Overview of Management Systems Used By EHS Professionals

Overview of Management Systems For EHS Professionals

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ISO 45001 Safety Management Standard Draft Published

The International Organization for Standardization (ISO) has release a final draft of it proposed International Standard for Occupational Health and Safety Management Systems, designated ISO 45001. Publication of the final standard is likely to be in the first half of 2018.

The standard is being developed by a committee of occupational health and safety experts, and will follow other generic management system approaches such as ISO 14001 and ISO 9001. It will take into account other International Standards in this area such as OHSAS 18001, the International Labour Organization's ILO-OSH Guidelines, various national standards and the ILO's international labor standards and conventions.

For those organizations that have already developed safety and health programs under OHSAS 18001, the publication of ISO 45001 will be particularly significant. OHSAS 18001 will be withdrawn on publication of ISO 45001 and organizations currently certified to OHSAS 18001 will have a three year period to migrate to ISO 45001.

Click here for examples of Caltha projects related to management systems and specifically on health and safety.

ISO 14001 Cosultant In Minnesota

In September 2015, the revised ISO standard for Environmental Management Systems (EMS) was released, designated  ISO-14001:2015. The new ISO 14001:2015 is similar in many respects to the prior ISO 14001 standard, however it does make numerous changes which will require operations that currently meet the  ISO 14001:2004 to make important changes to how their programs are planned and implemented.. Organizations are granted a three-year transition period after the revision has been published to migrate their environmental management system to the new edition of the standard. After this transition period, companies that opt for third party certification will have to seek certification to the new version of the standard. The former version, ISO 14001:2004, and any certification to it, will be out of date.

Caltha LLP provides technical support to organizations seeking ISO 14001 certification or to upgrade their existing programs to meet the new requirements. Caltha also provides technical support to organizations wanting to improve their environmental and sustainability programs by implementing portions of the ISO standard, without aspiring to gain third party certification. Contact Caltha LLP for further information.

Click here to see examples of Caltha LLP ISO 14001 related projects.

Multimedia Compliance Audits, Management System Audits, EHS Audits

Brief project summaries for consulting work completed by Caltha LLP. Project summaries archived here include compliance audits, multimedia audits, regulatory program audits, including air rule audits, hazardous waste - RCRA audits, wastewater and stormwater discharge audits, TSCA audits, EHS audits, safety audits, product stewardship, product responsibility audits, energy audits, EMS audits, management system audits, audit training and others.


Click here to see a summary of projects completed by Caltha LLP related to compliance audits, multimedia audits, regulatory program audits, air rule audits, hazardous waste, RCRA audits, wastewater and stormwater discharge audits, TSCA audits, EHS audits, safety audits, product stewardship, product responsibility audits, energy audits, EMS audits, management system audits.

Caltha LLP provides specialized expertise to clients nationwide in the evaluation environmental rules, developing EHS compliance procedures, and preparing cost-effective EHS management programs. For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website

What Are Legal and Other Requirements Under ISO 14001?

One of the more challenging aspects of conforming to the ISO 14001 standard for Environmental Management Systems (EMS) is addressing “other requirements” The term “other requirements” is always associated with “legal requirements” within the standard and has the same obligations. An organization must identify its “other requirements” and periodically assess compliance.

Legal requirements are more easily understood by most organizations; these are identified in laws, rules, regulations, and in permits that the organization is subject to. However, “other requirements” are those obligations the organization has taken on that go beyond legal requirements. Some examples may be trade organization standards for responsible care of chemicals, agreements for labeling of products, or voluntary industry product stewardship programs.

It is important to recognize that under ISO 14001, once an organization makes a commitment to meet these types of requirements, they have the same importance as legal requirements under ISO 14001. This means that the organization must periodical assess its compliance (i.e, audit) with these other requirements.


Caltha LLP provides expert technical assistance to organizations wanting to become registered under ISO 14001 or to improve their EMS. For more information go to ISO 14001 and Environmental Management Systems Services website.

For further information contact Caltha LLP at info@calthacompany.com or Caltha LLP Website 

 

Environmental Management Systems Audit Compared To Regulatory Compliance Audits

Recently, there has been an increased interest in conducting “Systems Audits” especially within businesses or agencies already familiar with “Compliance Audits”. In this article, we will compare Systems Auditing to traditional Compliance Auditing.

Compliance auditing tends to be a straight-forward process. Objective evidence is collected to determine the status of compliance relative to specific requirements. Often these will be regulatory requirements, but compliance audits can be conducted relative to company or agency policies or procedures. To conduct a compliance audit, the auditor needs to know what the specific requirements are. Based on documentation review and observations made by the auditor, compliance with these requirements is evaluated.

Compliance auditing tends to develop a “snap-shot” of compliance on the day the audit was conducted. The purpose is to determine whether or not the auditee is in compliance, and not how compliance is attained.

Systems audits extend beyond strict compliance on the day of the audit. Although compliance with requirements is an important factor in a systems audit, providing an indication of system effectiveness, auditing the process leading to compliance is just as important.

For systems audits, the auditor needs to not only understand the specific compliance requirements, but also needs to understand the system the auditee uses to attain compliance. To pass a systems audit, the auditee must be in compliance with requirements and must demonstrate that an effective system is in place and being implemented to continuously be in compliance.

Systems audits will assess the compliance assurance system, and not simply assess the status of compliance on the day of the audit. Because a systems audit requires more intimate knowledge of the systems being used by the auditee, typically a systems auditor will request more information prior to the audit, including documents such as written plans and procedures, training requirements, etc. Often, systems audits will focus on specific areas, rather than being a site-wide assessment.

Systems audits offer a clear advantage beyond compliance audits – they address the underlying processes in place to assure on-going compliance. Systems audits also require a higher level of effort by the auditor and involve a broader range of personnel at a facility.

Caltha LLP provides specialized expertise to clients nationwide in the conducting compliance audits and environmental management systems audits, training internal auditors, and preparing cost-effective compliance management programs.

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

Regulatory Compliance and ISO 14001 - Are They Equivalent?

“A manufacturing facility has worked for nearly two years to develop programs and procedures to become ISO 14001 registered. At the end of a three-day registration audit they gain registration under ISO 14001 through a well respected third-party registrar.

The following month, the facility is subject to a routine compliance audit directed by its corporate EH&S Department. The audit identifies numerous deficiencies and findings in the facility’s compliance with environmental regulations.”

The obvious question asked by plant management is "does ISO 14001 registration have any relationship to compliance with environmental regulations"?

The answer is certainly yes, however it can not be assumed that simply because a facility is ISO 14001 registered it is also in compliance with applicable regulations.

In the example described above, the compliance audit is actually part of the environmental management system (EMS), not an independent measure of the effectiveness of the EMS. An ISO 14001 compliant EMS requires that the organization periodically assess its compliance with applicable regulations. The key measure of the effectiveness of the EMS is how the corrective actions are addressed once a compliance issue was identified, and were corrective actions effective.

If similar compliance issues continue to be identified during subsequent audits, there may be a breakdown of the EMS that needs to be addressed. However, the organization should not be surprised if compliance issues are identified during audits moving forward. Overall, by assessing compliance and responding appropriately, the organization will be on track to continuously improve of its EMS.

Caltha LLP provides expert technical assistance to organizations wanting to become registered under ISO 14001 or to improve their EMS. For more information go to ISO 14001 and Environmental Management Systems Services website.

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

Environmental Compliance Audits - Role in Environmental Due Diligence

"Should I include a compliance audit as part of my environmental due diligence?”
This question arises frequently during environmental due diligence for mergers and acquisitions. The answer is actually relevant to many types of transactions, whether a business is being acquired, or if “assets only” are being purchased.

Compliance with applicable regulations can have a significant financial impact on a business transaction; however, separating and focusing on key issues will reduce the level of effort required and eliminate spending time and resources collecting information that has very little impact on the transaction.

Many of the “best-in-class” companies conduct routine environmental compliance audits of their operations. The important point is that even the best run companies will find compliance issues at their facilities and will routinely be in corrective action to improve their operations and address any deficiencies. Often, these non-compliance issues are administrative, such as maintaining required documentation, or training-related. Once the deficiency is identified, it can be quickly remedied at little or no cost.

While considering using a formal Environmental Compliance Audit during due diligence, it should acknowledged that most audits will identify some areas of improvement within the organization. Given this, careful consideration should be given to how this information will be used in the due diligence effort. Given the time frame typically allowed for due diligence, it is often difficult to conduct a formal compliance audit. Beyond the time constraints, confidentially concerns may limit access to facility staff who would typically be an integral part of the audit process. And in the end, the the most important consideration will be whether or not the information gathered will be useful to business decisions regarding the transaction.

In many cases, a COMPLIANCE ASSESSMENT is more useful that a COMPLIANCE AUDIT. For more information:

Article comparing Environmental Compliance Assessments to Compliance Audits

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website

Environmental Management System Audits Compared to Compliance Audits

Recently, there has been an increased interest in conducting “Systems Audits” especially within businesses or agencies already familiar with “Compliance Audits”. In this article, we compare Systems Auditing to traditional Compliance Auditing.

Compliance auditing tends to be a straight-forward process. Objective evidence is collected to determine the status of compliance relative to specific requirements. Often these will be regulatory requirements, but compliance audits can be conducted relative to company or agency policies or procedures. To conduct a compliance audit, the auditor needs to know what the specific requirements are. Based on documentation review and observations made by the auditor, compliance with these requirements is evaluated.

Compliance auditing tends to develop a “snap-shot” of compliance on the day the audit was conducted. The important point is whether or not the auditee is in compliance, and not how compliance is attained.

Systems audits extend beyond strict compliance on the day of the audit. Although compliance with requirements is an important factor in a systems audit, providing an indication of system effectiveness, auditing the process leading to compliance is just as important.

For systems audits, the auditor needs to not only understand the specific compliance requirements, but also needs to understand the system the auditee uses to attain compliance. To pass a systems audit, the auditee must be in compliance with requirements and must demonstrate that an effective system is in place and being implemented to continuously be in compliance.

Systems audits will assess the compliance assurance system, and not simply assess the status of compliance on the day of the audit. Because a systems audit requires more intimate knowledge of the systems being used by the auditee, typically a systems auditor will request more information prior to the audit, including documents such as written plans and procedures, training requirements, etc. Often, systems audits will focus on specific areas, rather than being a site-wide assessment.

As an example, we will consider how a systems audit would address a specific compliance issue –proper labeling of drums in a hazardous waste storage area. In this case, drums of hazardous waste must be properly labeled; this is very straight forward for a compliance auditing process. The specific requirements for labeling are well documented and apply to all facilities that store hazardous waste. The auditor simply reviews the labeling documentation and determines if it meets these requirements.

Auditing the proper labeling of the hazardous waste drums with a systems auditing approach will require that the auditor understand the process the facility uses to assure that drums are properly labeled. While the requirements for labeling are generic and apply to all facilities that store hazardous waste, the system to assure proper labeling will be unique to each facility.

The compliance audit reviewed one type of document –the drum label –to determine compliance. The systems audit may review a broad range of documents related to the facility’s compliance system; for example,

• Internal checklists/blank label forms
• Written procedures
• Training requirements and training records
  

A systems auditor may also conduct interviews with key staff to assure they have been trained and understand the procedures they need to follow.

Systems audits offer a clear advantage beyond compliance audits – they address the underlying processes in place to assure on-going compliance. Systems audits also require a higher level of effort by the auditor and involve a broader range of personnel at a facility.

For further information contact Caltha LLP at
info@calthacompany.com
or
Caltha LLP Website