evaluating 20 compliance
TRANSCRIPT
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Evaluating Compliance
Dr Emma Goodchild
Manager, ENVIRON, Manchester
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Agenda
Background
ISO 14001 Requirements
Meaning of ‘Evaluation’
Process for a Compliance Evaluation
Summary
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Background
The value of ISO 14001 was / is being reduced bycertified companies being prosecuted
New clause was introduced in 2004 version of‘ ’
Presents a key challenge to most organisations dueto very wide scope and the significant knowledge
requiredAs a result is a common area of non-complianceduring external audits
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ISO 14001 Structure
Manage-
Environ-mentalPolicy
4.2
4.3
4.6
ISO 14001Overview
mentReview
Planning
Imple-mentation
& Operation
Checking& Corrective
Action
4.44.5
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ISO 14001 ELEMENTS
4.5 Checking
REQUIREMENTS
4.5.1 Monitoring & Measurement
4.5.2 Evaluation of Compliance
4.5.3 Nonconformity, Corrective Action & Preventative Action4.5.4 Control of Records
4.5.5 Internal Audit
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ISO 14001 ELEMENTS
4.3.3 Evaluating Compliance
Consistent with its commitment to compliance, theorganisation shall establish, implement and maintain aprocedure(s) for periodically evaluating compliancewith applicable legal requirements
The organisation shall evaluate compliance with otherrequirements to which it subscribes
The organisation shall keep records of the results ofperiodic evaluations
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Meaning of ‘Evaluating’
measure or estimate the nature, quality, ability,extent, or significance ofto draw conclusions from examining
To make a judgement based on criteria A systematic determination of significance ofsomething or someone using criteria against a set ofstandards
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Suggested Procedure for EvaluatingCompliance
1. Clearly identify legal and ‘other’ requirements
2. Relate requirements to processes and activities
3. Select competent person to carry out evaluation
4. Develop checklist or other approach5. Carry out evaluation
6. Assess extent to which the organisation meetsrequirements
7. Review and report to senior management
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Identification of Legal Requirements
Legislation, including Acts and Regulations
EU Regulations (which stay as EU wideRegulations)
EU Directives (may not yet enacted into UK Law)Permits, licenses or other authorisations
Orders issued by regulatorsPlanning permissions
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Examples of Permits
IPPC Permits
Part B Local Authority Permits
Surface Water Discharge Consents
Trade Effluent Discharge Consents
Consent to Discharge to Land
Abstraction LicencesPlanning Permissions
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Identification of ‘Other’ Requirements
Non-Regulatory Guidance
Voluntary Principals or Codes of Practice
Corporate Requirements
Contracts
Requirements of Trade Associations
Agreements with Non-governmental organisationsAgreements with general public
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Select Competent Person (s)
Ideally with expertise in all legislation that applies tothe organisationCompetence is based on training, qualifications and
Consider external assistance if organisation doesnot have necessary expertise in-house
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Establish Checklist
Base on existing Register of Legal & Other Requirements
(Clause 4.3.2)Commercially available checklists can be used but will needto be reviewed to include only those ‘applicable to
env ronmenta aspectsIdentify applicability of each piece of legislation (i.e. whichareas of the site are affected)
Identify what needs to be checked to evaluate compliance foreach piece of legislation
Consider what is already being done to assess compliance
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Examples of Ongoing ComplianceEvaluations
Routine ‘Day to Day’ monitoring
– Trade effluent monitoring and analysis data – Surface water monitoring and analysis data
Non-Routine Periodic Monitoring
– Stack monitoring – Asbestos surveys
Routine Inspections and checks
Internal audits – Against permits / consents – Against relevant procedures (pull out which requirements are legally
required to assist internal auditors)
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Example Checklist – Waste Documents
Duty of Care Transfer Notes?
Waste Carrier’s Licences?
Final Disposal Site Licences?
Hazardous Waste Registration?
Hazardous Waste Consignment Notes?
Quarterly Returns from Contractors?Packaging Certificate of Compliance?
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Interviews
Evidence
Verbal
Ph sical
Carry Out Evaluation
Observations
Records
Documentary
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Example Observations
Aboveground Storage Tanks
Underground Storage Tanks
Drum and Container Storage
Waste Segregation & Storage
Bunds & Impermeable Surfaces
Hazardous Materials StorageSpills / Staining
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Example Records
Leak Tests on Refrigeration Systems
Qualification of Refrigeration Contractors
Maintenance on Interceptors
Maintenance of Pollution Control EquipmentTank Integrity Tests
Testing results on Transformers for PCBs
Asbestos register and management plan
Spill records and response
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Assess Extent of Compliance
Review all findings
Categorise findings e.g.: – Major Regulatory (e.g. lack of permit or consent)
– . . – Observation (e.g. isolated weakness) – Best Management Finding (e.g. against ‘other
requirement’ or best practice)
Prioritisation of findings
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Reporting & Review
Document findings in a ‘stand-alone’ report (but can
reference routine monitoring or other audits)Prioritise findings so that its clear where the non-compliances exist and their significance
Include legal or best practice citation against each findingAddress findings through established non-conformanceprocess
Ensure corrective and preventative actions are identifiedTransfer longer terms actions onto ManagementProgrammes
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