August Mack News

The fourth phase in an environmental management system (EMS) is checking and corrective action. In this phase the following must be considered:

• Monitoring & Measurement
  • Procedure flow charts can be used to track EMS performance for consistency and frequency with established objective
    • Fact or Fluke? Who did what? Did it work? Why?
  • Is your EMS “auditable”? - Internal? 3rd party?
    • Does it conform to ISO 14001 standards; non-conformances mean mitigative actions
  • How will you keep records?
    • Paper or electronic?
    • How are official documents communicated/retired/filed, etc.?
    • Do employees have access to up-to-date forms?
    • Are page/table numbering procedures consistent?
• Nonconformance & Corrective & Preventative Action
  • Establish procedures for handling and investigating nonconformance, mitigating its impacts, and for taking corrective and preventive actions
    • “Nonconformance” is not conforming to the requirements of the EMS, including but not limited to noncompliance to regulatory requirements
  • Corrective and preventive actions should be appropriate to the problem and risk.
    • Leverage ISO 9000 corrective active process
    • Corrective actions initiated in response to a nonconformance during an internal EMS audit, should analyze problems and fix root cause
  • EMS documents are changed in response to corrective and preventive actions
• Records
  • Establish procedures to identify, maintain, and dispose of EMS records
    • Create a master list of EMS records showing data such as who is responsible for them, where they are kept, how long, etc.
    • Leverage ISO 9000 procedures where appropriate
  • Records should be legible, identifiable, traceable, and retrievable
  • Define retention times
• EMS Audit
  • Establish procedures to conduct EMS audits in order to:
    • Determine whether or not EMS conforms to planned arrangements and ISO 14001, and has been implemented effectively; and
    • Report results to management
  • Audit procedures should cover audit scope, frequency, and methodology, and who’s responsible for performing and reporting activities
  • Consider combined EMS/QMS audits
  • Consider frequent small-scope audits rather than annual or bi-annual full-scope audits
  • Base the audit program and schedule on the importance of the area being audited and the results of previous audits