Checking & Corrective Action EPA Regions 9 & 10 and The Federal Network for Sustainability

ISO 14001 Components Policy Planning Implementation and Operation Checking and Corrective Action Management Review

ISO 14001 Elements Checking and Corrective Action involves: Monitoring and measurement Nonconformance and corrective and preventive action Records EMS Audits

Monitoring and Measurement EPA Regions 9 & 10 and The Federal Network for Sustainability

Requirements Document procedures to routinely monitor and measure activities with significant impacts Record progress on objectives & targets Calibrate equipment Evaluate compliance Keep records

Actions to Support Measurement Identify performance indicators Establish schedules for monitoring Establish record-keeping requirements Document measurement procedures Communicate to appropriate staff and managers Performance indicators should be objective, verifiable and reproducible. Should be relevant to the organization’s activities, consistent with its environmental policy, practical, cost-effective, and technologically feasible.

Nonconformance and Corrective and Preventive Action EPA Regions 9 & 10 and The Federal Network for Sustainability

Requirements Establish procedures for Non-conformance with the EMS detecting reporting investigating correcting preventing Non-conformance with the EMS

Actions Identify cause of nonconformance Determine appropriate response Ensure actions are appropriate to the size of the problem Identify personnel responsible for corrective action and their authorities Implement corrective action

Actions continued Investigate root cause to identify potential preventive action Implement or modify controls to prevent repetition of the nonconformance Track progress on correction/prevention Document changes in written procedures Record the changes made

EPA Regions 9 & 10 and The Federal Network for Sustainability Records EPA Regions 9 & 10 and The Federal Network for Sustainability

Requirements Identify records associated with environmental issues Establish and maintain procedures for their identification, maintenance and disposal ISO14001 4.5.3 specifically mentions including training records and results of audits and reviews. ISO14004 describes records as: Legislative and regulatory requirements Permits Environmental aspects and their associated impacts Environmental training Inspection, calibration and maintenance activity Monitoring data Details of non-conformance: incidents, complaints and followup actions Product identification: composition and property data Supplier and contractor information Environmental audits and management reviews Records shall be legible, identifiable and traceable to the activity, product or service involved. E. Records shall be stored and maintained so they are readily retrievable and protected against damage, deterioration or loss.

Documents vs. Records Documents Records Offer guidance or explain actions to be carried out Can be changed Records Provide verification of things that have happened Cannot be changed

Documents vs. Records Documents are materials that provide management directions: environmental policy internal standards and operating procedures EMS procedures organization charts emergency plans Records include training records incident reports product information complaints and responses audit results management review meeting minutes

Scope of Records Records should cover: Legislative and regulatory requirements Permits Environmental aspects and their associated impacts Environmental training activity Inspection, calibration and maintenance activity Continued…

Scope of Records …Records should cover: Monitoring data Details of non-conformance: incidents, complaints and follow-up action Product identification: composition and property data Supplier and contractor information Environmental audits and management reviews

Requirements for Records Maintenance Good environmental information management includes: Identification Collection Indexing Filing Storage Maintenance Retrieval Retention Disposal

EPA Regions 9 & 10 and The Federal Network for Sustainability EMS Audits EPA Regions 9 & 10 and The Federal Network for Sustainability

Requirements Determine whether the system conforms Assess whether it has been properly implemented and maintained Provide information to management

Types of EMS Audit Complete Partial Internal External Certification audit Surveillance audit

EMS Audit Protocol Establish procedures that cover Scope Frequency Methodologies Audit responsibilities Reporting responsibilities

Audit Program Establish audit schedule Internal External Base on environmental importance of the activity Consider results of previous audits

Audit Process Document and record review Opening meeting Site tour Interviews Auditor conference(s) Findings development Closing meeting Audit report

Audit Outcomes Report to management Identify corrective actions Record audit results

Continual Improvement Identify areas for improvement of EMS Determine root cause of nonconformance Develop corrective and preventive action plan Implement corrective and preventive actions Verify effectiveness of action plans Make changes to procedures

Summary An EMS involves checking and corrective action procedures Identifies nonconformances and opportunities for improvement The system itself is audited Document changes in procedures Record changes made