TOOLS FOR IMPLEMENTATION OF ISO 14001
ENVIRONMENTAL MANAGEMENT SYSTEM FOR OAK RIDGE
OPERATIONS ENVIRONMENTAL MANAGEMENT PROGRAM
Charlene Caswell
Quality Assurance Specialist
Jacobs EM Team
125 Broadway Avenue
Oak Ridge, TN 37830
Clayton Gist, Ph.D.
Waste Operations Team Leader
Environmental Management
Post Office Box 2001
Oak Ridge, TN 37831-8541
Ana Rosado-Gonzalez, M.S.
Program Manager
Environmental Management
Post Office Box 2001
Oak Ridge, TN 37831-8541
ABSTRACT
In 1996, the International Organization for Standardization (ISO) issued its standard 14001. By the end of that year, only a small percentage of U.S. companies had registered or "self-declared" their conformance with the standard. Today, the increased acceptance of this standard is evidenced by the number of companies and government entities that are in the initial phase of implementing an environmental management system (EMS). With the standards increased popularity and growing awareness of its benefits, many organizations are now interested in learning how to implement, monitor, and manage an EMS. The U.S. Department of Energy, Oak Ridge Operations Office (DOE-ORO), Environmental Management (EM) Program, recently evaluated these benefits and decided to implement an EMS using the elements identified in ISO 14001. This paper shares specific tools, lessons learned, and workable recommendations with other organizations that may be considering an EMS.
INTRODUCTION
This paper discusses the specific systems and tools being developed and employed by the U.S. Department of Energy, Oak Ridge Operations Office (DOE-ORO), Environmental Management (EM) Program to implement International Organization of Standards (ISO) 14001 Environmental Management System (EMS) requirements. ISO 14001 is being used to meet the objectives defined in the DOE Accelerating Cleanup: Focus on 2006, which presents the strategy to remediate the Oak Ridge Reservation by 2006. Specific examples of the tools and systems being used include selection of the ISO 14001 EMS lead team, gap analysis, establishing schedules for implementation, action tracking, and EMS employee orientation packages. This paper summarizes the status of EMS implementation, shares lessons learned, and provides recommendations.
As indicated above, the focus of this paper will be on tools for planning and implementation of the EMS. Therefore, an elementary understanding of the ISO 14001 standard would benefit readers. Numerous resources exist providing background information on the ISO 14001 EMS including extensive documentation available on the Internet.
TOOLS FOR IMPLEMENTATION
Selection of the EMS Lead Team
As a critical first step in implementing the EMS, EM management appointed an EMS representative and established criteria for selecting EMS lead team members. Members were selected based on their expertise in five substantive elements of ISO 14001: policy, planning, implementation and operation, checking and corrective action, and management review. For example, the "checking and corrective action" element was assigned to the DOE-ORO QA program manager based on previous experience in auditing and corrective action tracking. Individuals with expertise in regulatory compliance, pollution prevention, project controls, health and safety, and waste management were also selected to cover the remaining elements of the standard.
After the lead team was formed, members attended a 5-day American National Standards Institute Registrar Accreditation Board (ANSI-RAB) certified lead auditor course. The course included a detailed history of the ISO 14000 series standards, elements of the ISO 14001 EMS, and auditing techniques against the requirements of ISO 14001 standard. Team members who attended this course gained a solid foundation to begin planning and implementing the EMS.
Gap Analysis
After completing the ISO 14000 lead auditor course, team members performed a preliminary gap analysis of EM Program conformance with ISO 14001 requirements. This initial evaluation took place during an informal working group session. Although results from the preliminary review were not detailed, they provided the team information on the current status of EM processes with conformance to ISO 14001 EMS requirements. Results of this review were documented in the EMS action tracking system.
The continuing process of compiling and reviewing all applicable plans, procedures, and systems within the organization is a tremendous effort. This is especially true given the state and federal laws, secretarial mandates, procedures and plans, and DOE Orders applicable to the EMS. Ideally, the team would find minimal gaps and could maximize the use of existing systems and procedures. Additional processes would be added with caution and only where no existing system or procedure would suffice. Figure 1 shows how gaps are analyzed against the five elements of ISO 14001.
Figure 1. Gap Analysis Scheme
Establishing Schedules for Implementation
The preliminary gap analysis allowed the team to establish schedules for completion of specific activities required by the EMS. These activities include employee orientation; developing procedures and the EMS manual; and future plans for managing and assessing the EMS. (Figure 2).
Figure 2. Establishing Schedules for Implementation (current as of November 1997)
By identifying key activities and setting firm schedules, the team avoids the endless implementation loop. Schedules allow team members to clearly focus on activities required for implementation and are a useful tool for planning and identifying resources needed for future completion of activities.
Action Tracking
Actions resulting from gap analysis and additional action items identified during EMS team meetings are captured in the EMS action tracking system. This system was developed with user-friendly software and has multiple reporting capabilities. Reporting fields include assigned actions, corresponding section of the standard, person(s) responsible, due date, and comments sections. An example of the action tracking system is shown in Table I.
Table I. Action Tracking Report
Section: 4.2 Environmental policy | |||
Assigned: | Wednesday, May 07, 1997 | Assigned to: | Gonzalez |
Due: | Monday, December 15, 1997 | Status: | Open |
Action: | Provide final policy statement; review and finalize EMS policy statement and present to upper management for approval. |
Comments: |
|
Section: 4.3.2 Legal and other requirements | |||
Assigned: | Tuesday, June 10, 1997 | Assigned to: | Ferre |
Due: | Friday, January 30, 1998 | Status: | Open |
Action: | Define and develop procedures for identifying and accessing legal and other requirements applicable to identified environmental aspects. |
Comments: Pending reassignment of actions. | |
Assigned: |
Thursday, September 25, 1997 | Assigned to: | Rice |
Due: | Monday, March 30, 1998 | Status: | Open |
Action: | Update existing procedures. |
Comments: |
Actions are divided among the team members, focusing on area of expertise to expedite task completion. Actions are added or removed as necessary. Updated reports are provided to team members during EMS team meetings.
EMS Employee Orientation
To effectively implement the EMS, supervisors and employees must understand the environmental policy, the overall benefits of the EMS, and their roles/responsibilities in implementing and managing the EMS. Therefore, an understanding of the EMS at some level is critical to its success and acceptance throughout the organization.
Employee orientation packages focus on the specific benefits and roles/responsibilities of individuals receiving the orientation. For example, the first orientation session is for DOE EM program managers and focuses on benefits of the EMS and the program managers specific roles/responsibilities for implementation of programs and projects. The orientation also focuses on awareness of the EMS policy. Table II outlines the program manager orientation package.
Table II. DOE Program Manager Orientation
Sections |
Outline |
Introduction |
Covers the need for an EMS, benefits, and the environmental policy |
Understanding ISO 14000 |
Gives a brief description of ISO 14000, history and background, and relationships with other agencies |
Elements of the EMS |
Gives the key elements and examples of roles and responsibilities of the program managers implementing and managing the EMS in their programs |
Implementation Status |
This section will inform the program managers of team status "where are we" and "where do we plan to go" |
Future orientation packages will focus on the roles and responsibilities of technical and administrative staff. Orientations will be documented and maintained as part of the EMS.
STATUS OF IMPLEMENTATION
As shown on Figure II, DOE is continuing the gap analysis to determine conformance with ISO 14001 EMS requirements. This process should continue through December 1997.
In 1998, procedures will be developed or revised as necessary to fill identified gaps. The EMS manual will be written to serve as a roadmap for the environmental aspects and impacts, legal requirements, processes, procedures, and plans required by the EMS. The team will also focus on how to manage the EMS.
It will be necessary to implement an EMS auditing program and identify a system for tracking audits and corrective actions. A system will also be needed to control documentation that results from the EMS.
LESSON LEARNED/RECOMMENDATIONS
The team has several actions to close before implementation of the EMS is complete. Nonetheless, a number of lessons learned and recommendations have been identified, as summarized below.
Communication lines should be opened immediately after the decision is made to implement an EMS. All employees must be made aware of the system through briefings, staff meetings, and/or presentations. Management should communicate to personnel that equivalency of the standard may already exist from regulations, processes, and procedures that the organization already has in place. This will defuse any concerns about management "reinventing the wheel". Also, consider publishing a monthly newsletter informing personnel of EMS Team accomplishments as well as local and national EMS highlights.
Team members should attend an ISO 14001 implementation or auditing course. EMS team members found the course very beneficial in understanding and applying the elements of ISO 14001 to EM.
Commitment of top management is critical to implementing the EMS. Unless benefits of the EMS are communicated to all employee levels, the chances of success are minimal.
"Where are we and where do we plan to go" is the phrase originally used by one of the coauthors of this paper. This idea has evolved into a tool that is consistently used to focus the teams energies and maintain a common vision. While recognizing that other organizations will and should have their modifications to this, a concept that encourages consistent reevaluation and focuses on the objectives of implementing the EMS is critical to its success.
The development and implementation of the EMS must be a primary responsibility of employees working on the team. Appropriate time and resources must be provided to employees to complete the numerous actions required to plan and implement the EMS.