ISO 14001:1996 4.3.1 Environmental Aspects NC DPPEA

Core Element of EMS Most other elements are directly associated with results from identifying and ranking aspects and their associated impacts: Policy Objectives and Targets Management Program Training/Awareness Operational Control Emergency preparedness Monitoring and measuring Corrective and Preventative Action Auditing I think it is important to emphasize that the company should be prepared to spend quality time on this element. Most other activities during the implementation of the EMS will be directly related to results from this effort. Facilities should try and not get discouraged by the time required for this element, it is one of the most time consuming.

Definition of Aspect / Impact Environmental aspect (cause) element of organizations activities, products, or services which can interact with the environment. Environmental impact (effect) any change to the environment whether adverse or beneficial, wholly or partially resulting from an organization’s activities, products, or services I thought it would be good to start off with the definition of aspects and impacts and provide some examples before we get to far into the presentation.

Aspect and Impact Example Activity, Product, Service Aspect Impact Boiler Operations Air emissions Air pollution Fuel consumption Natural resource depletion Boiler blowdown Water pollution Water consumption

Step One Establish a team. Examples: representative of QA/QC, maintenance, utilities, production divisions, office, environmental Educate the team on purpose and implications of this activity. This team may already be established for the development of the complete EMS or may be one that needs to be organized for this specific element. While some organizations have had one or two personnel to evaluate the environmental aspects and impacts, it is important to share the responsibility of the effort. Although having a larger team may require more upfront effort the results of the evaluation may be more useful and more broadly understood. This activity will help individuals from various departments or divisions of the organization step back and develop a better understanding of the true impacts of its activities. Also it will help to have a diverse background when evaluating significance of all these impacts. The team will need to be educated on definitions of and responsibilities related to developing a ranking of env. aspects and impacts. The next slides address issues that will be important for the team members to understand. The team will need to develop a methodology for identifying and ranking aspects and impacts. This procedure is not required to be documented but it would be extremely useful to document.

Purpose and Implications Determining the significant environmental aspects and associated impacts allows a facility to focus its time and resources on those issues with the greatest potential for environmental impact. The Ems team should be made aware that this process allows management to more effectively reduce potential environmental impacts through focusing resources on the activities with the greatest potential for environmental harm.

Purpose and Implications The evaluation of environmental aspects and their associated impacts should be primarily “fenceline” issues. 3.12 Definition of organization will establish “fenceline” or boundaries. Internal issues should not be a primary focus unless health and safety are included in management system. Defining the organization to which the EMS will apply is an important for step in EMS development for the aspect element as well as all the others. The primary aspects and associated environmental impacts are typically evaluated in terms of their impact across the boundaries or fenceline of the organization as opposed to internal issues. Thus small spills that occur within the fenceline and do not impact area outside fenceline through surface water, groundwater. land disposal, air etc. are not a primary area of focus. Obviously if the facility include health and safety within the EMS this will include internal issues

Purpose and Implications The organization only has to identify those environmental aspects that it “can control and over which it can be expected to have influence”. Control includes fiscal control (financial ability that can affect aspect) and organizational control (decision making authority that can effect aspect) The facility should not spend resources assessing aspects it cannot do anything about.

Purpose and Implications The following activities for identified significant environmental aspects will have to be completed under other elements: Operational procedures Education, competence and training of employees whose activities affect these aspects. Monitoring and measuring techniques. It is important for the team to keep in mind that the significant aspects they identify will impact the activities required to meet other elements. For example: The team should not rank items as significant just because they know there are environmental controls for it or that they can implement an easy objective and target for it because they will end up having to also monitor and measure this aspect, train employees on it, and develop procedures for activities related to it. Thus, the facility will create a lot more work for itself as related to other elements that won’t necessarily improve its environmental performance in relation to its true significant environmental aspects.

Step Two Identify Aspects / Impacts Select an activity, a product or service. Identify as many environmental aspects as possible associated with the selected activity. Identify as many actual and potential, positive and negative, environmental impacts associated with each identified aspect. Each team member should be responsible for identifying environmental aspects of the activities in the assigned area. The selected activity should be large enough for meaningful examination and small enough to be understood. It is important to consider the aspects and impacts that do not normally occur as well as the aspects that cause positive impacts.

Example Aspect / Impact Form The team will find it extremely useful to develop a universal form for collecting information on aspects and associated impacts of specified activities. During the process of gathering this information, team members should also identify whether the aspects has current controls or not. Additional information may be collected that will prove useful during other elements. For example, can improvements be made to controls, information on waste volume or usage data that can prove useful during significance determination, etc.

Identifying Aspects of Activities Activity Inputs: Raw material Electricity Water Outputs: Finished product Exhaust Waste products It may prove useful for team member to identify inputs and outputs from specific activities to help identify environmental aspects

Identifying Aspects and Impacts Aspects of activities that should be considered include: Emissions to air / releases to water Surface and groundwater Waste disposal / land contamination Raw material / natural resource use energy, water, chemicals, lumber, etc. Local environmental / community issues noise, odor, land use, appearance, etc.

Sources of information process flow diagram input/output (mass balance) regulatory reports utility bills QC information (defects, product changes) waste hauling records purchasing receipts records of external communication

Step Three Identify significant aspects Develop a definition of significance and determine what factors will be considered in determining significance Should involve input from top management Establish a rating scheme for the factors of significance It is important for top management to be involved in determining what the organization defines as significant.

Factors to Consider Environmental Concerns such as: The scale of the impact The severity of impact The probability of impact Duration of impact Business Concerns such as: Potential regulatory and legal exposure Difficulty and cost of changing the impact Effect of change on other activities and processes Concerns of interested parties Effect on the public image of the organization There are many factors for the team to consider when developing the criteria of what is considered significant both in terms of the environment and business operations.

Significance Criteria Example Rating Scheme Significance Criteria Rating Scheme Legal Liabilities: Is the aspect regulated Low (1): Issue not regulated Medium (2): Violation or possible fine High (3): Criminal Action Public Concern: Has the Public ever expressed concern about the aspect Low (1): never Medium (2): sometimes High (3): Often Frequency: What is the overall frequency or probability of the aspects impact Low (1): less than once a year Medium (2): Between 1/mn and 1/yr High (3): Occurs monthly or more freq. Severity: What is the overall severity of the aspects impact Low (1): impact aesthetic, amenity Medium (2): impact water, air, soil quality High (3): detrimental to human, flora fauna Once the team has identified that factors or criteria it will need to develop a rating scheme that defines for the team member when to apply a specific value or indicator to the aspect and associated impact.

Example Significance Matrix Activity, Product, Service Aspect Impact Legal Liability Public Concern Frequency Severity OSR Significance (OSR>2.5) Dissolve Mineral Ore Water use Resource depletion 1 3 2 1.75 No Natural Gas Use Resource depletion 1.50 Air pollution (Nox) Use of Strong Acids Spills to land or water 2.75 Yes The team will rank the aspects and impacts for each criteria using the rating scheme. This effort should be evaluated as a group at some point so that all members have an understanding and can offer input into how items are scored.

Additional Resources ISO 14004 See DPPEA website http://www.p2pays.org/iso/index.htm Refer to Alcoa and Uniroyal Chemical Co. EMS Manuals in your notebook