6 Monitoring & Measurement 4.5.1 Corrective / Preventive Action 4.5.3.2 Potential Emergencies 4.4.7 Emergency Response Plans 4.4.7 Compliance Evaluations 4.5.2 Management Review 4.6 Emergency Drills 4.4.7

How’s Does ISO/CD 45001 Work 64

Identifying Environmental Aspects * Legal & Other Requirements Setting Objectives, Targets, Programs * Environmental Training Environmental Communication Document Control Operational Controls Contractor Management Emergency Response Planning Monitoring & Measuring Compliance Evaluation Corrective & Preventive Action Environmental Records Internal EMS Audit EMS Management Review ISO 14001:2004 Level 2 Procedures Required Recommended Red Add to 9000 Procedure 65

7.5 - Documentation - Typical ISO 14001 Document System EMS Manual Procedures Work Instructions Records Intent & Direction What you do & who does it How you do it Evidence of what you do 66

Links http://www.bms-services.com/iso-140012015/ 67

6.2.1 xxx 68

14001: 2004 - Docs & Records (1 of 2) 69

14001: 2004 - Docs & Records (2 of 2) 70

Op Controls (part 2) . Communicate relevant requirements to those external providers including contractors Grounds keeping No pesticides allowed Air Conditioning/ Chiller servicing Service technicians must show proper certification to handle Freon On-site Contractors must follow our Construction facility’s liquid waste disposal procedures Shipping (trucking, All Shippers must check in with transportation, bulk the Shipping/Receiving Dept. for delivery, labeling) instruction on our bulk chemical unloading procedures 71

Other Legal Requirements Legal Req’t Code Aspect Corporate Environ. Policy Customer Manadate for ISO Pallet Nemotode Treatment Customer Prohibition of Toxics Company Web Could be Site several Customer Letter Could be several Geographical Shipping Request Letter Customer Letter Raw Material Usage 72