Evaluating 20 Compliance

8/18/2019 Evaluating 20 Compliance

1/21

Evaluating Compliance

Dr Emma Goodchild

Manager, ENVIRON, Manchester


2/21

Agenda

Background

ISO 14001 Requirements

Meaning of ‘Evaluation’

Process for a Compliance Evaluation

Summary


3/21

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


4/21

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


5/21

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


6/21

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


7/21

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


8/21

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


9/21

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


10/21

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


11/21

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


12/21

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


13/21

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


14/21

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)


15/21

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?


16/21

Interviews

Evidence

Verbal

Ph sical

Carry Out Evaluation

Observations

Records

Documentary


17/21

Example Observations

Aboveground Storage Tanks

Underground Storage Tanks

Drum and Container Storage

Waste Segregation & Storage

Bunds & Impermeable Surfaces

Hazardous Materials StorageSpills / Staining


18/21

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


19/21

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


20/21

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


21/21