ISO 14000: Environmental Management

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.

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.

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:

1. Wastewater
2. Air emissions
3. Hazardous and solid waste
4. Raw materials
5. 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.