Excerpt from US TEAM GUIDE by LeeGreenwood

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									                                                         EMS Information/Checklist/Appendices
                                                           Excerpt from US TEAM GUIDE
                                                    SECTION 6 - OTHER ENVIRONMENTAL ISSUES
                                                                   December 2005



A. Applicability

This section addresses the following issues:
       1. the National Environmental Policy Act (NEPA) process
       2. environmental noise
       3. the Installation Restoration Program (IRP)
       4. pollution prevention
       5. program management
       6. waste military munitions.
       7. Environmental Management Systems (EMS)

The checklist for EMS primarily consists of management practices (MP). These MPs are drawn from ISO 14001, the Code of Environmental Management
Principles (CEMP) and guidance documents provided by the EPA. This checklist is also targeted at facility-level (i.e., installation, project, refuge, laboratory,
center, park) EMS, not at Departmental, Bureau, Agency, or Regional EMSs [Added July 2003].

Assessors are required to review state and local regulations and, if applicable, the appropriate Agency Supplement, to perform a comprehensive assessment.

B. Federal Regulations

EMS

EO 13148, Greening the Government through Leadership in Environmental Management. This EO, dated 21 April 2000, mandates that environmental
  management considerations must be a fundamental and integral component of Federal Government policies, operations, planning, and management. This order
  applies to Federal facilities in any State of the United States, the District of Columbia, the Commonwealth of Puerto Rico, Guam, American Samoa, the United
  States Virgin Islands, the Northern Mariana Islands, and any other territory or possession over which the United States has jurisdiction. Each agency with
  facilities outside of these areas, however, is encouraged to make best efforts to comply with the goals of this EO for those facilities [Added July 2003].

  The primary goals of this EO in the arena of environmental management systems are:
   1. By 21 October 2001, each agency will have conducted an agency-level environmental management system self assessment based6on the Code of
        Environmental Management Principles (CEMP) for Federal Agencies developed by the EPA (61 Fed. Reg. 54062) and/or another appropriate
        environmental management system framework. Each assessment should have included a review of agency environmental leadership goals, objectives,
        and targets. Where appropriate, the assessments may have been conducted at the service, bureau, or other comparable level.
   2. By 21 April 2002, each agency will have implemented environmental management systems through pilot projects at selected agency facilities based on
        the CEMP for Federal Agencies and/or another appropriate environmental management system framework (i.e., ISO 14001).

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    3.   By 31 December 2005, each agency shall implement an environmental management system at all appropriate agency facilities based on facility size,
         complexity, and the environmental aspects of facility operations. The facility environmental management system shall include measurable
         environmental goals, objectives, and targets that are reviewed and updated annually. Once established, environmental management system performance
         measures shall be incorporated in agency facility audit protocols.

  Except as otherwise required by applicable law, in the interest of national security, the head of any agency may request from the President an exemption from
  complying with the provisions of any or all provisions of this order for particular agency facilities, provided that the procedures set forth in section 120(j)(1) of
  the Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as amended (42 U.S.C. 9620(j)(1)), are followed, with the following
  exceptions:
    1. an exemption issued under this section will be for a specified period of time that may exceed 1 year;
    2. notice of any exemption granted under this section for provisions not otherwise required by law is only required to the Director of OMB, the Chair of
        the CEQ, and the Director of the National Security Council; and
    3. an exemption under this section may be issued due to lack of appropriations, provided that the head of the agency requesting the exemption shows that
        necessary funds were requested by the agency in its budget submission and agency plan under Executive Order 12088 of October 13, 1978, and were
        not contained in the President’s budget request or the Congress failed to make available the requested appropriation.

  To the maximum extent practicable, and without compromising national security, each agency shall strive to comply with the purposes, goals, and
  implementation steps in this EO. Nothing in this EO affects limitations on the dissemination of classified information pursuant to law, regulation, or Executive
  order.

  Nothing in this EO alters the obligations under EPCRA, Pollution Prevention Act (PPA), and Clean Air Act (CAA) independent of this EO for Government
  owned, contractor-operated facilities and Government corporations owning or operating facilities or subjects such facilities to EPCRA, PPA, or CAA if they
  are otherwise excluded. However, each agency shall include the releases and other waste management of chemicals for all such facilities to meet the agency’s
  reporting responsibilities.

International Organization for Standardization (ISO) 14001, Environmental Management Systems – Specification with Guidance for Use. This standard, revised
   15 November 2004, addresses the basic structures and systems needed for an effective environmental management systems. ISO 14001 is not a regulation, it
   provides guidance to any organization wishing to [Added April 2005]:
       1. establish, implement, maintain and improve an environmental management system,
       2. assure itself of conformity with its stated environmental policy,
       3. demonstrate conformity with this International Standard by
             a. making a self-determination and self-declaration of conformance, or
             b. seeking confirmation of its conformance by parties having an interest in the organization, such as
                 customers, or
             c. seeking confirmation of its self-declaration by a party external to the organization, or
             d. seeking certification/registration of its environmental management system by an external organization.

International Organization for Standardization (ISO) 14004, Environmental Management Systems — General Guidelines on Principles, Systems and Support
   Techniques. This standard, revised 15 November 2004, provides assistance to organizations that wish to implement or improve an environmental management
   system and thereby improve their environmental performance. This International Standard is consistent with the concept of sustainable development and
   compatible with diverse cultural, social and organizational frameworks and systems of management [Added April 2005].
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C. State/Local Regulations
No EMS Information

D. Key Compliance Requirements

EMS Audit – The checklist provided in topic heading O7: EMS is not meant to support a comprehensive audit of the extent to which an organization’s EMS
  actually functions. Rather, it is used as part of an environmental compliance audit to evaluate only whether or not the required elements of an EMS are
  present. Thus, in addition to the review conducted as part of an environmental compliance audit, conformance audits are still appropriate. The majority of
  Federal Agencies appear to be using ISO 14001 in the development of their EMSs; for that reason, ISO 14001 forms the basis of the checklist in this manual
  [Added July 2003].

  Agency/Component Supplements will provide critical information on how EMS is to be implemented, how it is to be incorporated into the culture of the
  organization, and what specific goals and objectives the organization must meet. The checklist items in under topic heading O7 in TEAM Guide are guidance
  to help in evaluating the process, but an EMS is actually evaluated in two ways:
          1. the system elements are checked against the chosen model to ensure that all the necessary pieces are present
          2. the site’s own EMS is audited against what it says it will do

  Unlike regulatory compliance audits, there are no specific requirements to be followed other than having the required elements of the EMS. In an EMS
  conformance audit, the scope, parameters, activities, and documentation to be reviewed are each a function of what the site said it would as part of its EMS.
  For example, an organization may use the checklist in this U.S. TEAM Guide to establish whether or not it has a procedure for external communication. But if
  that procedure says that the organization will meet with the town board monthly to discuss environmental issues, another checklist must be used to establish
  whether or not that is actually happening.

  Both auditors who are reviewing an EMS in the context of a regulatory compliance audit and auditors who are conducting EMS conformance audits must
  show restraint in how they comment and present valid findings. If a facility has a procedure for doing something, the organizations is doing what it says it will
  do, and that procedure appears to be working, then the facility is in conformance, whether or not the auditor happens to think that there is a better procedure.
  If asked, the auditor can provide additional information as an addition to the statement of fact that the site is in conformance with their chosen EMS model and
  site-specific EMS implementation requirements.

E. Key Compliance Definitions

       Appropriate Agency Facilities - in accordance with the EO, each agency should determine appropriateness based on the, "size, complexity, and the
        environmental aspects‖ of facility operations (EMS Primer for Federal Facilities, Definitions) [Added July 2003].

       Appropriate Facility - for the purposes of this EMS guidance, a "facility" that must have an EMS is any Federal property, properties, organization or
        operation that conducts activities that can have a significant impact on the environment, either directly or indirectly, individually or cumulatively, due to
        operations of that facility's mission, processes or functions (EMS Primer for Federal Facilities, Definitions) [Added July 2003].

       Auditor - person with the competence to conduct an audit (ISO 14001:2004, para 3.1) [Added April 2005].

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   Continual Improvement - recurring process of enhancing the environmental management system (3.8) in order to achieve improvements in overall
    environmental performance (3.10) consistent with the organization's environmental policy. NOTE: The process need not take place in all areas of
    activity simultaneously. (ISO 14001:2004, para 3.2) [Added April 2005].

   Continual Improvement: - Process of enhancing an organization/facility’s environmental performance through a recurring cycle of planning,
    implementing, reviewing and improving (EMS Primer for Federal Facilities, Definitions) [Added July 2003].

   Correction - action taken to eliminate a detected nonconformity (ISO 14004:2004, para 3.3) [Added April 2005].

   Corrective Action - action to eliminate the cause of a detected nonconformity (ISO 14001:2004, para 3.3) [Added April 2005].

   Document - information and its supporting medium. NOTE 1: The medium can be paper, magnetic, electronic or optical computer disc, photograph or
    master sample, or a combination thereof. NOTE 2 Adapted from ISO 9000:2000, 3.7.2 (ISO 14001:2004, para 3.4) [Added April 2005].

   Environmental Aspect - element of an organization's activities or products or services that can interact with the environment. NOTE A significant
    environmental aspect has or can have a significant environmental impact (ISO 14001:2004, para 3.6) [Added April 2005].

   Environmental Aspect - any activity or process of an organization’s/facility’s activities or mission that can interact with and impact the environment
    (EMS Primer for Federal Facilities, Definitions) [Added July 2003].

   Environmental Aspects - the elements of an organization’s activities, products, or services that can interact with the environment (EO 13148, Section
    1009) [Added July 2003].

   Environmental Impact - Any change (complete or partial) to the environment, whether adverse or beneficial, resulting from an organization’s/facility’s
    functional mission or activities (EMS Primer for Federal Facilities, Definitions) [Added July 2003].

   Environmental Impact - any change to the environment (3.5), whether adverse or beneficial, wholly or partially resulting from an organization's
    environmental aspects (ISO 14001:2004, para 3.7) [Added April 2005].

   Environmental Management System (EMS) - part of an organization's management system used to develop and implement its environmental policy and
    manage its environmental aspects. NOTE 1: A management system is a set of interrelated elements used to establish policy and objectives and to achieve those
    objectives. NOTE 2 A management system includes organizational structure, planning activities, responsibilities, practices, procedures, processes and resources (ISO
    14001:2004, para 3.8) [Added April 2005].

   Environmental Management System (EMS) - that component of any organization’s (agency, service, bureau, mode, district, region, facility, unit,
    installation, etc) overall management systems that takes into account Organizational Structure, Planning, Activities, Procedures, Processes, and
    Resources for developing, implementing, achieving, reviewing, and maintaining their environmental programs and policy. An EMS (EMS Primer for
    Federal Facilities, Definitions) [Added July 2003]:
         1. Serves as a tool for improving overall performance, both environmental and agency mission;

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        2.   Integrates responsibilities and practices into an overall management system to increase efficiency and reduce environmental impacts.
        3.   Provides a systematic way of managing an organization’s environmental affairs by,
        4.   Identifying and addressing immediate, cumulative and long-term impacts of its missions, services and processes on the environment,
        5.   Providing order and consistency to address environmental concerns through the allocation of resources, assignment of responsibility and
             ongoing evaluation of practices procedures and processes; and
        6.   Relies on the concept of continual improvement for success.

   Environmental Objective - overall environmental goal, consistent with the environmental policy, that an organization sets itself to achieve (ISO
    14001:2004, para 3.9) [Added April 2005].

   Environmental Performance - measurable results of an organization's management of its environmental aspects. NOTE: In the context of environmental
    management systems, results can be measured against the organization's environmental policy, environmental objectives, environmental targets and
    other environmental performance requirements (ISO 14001:2004, para 3.10) [Added April 2005].

   Environmental Performance Indicator (EPI) - specific expression that provides information about an organization's environmental performance (ISO
    14004:2004, para 3.3) [Added April 2005].

   Environmental Policy - A statement by the organization and/or facility of its intent to take environmental concerns into account and present proof of Top
    Management’s Commitment to this cause (EMS Primer for Federal Facilities, Definitions) [Added July 2003].

   Environmental Policy - overall intentions and direction of an organization related to its environmental performance as formally expressed by top
    management. NOTE: The environmental policy provides a framework for action and for the setting of environmental objectives and environmental targets (ISO
    14001:2004, para 3.11) [Added April 2005].

   Environmental Target - detailed performance requirement, applicable to the organization or parts thereof, that arises from the environmental objectives
    and that needs to be set and met in order to achieve those objectives (ISO 14001:2004, para 3.12) [Added April 2005].

   Facility - any building, installation, structure, land, and other property owned or operated by, or constructed or manufactured and leased to, the Federal
    Government, where the Federal Government is formally accountable for compliance under environmental regulation (e.g., permits, reports/records
    and/or planning requirements) with requirements pertaining to discharge, emission, release, spill, or management of any waste, contaminant, hazardous
    chemical, or pollutant. This term includes a group of facilities at a single location managed as an integrated operation, as well as government owned
    contractor operated facilities (EO 13148, Section 1004) [Added July 2003].

   ISO - the International Organization for Standardization, a network of national standards institutes from 145 countries working in partnership with
    international organizations, governments, industries, business, and consumer representatives (7 CFR 2902.2) [Added April 2005].

   Interested Party - person or group concerned with or affected by the environmental performance of an organization (ISO 14001:2004, para 3.13)
    [Added April 2005].




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   Internal Audit - systematic, independent and documented process for obtaining audit evidence and evaluating it objectively to determine the extent to
    which the environmental management system audit criteria set by the organization are fulfilled. NOTE In many cases, particularly in smaller organizations,
    independence can be demonstrated by the freedom from responsibility for the activity being audited (ISO 14001:2004, para 3.14) [Added April 2005].

   Management Performance Indicator (MPI) - environmental performance indicator that provides information about the management efforts to influence
    an organization's environmental performance (ISO 14004:2004, para 3.3) [Added April 2005].

   Nonconformity - non-fulfillment of a requirement (ISO 14001:2004, para 3.15) [Added April 2005].

   Operational Performance Indicator (OPI) - environmental performance indicator that provides information about the environmental performance of an
    organization's operations (ISO 14004:2004, para 3.3) [Added April 2005].

   Organization - company, corporation, firm, enterprise, authority or institution, or part or combination thereof, whether incorporated or not, public or
    private, that has its own functions and administration. NOTE For organizations with more than one operating unit, a single operating unit may be defined as an
    organization (ISO 14001:2004, para 3.16) [Added April 2005].

   Organization – For the purposes of this guidance an organization is any Federal Agency, Service, Department, region, office, division, bureau or other
    sub-unit, with overall policy and budget authority. Similar type facilities or programs can be grouped as an organization and covered by an
    organizational EMS (EMS Primer for Federal Facilities, Definitions) [Added July 2003].

   Pollution Prevention – “source reduction,” as defined in the Pollution Prevention Act (PPA), and other practices that reduce or eliminate the creation of
    pollutants through (EO 13148, Sec. 1007) [Added July 2000]:
   increased efficiency in the use of raw materials, energy, water, or other resources; or
   protection of natural resources by conservation.

   Preventive Action - action to eliminate the cause of a potential nonconformity (ISO 14001:2004, para 3.17) [Added April 2005].

   Prevention of Pollution - use of processes, practices, techniques, materials, products, services or energy to avoid, reduce or control (separately or in
    combination) the creation, emission or discharge of any type of pollutant or waste, in order to reduce adverse environmental impacts. NOTE Prevention
    of pollution can include source reduction or elimination, process, product or service changes, efficient use of resources, material and energy substitution, reuse, recovery,
    recycling, reclamation and treatment (ISO 14001:2004, para 3.18) [Added April 2005].

   Procedure - specified way to carry out an activity or a process. NOTE 1 Procedures can be documented or not (ISO 14001:2004, para 3.19) [Added
    April 2005].

   Record - document stating results achieved or providing evidence of activities performed (ISO 14001:2004, para 3.20) [Added April 2005].

   Self Declaration – Self declaration occurs when a facility or organization affirms that it is in conformance with the defined elements of a facility or
    program EMS; the declaration may reflect a formal internal or external audit of the facility or organization EMS against an accepted EMS framework.
    (EMS Primer for Federal Facilities, Definitions) [Added July 2003].

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F. Records To Review
No EMS Information

G. Physical Features To Inspect
No EMS Information

H. Guidance for Other Environmental Issues Checklist Users

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                    EMS

                    O7.1
                    All Facilities

                    O7.1.1.US. The current status      Determine if noncompliance issues have been resolved by reviewing a copy of the
                    of any ongoing or unresolved       previous report, consent orders, compliance agreements, NOVs, interagency
                    consent orders, compliance         agreements, programmatic agreements executed with the SHPO, NEPA
                    agreements,      notices     of    documents with specific mitigation requirements, management plans, litigation
                    violation (NOVs), interagency      settlement agreements, court imposed injunctions, or equivalent state enforcement
                    agreements, or equivalent          actions.
                    state enforcement actions is
                    required to be examined (a
                    finding under this checklist
                    item      will    have      the
                    enforcement             action/
                    identifying information as the
                    citation) [Added July 2003].

                    O7.1.2.US.        As of 31         (NOTE: The determination of whether or not a federal facility needs an EMS is
                    December       2005      certain   based on facility size, complexity, and the environmental aspects of facility
                    Federal facilities are required    operations.)
                    to    have       environmental
                    management system (EMS)            Verify that a federal facility has an EMS that includes measurable environmental
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that    include     measurable     goals, objectives, and targets.
environmental             goals,
objectives, and targets that are   Verify that the measurable environmental goals, objectives, and targets are
reviewed      and      updated     reviewed and updated annually.
annually (EO 13148, Section
401(b)) [Added July 2003].         Verify that, as goals, objectives, and targets are met, new goals, objectives and
                                   targets are developed.

                                   (NOTE: See Appendix 6-4 for an example of EMS and Appendix 6-5 for USEPA
                                   position statement on EMS.)

O7.1.3.US. Federal facilities      Verify that federal facilities have developed a written plan that sets forth the
are required to develop a          facility’s contribution to the goals and requirements established in EO 13148.
written plan that sets forth the
facility’s contribution to the     (NOTE: EO 13148 covers:
goals     and     requirements          development and implementation of environmental management systems
established in EO 13148 (EO                  (EMS) (if the agency finds that the facility is “appropriate” for an
13148,      Section     305(b))              EMS)
[Added July 2003].                      establishing and implementing environmental compliance audit programs
                                             and policies that emphasize pollution prevention as a means to both
                                             achieve and maintain environmental compliance
                                        timely planning and reporting under EPCRA (when applicable)
                                        reduction of reported Toxic Release Inventory (TRI) releases and off-site
                                             transfers of toxic chemicals for treatment and disposal
                                        reduction of use of selected toxic chemicals, hazardous substances, and
                                             pollutants, or its generation of hazardous and radioactive waste types
                                        phasing out the procurement of Class I ozone-depleting substances for all
                                             nonexcepted uses
                                        promoting the sustainable management of Federal facility lands through
                                             the implementation of cost-effective, environmentally sound
                                             landscaping practices, and programs to reduce adverse impacts to the
                                             natural environment.)

                                   (NOTE: ―Facility‖ means any building, installation, structure, land, and other
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                               property owned or operated by, or constructed or manufactured and leased to, the
                               Federal Government, where the Federal Government is formally accountable for
                               compliance under environmental regulation (e.g., permits, reports/records and/or
                               planning requirements) with requirements pertaining to discharge, emission,
                               release, spill, or management of any waste, contaminant, hazardous chemical, or
                               pollutant. This term includes a group of facilities at a single location managed as
                               an integrated operation, as well as government owned contractor operated
                               facilities (EO 13148, Sec. 1004).)

                               Verify that the plan reflects the size and complexity of the facility.

                               (NOTE: Where pollution prevention plans or other formal environmental
                               planning instruments have been prepared for facilities, an agency may elect to
                               update those plans to meet the requirements and goals of this checklist item.)




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EMS

O7.2
Missing, Risk Management,
and Positive Checklist Items

O7.2.1.US.    Facilities are   Determine if any new regulations concerning EMS have been issued since the
required to comply with all

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applicable Federal regulatory     finalization of the manual.
requirements not contained in
this checklist (a finding under   Determine if the facility has activities or facilities that are regulated but not
this checklist item will have     addressed in this checklist.
the citation of the applied
regulation as a basis of          Verify that the facility is in compliance with all applicable and newly issued
finding) [Added July 2003].       regulations.

O7.2.2.US.             Risk       Determine if risk management techniques are promoted in environmental efforts.
management       techniques
should be promoted in
environmental efforts (MP)
[Added July 2003].

O7.2.3.US. Facilities should      Determine if the facility has gone above and beyond simply complying with
go above and beyond               environmental requirements.
statutory   and   regulatory
compliance (MP) [Added
July 2003].



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EMS

O7.10
Policy


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O7.10.1.US. Federal facility    (NOTE: This checklist item is drawn from ISO 14001:2004, para 4.2a through
EMS should have a policy       4.2e, Appendix A, para. A2; and ISO 14004:2004, para 4.1.3 and 4.2.)
statement endorsed by top
management (MP) [Added         Verify that the policy statement:
July 2003, Revised April
2005].                                is appropriate to the nature, scale and environmental impacts of the federal
                                           facility’s activities, products and services
                                      includes a commitment to continual improvement and prevention of
                                           pollution
                                      includes a commitment to comply with applicable legal requirements and
                                           with other requirements to which the facility subscribes which relate to
                                           its environmental aspects
                                      includes a commitment to set an example in the field of environmental
                                           management
                                      provides the framework for setting and reviewing environmental objectives
                                           and targets
                                      is documented, implemented and maintained
                                      is available to the public.

                               Verify that, where possible, the policy statement is tied to the facility’s
                               Agency/Departmental/Bureau mission and priorities.

                               Verify that, in the process of developing its environmental policy, a facility
                               considers the following:

                                      its mission, vision, core values and beliefs
                                      coordination with other facility policies (e.g. quality, occupational health
                                           and safety)
                                      the requirements of, and communication with, interested parties
                                      guiding principles
                                      specific local or regional conditions
                                      its commitments to prevention of pollution and continual improvement
                                      its commitment to comply with legal requirements and other requirements
                                           to which the facility subscribes.
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                Verify that top management has endorsed the policy statement.

                Verify that the environmental policy recognizes that all activities, products and
                services within the defined scope of a facility’s EMS can cause impacts on the
                environment.

                (NOTE:       Endorsement may take a variety of forms depending on the
                facility/organizations culture and structure.

                (NOTE: Interview personnel who are familiar with the policy development
                process. The following questions will assist in verifying conformance to this
                requirement.
                       What is top management’s definition of the organization’s environmental
                            policy?
                       How does top management ensure that its policy is appropriate to the
                            nature, scale, and environmental impacts of its activities, products, or
                            services?
                       How does the policy guide the organization towards appropriate
                            technologies and management practices?
                       Is the policy consistent with other organizational policies? If so, how?
                       How does the policy guide the setting of environmental objectives and
                            targets?
                   How does the policy guide the organization in reviewing and adjusting its
                      environmental objectives and targets?)

                (NOTE: The environmental policy is the driver for implementing and improving
                an organization's EMS so that it can maintain and potentially improve its
                environmental performance. Therefore, this policy should reflect the commitment
                of top management to comply with applicable legal requirements and other
                requirements, to prevent pollution and to continually improve. The environmental
                policy forms the basis upon which the organization sets its objectives and targets.
                The environmental policy should be sufficiently clear to be able to be understood
                by internal and external interested parties, and should be periodically reviewed
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                                 and revised to reflect changing conditions and information.)

                                 (NOTE: The area of application (i.e. scope) of the policy should be clearly
                                 identifiable and should reflect the unique nature, scale and environmental impacts
                                 of the activities, products and services within the defined scope of the EMS. The
                                 ―scope‖ also includes the boundaries of the organization to which the EMS
                                 applies. Once the scope of the environmental management system has been
                                 defined, all activities, products and services of the organization that are within the
                                 defined scope should be included in the EMS.)

                                 (NOTE: Top management usually consists of a person or group of people who
                                 direct and control an organization at the highest level.)

                                 (NOTE: Both auditors who are reviewing an EMS in the context of a regulatory
                                 compliance audit and auditors who are conducting EMS conformance audits must
                                 show restraint in how they comment and present valid findings. If a facility has a
                                 procedure for doing something, the organizations is doing what it says it will do,
                                 and that procedure appears to be working, then the facility is in conformance,
                                 whether or not the auditor happens to think that there is a better procedure. If
                                 asked, the auditor can provide additional information as an addition to the
                                 statement of fact that the site is in conformance with their chosen EMS model and
                                 site-specific EMS implementation requirements.)

O7.10.2.US.       EMS policy     (NOTE: This checklist item is drawn from ISO 14001:2004, para 4.2f, 4.2g, and
should be communicated to        Appendix A, para A2.)
all persons working for or on
behalf of the facility as well   Verify that the EMS policy is communicated to all persons working for or on
as to the public (MP) [Added     behalf of the facility.
July 2003, Revised April
2005].                           Verify that the EMS policy is communicated to the public.

                                 Verify that, if appropriate, the EMS policy is communicated to external entities
                                 and individuals.

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                (NOTE: The following questions will assist in verifying conformance to this
                requirement.
                       What are the procedures to check if the environmental policy is understood
                          and practiced?)

                (NOTE: Interview personnel in various management levels at the facility. The
                following questions will assist in verifying conformance to this requirement.
                       Are you familiar with the policy?
                       Are you familiar with the EMS program?)

                (NOTE: The environmental policy should be communicated to all persons who
                work for, or on behalf of, the organization, including contractors working at an
                organization's facility. Communication to contractors can be in alternative forms
                to the policy statement itself, such as rules, directives and procedures, and may
                therefore only include pertinent sections of the policy. The facility’s
                environmental policy should be defined and documented by its top management
                within the context of the environmental policy of any broader corporate body of
                which it is a part, and with the endorsement of that body. Top management usually
                consists of a person or group of people who direct and control an organization at the
                highest level.)

                (NOTE: Both auditors who are reviewing an EMS in the context of a regulatory
                compliance audit and auditors who are conducting EMS conformance audits must
                show restraint in how they comment and present valid findings. If a facility has a
                procedure for doing something, the organizations is doing what it says it will do,
                and that procedure appears to be working, then the facility is in conformance,
                whether or not the auditor happens to think that there is a better procedure. If
                asked, the auditor can provide additional information as an addition to the
                statement of fact that the site is in conformance with their chosen EMS model and
                site-specific EMS implementation requirements.)




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EMS

O7.20
Planning

O7.20.1.US.            Federal   (NOTE: This checklist item is drawn from ISO 14001:2004, para 4.3.1 and ISP
facilities should develop and    14004:2004, para 4.3.1.)
implement a procedure to
identify         environmental   Verify that the facility has established, implemented and maintains a procedure(s):
aspects and their impacts
(MP) [Added July 2003,                  to identify the environmental aspects of its activities, products, and
Revised April 2005].                        services within the defined scope of the EMS that it can control, and
                                            those that it can influence taking into account planned or new
                                            developments, or new or modified activities, products and services
                                        to determine those aspects that have or can have significant impact(s) on
                                            the environment (i.e. significant environmental aspects).

                                 (NOTE: For example, if a facility washes vehicles/heavy equipment onsite, there
                                 is a potential to impact groundwater or surface water with oily residues from the
                                 vehicle or heavy equipment.)

                                 Verify that the facility documents the environmental aspects and those which are
                                 significant environmental aspects.

                                 (NOTE: See Appendix 6-6 for additional guidance on the identification of aspects
                                 and impacts.)

                                 Verify that the significant environmental aspects are taken into account in
                                 establishing, implementing and maintaining the EMS.

                                 (NOTE: An facility’s policy, objectives and targets, training, communications,
                                 operational controls and monitoring programs should be primarily based on
                                 knowledge of its significant environmental aspects, although issues such as
                                 applicable legal requirements and other requirements to which the organization
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                subscribes and the views of interested parties will also need to be taken into
                account.)

                (NOTE: The identification of significant environmental aspects is an ongoing
                process that enhances an organization's understanding of its relationship to the
                environment and contributes to continual improvement of its environmental
                performance through enhancement of its EMS.)

                (NOTE: There is no single approach for identifying environmental aspects and
                environmental impacts and determining significance that will suit all
                facilities/organizations.)

                Verify that new or recently changed products, activities, or services are adequately
                addressed in the most recent list of aspects and impacts.

                (NOTE: The following questions will assist in verifying conformance to this
                requirement.
                       What is the procedure to identify significant environmental aspects?
                       How is it maintained?
                       What are the environmental aspects of the organization’s activities,
                            products, and services?
                       Is there an assignment of responsibility for periodic review and application
                            of the procedure? If so, who is assigned this responsibility?
                       How does the procedure enable the organization to determine which
                            environmental aspects have or could have significant impacts on the
                            environment?
                       How do you identify all aspects of your activities, products, and services?
                       How does the organization consider its environmental aspects when setting
                            its objectives?
                       How does the organization consider normal operating conditions, shut
                            down and start up conditions, and the realistic significant impacts
                            associated with potential or emergency situations?
                       How are input materials considered?
                       How are proper use and disposal issues considered?
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                                        What procedures are used to keep this information up-to-date?
                                        How will any intended changes or additions to activities, products, or
                                           services affect the environmental aspects and their associated
                                           impacts?)

                                 (NOTE: Interview personnel in various management levels at the facility. The
                                 following questions will assist in verifying conformance to this requirement.
                                        What are the significant aspects and impacts associated with your
                                            function?
                                        How do you know what to do? (Ask for procedures and operating criteria).
                                        What specific training have you received?
                                        Are there any objectives and targets associated with your function?
                                        Are you responsible for any monitoring and measurement activities?
                                        What records do you keep?)

                                 (NOTE: Both auditors who are reviewing an EMS in the context of a regulatory
                                 compliance audit and auditors who are conducting EMS conformance audits must
                                 show restraint in how they comment and present valid findings. If a facility has a
                                 procedure for doing something, the organizations is doing what it says it will do,
                                 and that procedure appears to be working, then the facility is in conformance,
                                 whether or not the auditor happens to think that there is a better procedure. If
                                 asked, the auditor can provide additional information as an addition to the
                                 statement of fact that the site is in conformance with their chosen EMS model and
                                 site-specific EMS implementation requirements.)

O7.20.2.US.               The    (NOTE: This checklist item is drawn from ISO 14001:2004, para 4.3.2, Appendix
development       of     EMS     A, para. A.3.2 and ISO 14004:2004, para 4.3.2)
environmental objectives and
targets should include the       (NOTE: This may be done through an Agency/Bureau/Departmental auditing
consideration of regulatory      program and interaction with state and federal compliance assistance
requirements applicable to the   organizations.)
federal facility (MP) [Added
July 2003, Revised April         Verify that the facility has established, implemented, and maintains a procedure(s)
                                 to:
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2005].
                           identify and have access to the applicable legal requirements and other
                               requirements applicable to the facility and related to its environmental
                               aspects
                           determine how the applicable requirements apply to its environmental
                               aspects.

                    Verify that the facility ensures that the applicable legal requirements and other
                    requirements to which the organization subscribes are taken into account in
                    establishing, implementing and maintaining its EMS.

                    (NOTE: See Appendix 6-7 for examples of activities, products and services and
                    their associated environmental aspects, objectives, targets, programs, indicators,
                    operational control, and monitoring and measurement.)

                    (NOTE: Examples of other requirements to which the organization may subscribe
                    include, if applicable,
                           agreements with public authorities,
                           agreements with customers,
                           non-regulatory guidelines,
                           voluntary principles or codes of practice,
                           voluntary environmental labeling or product stewardship commitments,
                           requirements of trade associations,
                           agreements with community groups or non-governmental organizations,
                           public commitments of the organization or its parent organization,
                           corporate/company requirements.
                    The determination of how legal and other requirements apply to an organization's
                    environmental aspects is usually accomplished in the process of identifying these
                    requirements. It may not be necessary, therefore, to have a separate or additional
                    procedure in order to make this determination.)

                    (NOTE: Information on internal performance criteria, together with applicable
                    legal requirements and other requirements to which the organization subscribes,
                    can assist an organization in developing its objectives and targets. Where legal
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                                and other requirements do not exist or are insufficient to meet the organization's
                                needs, an organization may develop and implement internal performance criteria
                                to meet its needs. Examples of internal performance criteria might include
                                limitations on types and quantities of fuels or hazardous substances that can be
                                used or managed at a facility or limitations on air emissions that go beyond legal
                                compliance requirements.)

                                (NOTE: Both auditors who are reviewing an EMS in the context of a regulatory
                                compliance audit and auditors who are conducting EMS conformance audits must
                                show restraint in how they comment and present valid findings. If a facility has a
                                procedure for doing something, the organizations is doing what it says it will do,
                                and that procedure appears to be working, then the facility is in conformance,
                                whether or not the auditor happens to think that there is a better procedure. If
                                asked, the auditor can provide additional information as an addition to the
                                statement of fact that the site is in conformance with their chosen EMS model and
                                site-specific EMS implementation requirements.)

O7.20.3.US. EMS Planning        (NOTE: This checklist item is drawn from ISO 14001:2004, para 4.3.3, Appendix
should      include       the   A, para A3.3, and ISO 14004:2004, para 4.3.3)
development                of
environmental objectives and    Verify that environmental planning includes the identification of environmental
targets (MP) [Added July        objectives and targets.
2003, Revised April 2005].
                                Verify that the facility has established, implemented, and maintains documented
                                environmental objectives and targets, at relevant functions and levels within the
                                facility.

                                Verify that, when setting objectives and targets, the facility/organization
                                considered several inputs, including:

                                       principles and commitments in its environmental policy
                                       its significant environmental aspects (and information developed in
                                           determining them)
                                       applicable legal requirements and other requirements to which the
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                            organization subscribes
                       effects of achieving objectives on other activities and processes
                       views of interested parties
                       technological options and feasibility
                       financial, operational, and organizational considerations, including
                            information from suppliers and contractors
                       possible effects on the public image of the organization
                       findings from environmental reviews
                       other organizational goals.

                Verify that the objectives and targets are specific and measurable.

                Verify that objectives and targets cover and short- and long-term issues.

                Verify that objectives were set at the top level of the facility and at other levels
                and functions where activities important to meeting the environmental policy
                commitments and overall organizational goals are carried out.

                (NOTE: An objective can be expressed directly as a specific performance level,
                or may be expressed in a general manner and further defined by one or more
                targets. When targets are set, they should be measurable by performance levels
                that need to be met to ensure the achievement of the related objectives. Targets
                may need to include a specified time frame to be delivered by the program.)

                Verify that objectives describe the organization's goals for environmental
                performance.

                (NOTE: Depending on the complexity of the facility, separate targets and
                objectives may be appropriate at varying management and operational levels of
                the facility.)

                (NOTE: When establishing and reviewing its objectives and targets, a facility
                shall take into account the legal requirements and other requirements to which the
                organization subscribes, and its significant environmental aspects. It shall also
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                consider its technological options, its financial, operational and business
                requirements, and the views of interested parties.)

                Verify that, where practicable, the objectives and targets are consistent with:

                       environmental policy
                       commitments to pollution prevention
                       compliance with applicable legal requirements
                       compliance with other applicable requirements.

                Verify that the objectives and targets incorporate continual improvement.

                Verify that part of the planning process includes the elaboration of a program
                addressing the following items for achieving the facility’s environmental
                objectives and targets:

                       roles
                       responsibilities
                       processes
                       resources
                       timeframes
                       priorities
                       the actions necessary for achieving the environmental objectives and
                            targets.

                Verify that a facility establishes objective, verifiable, measurable, and
                reproducible environmental performance indicators.

                (NOTE: See ISO 14031 and ISO/TR 14032 for further guidance on the selection
                and use of environmental performance indicators.)

                (NOTE: Progress towards an objective can generally be measured using
                environmental performance indicators such as:
                       quantity of raw material or energy used
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                       quantity of emissions such as CO2
                       waste produced per quantity of finished product
                       efficiency of material and energy used
                       number of environmental incidents (e.g. excursions above limits)
                       number of environmental accidents (e.g. unplanned releases)
                       percentage waste recycled
                       percentage recycled material used in packaging
                       number of service vehicle kilometers per unit of production
                       quantities of specific pollutants emitted, e.g. NOx, SO2, CO, VOCs, Pb,
                            CFCs
                       investment in environmental protection
                       number of prosecutions
                       land area set aside for wildlife habitat.)

                Verify that the metrics used to measure target attainment are valid.

                (NOTE: When considering its technological options, a facility should consider
                the use of best-available techniques where economically viable, cost-effective and
                judged appropriate. The creation and use of one or more programs is important to
                the successful implementation of an EMS. Each program should describe how the
                organization's objectives and targets will be achieved, including timescales,
                necessary resources and personnel responsible for implementing the program.
                These) programs may be subdivided to address specific elements of the
                organization's operations. The program should include, where appropriate and
                practical, consideration of planning, design, production, marketing and disposal
                stages. This may be undertaken for either current and new activities, products or
                services. For products, this can address design, materials, production processes,
                use and ultimate disposal. For installations or significant modifications of
                processes, this can address planning, design, construction, commissioning,
                operation and, at the appropriate time determined by the organization,
                decommissioning.)

                (NOTE: The following questions will assist in verifying conformance to this

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                                 requirement.
                                        How are the aspects of contractor and supplier activities considered when
                                           setting objectives?
                                        What are the significant impacts and how are they used in establishing
                                           environmental goals?
                                        What is the process for balancing and resolving conflicts between
                                           environmental and other business objectives and priorities?
                                        How do you consider your technological options when establishing and
                                           reviewing the objectives and targets?
                                        How do you prepare cost-benefit analyses? Where are these documented?
                                        How do the employees responsible for achieving the objectives and targets
                                           provide input into their development?)

                                 (NOTE: Both auditors who are reviewing an EMS in the context of a regulatory
                                 compliance audit and auditors who are conducting EMS conformance audits must
                                 show restraint in how they comment and present valid findings. If a facility has a
                                 procedure for doing something, the organizations is doing what it says it will do,
                                 and that procedure appears to be working, then the facility is in conformance,
                                 whether or not the auditor happens to think that there is a better procedure. If
                                 asked, the auditor can provide additional information as an addition to the
                                 statement of fact that the site is in conformance with their chosen EMS model and
                                 site-specific EMS implementation requirements.)

O7.20.4.US. EMS Planning         (NOTE: This checklist item is drawn from ISO 14001:2004, para 4.3.3 and ISO
should         include     the   14004:2004, para 4.3.3.1.)
identification              of
environmental responsibilities   Verify that, as a part of objectives and targets development, the facility
organization/facility-wide       establishes, implements and maintains a program(s) for achieving its objectives
(MP) [Added July 2003,           and targets, including:
Revised April 2005].
                                        designation of responsibility for achieving objectives and targets at
                                            relevant functions and levels of the organization, and
                                        the means and time-frame by which they are to be achieved.

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                              Verify that environmental responsibilities are documented in job descriptions.

                              Verify that environmental roles and responsibilities are not confined to the
                              environmental management function,

                              Verify that a facility identifies the contributions of different levels and functions
                              of the facility in achieving the objectives, and makes the individual members of
                              the facility aware of their responsibilities.

                              (NOTE: The following questions will assist in verifying conformance to this
                              requirement.
                                     What is the facilities procedure for defining and documenting roles,
                                        responsibilities, and authorities throughout the organization?
                                     How are the roles, responsibilities, and authorities communicated to
                                        facilitate effective environmental management?
                                     How are participants made aware of their roles and responsibilities within
                                        the EMS?)

                              (NOTE: Both auditors who are reviewing an EMS in the context of a regulatory
                              compliance audit and auditors who are conducting EMS conformance audits must
                              show restraint in how they comment and present valid findings. If a facility has a
                              procedure for doing something, the organizations is doing what it says it will do,
                              and that procedure appears to be working, then the facility is in conformance,
                              whether or not the auditor happens to think that there is a better procedure. If
                              asked, the auditor can provide additional information as an addition to the
                              statement of fact that the site is in conformance with their chosen EMS model and
                              site-specific EMS implementation requirements.)

O7.20.5.US. EMS planning      (NOTE: This checklist item is drawn from ISO 14001:2004, Appendix A and ISO
should include a comparison   14004:2004, para 4.1.4.)
of existing programs to an
accepted EMS framework        Verify that EMS planning includes a comparison to an accepted EMS framework
(MP) [Added July 2003,        (i.e., a gap analysis).

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Revised April 2005].   (NOTE: Appendix A of ISO 14001:2004 indicates that an organization with no
                       existing EMS should, initially, establish its current position with regard to the
                       environment by means of a review. The aim of this review is to consider all
                       environmental aspects of the organization as a basis for establishing the EMS.)

                       Verify that the comparison/review covers the following four key areas:

                              identification of environmental aspects, including those associated with
                                  normal operating conditions, abnormal conditions including start-up
                                  and shut-down, and emergency situations and accidents
                              identification of applicable legal requirements and other requirements to
                                  which the organization subscribes
                              examination of existing environmental management practices and
                                  procedures, including those associated with procurement and
                                  contracting activities
                              evaluation of previous emergency situations and accidents.)

                       (NOTE: The review can also include additional considerations, such as:
                            an evaluation of performance compared with applicable internal criteria,
                                 external standards, regulations, codes of practice and sets of principles
                                 and guidelines
                            opportunities for competitive advantage, including cost reduction
                                 opportunities
                             the views of interested parties
                            other organizational systems that can enable or impede environmental
                                 performance.)

                       (NOTE:     Methods that can be used to examine existing environmental
                       management practices and procedures include:
                             interviews with persons previously or currently working for or on behalf of
                                  the organization to determine the scope of the organization's past and
                                  current activities, products and services
                             evaluation of internal and external communications that have taken place
                                  with the organization's interested parties, including complaints,
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                             matters related to applicable legal requirements or other requirements
                             to which the organizations subscribes, past environmental or related
                             incidents and accidents
                        gathering information related to current management practices, such as:
                            process controls on purchasing hazardous chemicals
                            the storage and handling of chemicals [e.g. secondary containment;
                               housekeeping, storage of incompatible chemicals]
                            controls on fugitive emissions
                            waste disposal methods
                            emergency preparedness and response equipment
                            use of resources [e.g. use of office lights after working hours]
                            vegetation and habitat protection during construction
                            temporal changes in processes [e.g. changes to crop rotation patterns
                               affecting fertilizer discharges to water]
                            environmental training programs
                            review and approval process for operational control procedures, and
                            completeness of monitoring records and/or ease in retrieving
                               historical records.
                The review can be conducted using checklists, process flowcharts, interviews,
                direct inspection and past and current measurements, results of previous audits or
                other reviews depending on the nature of the facility/organization's activities,
                products and services. The results of the review should be documented so that it
                can be used to contribute to setting the scope and establishing or enhancing the
                facility/organization's EMS, including its environmental policy.)

                (NOTE: Individual Agencies may mandate the use of a particular model. One
                widely accepted EMS model is the ISO 14001 Standard. Another less widely
                accepted model is CEMP. The European Union’s Eco-Management and Audit
                Scheme [EMAS] is not typically used in the U.S.)

                (NOTE: Both auditors who are reviewing an EMS in the context of a regulatory
                compliance audit and auditors who are conducting EMS conformance audits must
                show restraint in how they comment and present valid findings. If a facility has a

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                               procedure for doing something, the organizations is doing what it says it will do,
                               and that procedure appears to be working, then the facility is in conformance,
                               whether or not the auditor happens to think that there is a better procedure. If
                               asked, the auditor can provide additional information as an addition to the
                               statement of fact that the site is in conformance with their chosen EMS model and
                               site-specific EMS implementation requirements.)

O7.20.6.US.             The    (NOTE: This checklist item is drawn from ISO 14004:2004, para 4.4.1.)
facility/organization budget
should address the costs of    Verify that EMS-related activities such as initial self-assessments, development of
EMS (MP) [Added July           performance measures, policy, and establishment of management systems are
2003, Revised April 2005].     addressed in the budget requests.

                               Verify that, when identifying the resources needed to establish, implement and
                               maintain the EMS, a facility considers:

                                      infrastructure
                                      information systems
                                      training
                                      technology
                                      financial, human and other resources specific to its operations.

                               Verify that resource allocations consider both the current and future needs of an
                               organization.

                               (NOTE: In allocating resources, an organization can develop procedures to track
                               the benefits as well as the costs of its environmental or related activities. Issues
                               such as the cost of pollution control, wastes and disposal can be included.)

                               Verify that resources and their allocation are reviewed periodically, and in
                               conjunction with the management review to ensure their adequacy.

                               (NOTE: In evaluating adequacy of resources, consideration should be given to
                               planned changes and/or new projects or operations.)
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                (NOTE: On 27 June 2002, OMB issued guidance in its Circular No. A-11 to
                Federal agencies regarding preparation and submission of their FY 2004 budgets.
                OMB Circular No. A-11 is considered an indicator of planning priorities in the
                Administration’s annual budget. The guidance included a new statement in section
                31, Compliance With Administration Policies and Other General Requirements,
                supporting the use of EMS by all Federal agencies. The guidance reads: ―Federal
                agencies should develop and implement environmental management systems in
                order to integrate environmental accountability into agency day-to-day decision-
                making and long-term planning processes across all agency missions, activities
                and functions. These efforts must be funded within guidance totals. They should
                include, but not be limited to, the following components: initial self-assessments,
                development of performance measures, policy, and establishment of management
                systems.‖)

                (NOTE: The following questions will assist in verifying conformance to this
                requirement.
                       What are the procedures for defining and providing resources to achieve
                          the environmental program’s objectives and targets?)

                (NOTE: Both auditors who are reviewing an EMS in the context of a regulatory
                compliance audit and auditors who are conducting EMS conformance audits must
                show restraint in how they comment and present valid findings. If a facility has a
                procedure for doing something, the organizations is doing what it says it will do,
                and that procedure appears to be working, then the facility is in conformance,
                whether or not the auditor happens to think that there is a better procedure. If
                asked, the auditor can provide additional information as an addition to the
                statement of fact that the site is in conformance with their chosen EMS model and
                site-specific EMS implementation requirements.)




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EMS

O7.30
Implementation

O7.30.1.US.           Facility   (NOTE: This checklist item is drawn from ISO 14001:2004, para 4.4.2 and ISO
personnel should be made         14004:2004, para 4.4.2.)
aware of their environmental
responsibilities (MP) [Added     Verify that the facility establishes, implements and maintains a procedure(s) to
July 2003, Revised April         make persons working for it or on its behalf aware of:
2005].
                                        the importance of conformity with the environmental policy and
                                             procedures and with the requirements of the EMS
                                        the significant environmental aspects and related actual or potential
                                             impacts associated with their work, and the environmental benefits of
                                             improved personal performance
                                        their roles and responsibilities in achieving conformity with the
                                             requirements of the EMS
                                        the potential consequences of departure from specified procedures.

                                 (NOTE: All persons working for or on behalf of an organization include
                                 employees, contractors and, as applicable, other involved parties.)

                                 (NOTE: Environmental responsibilities may include:
                                     who to call in case of a spill or other environmental exposure
                                     what to do if unsure how to dispose of an item
                                     taking advantage of recycling or pollution prevention opportunities.)

                                 (NOTE: The process of communicating environmental responsibilities may differ
                                 depending on the level of responsibilities. For example, it might be done as a part
                                 of an existing regularly scheduled meeting, through email alerts, through internal
                                 memos, through heightened awareness training.)

                                 Verify that the methodology used to communicate environmental responsibilities
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                               works by asking individuals what their environmental responsibilities/activities
                               are.

                               (NOTE: Asking employees the following questions will assist in verifying
                               conformance to this requirement.
                                     What are your roles and responsibilities with respect to environmental
                                         management?
                                     Where are these roles and responsibilities documented?
                                     What is your authority to fulfill these roles and responsibilities?
                                     Where is this authority documented?
                                     How were you made aware of your roles, responsibilities, and authorities?
                                     Do you understand your responsibilities within the EMS?)

                               (NOTE: Both auditors who are reviewing an EMS in the context of a regulatory
                               compliance audit and auditors who are conducting EMS conformance audits must
                               show restraint in how they comment and present valid findings. If a facility has a
                               procedure for doing something, the organizations is doing what it says it will do,
                               and that procedure appears to be working, then the facility is in conformance,
                               whether or not the auditor happens to think that there is a better procedure. If
                               asked, the auditor can provide additional information as an addition to the
                               statement of fact that the site is in conformance with their chosen EMS model and
                               site-specific EMS implementation requirements.)

O7.30.2.US.              The   (NOTE: This checklist item is drawn from ISO 14001:2004, para 4.4.2,
facility/organization should   Appendix A, para A.4.2, and ISO 14004:2004, para 4.4.2)
ensure that employees are
trained and capable of         Verify that, for those activities that are most important in the management of its
carrying out environmental     environmental aspects, the facility identifies the knowledge, understanding, skills,
responsibilities (MP) [Added   or abilities that make an individual competent to perform them.
July 2003, Revised April
2005].                         Verify that, once required competence is identified, the facility ensures that
                               persons performing these activities have the required competence.

                               Verify that the facility ensures that any person performing tasks for it or on its
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                behalf that have the potential to cause a significant environmental impact(s)
                identified by the organization is competent on the basis of appropriate education,
                training, or experience.

                Verify that personnel at all organizational levels are informed of, and trained to
                execute, their environmental responsibilities by asking them how and on what are
                they trained.

                Verify that the facility retains records supporting that personnel are competent.

                Verify that the facility identifies training needs associated with its environmental
                aspects and its EMS.

                (NOTE: See Appendix 6-8 for examples of types of environmental training that
                can be provided by a facility.)

                (NOTE: Awareness, knowledge, understanding, and competence may be obtained
                or improved through training, education, or work experience. Competence is
                based on appropriate education, training, skills and/or experience.
                Competence requirements should be considered in recruiting, training and
                developing future skills and abilities of persons working for or on behalf of
                the organization. Competence should also be considered in selecting contractors
                and others working for or on behalf of the organization.)

                Verify that the facility has identified and assessed any differences between the
                competence needed to perform an activity and that possessed by the individual
                required to perform the activity.

                Verify that any difference between the competence needed to perform an activity
                and that possessed by the individual required to perform the activity is rectified
                through additional education, training, skills development, etc.

                (NOTE: The facility will provide training or take other action to meet these needs,
                and retain associated records.)
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                                (NOTE: The facility should require that contractors working on its behalf are able
                                to demonstrate that their employees have the requisite competence and/or
                                appropriate training.)

                                (NOTE: Interview management responsible for identifying training needs. The
                                following questions are examples to assist in verifying conformance to this
                                requirement and may or may not be appropriate at an individual facility.
                                       How does the organization identify its environmental training needs?
                                       How are the environmental training needs of specific job functions
                                          analyzed?
                                       How are the organization’s environmental training programs developed,
                                          reviewed, and modified?
                                       How does the organization ensure that employee knowledge of regulatory
                                          requirements, internal standards, and organization environmental
                                          policies and objectives is current?
                                       What is the appropriate training for each area?)

                                (NOTE: Both auditors who are reviewing an EMS in the context of a regulatory
                                compliance audit and auditors who are conducting EMS conformance audits must
                                show restraint in how they comment and present valid findings. If a facility has a
                                procedure for doing something, the organizations is doing what it says it will do,
                                and that procedure appears to be working, then the facility is in conformance,
                                whether or not the auditor happens to think that there is a better procedure. If
                                asked, the auditor can provide additional information as an addition to the
                                statement of fact that the site is in conformance with their chosen EMS model and
                                site-specific EMS implementation requirements.)

O7.30.3.US.              The    (NOTE: This checklist item is drawn from ISO 14001:2004, para 4.4.3, Appendix
facility/organization should    A, para A.4.3 and ISO 14004:2004, para 4.4.3.)
have, and implement, internal
and external communication      Verify that, in relation to environmental aspects and EMS, the facility establishes,
processes on environmental      implements, and maintains a procedure(s) for:
management issues (MP)
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[Added July 2003, Revised          internal communication among the various levels and functions of the
April 2005].                            organization,
                                   receiving, documenting and responding to relevant communication from
                                        external interested parties.

                            (NOTE: Methods of internal communication may include regular work group
                            meetings, newsletters, bulletin boards, suggestion boxes, email, and intranet sites.)

                            Verify that employees know how to implement the procedure.

                            Verify that the facility has decided whether to communicate externally about its
                            significant environmental aspects and has documented its decision.

                            Verify that, if the facility has decided to communicate externally about its
                            significant environmental aspects, the facility has established and implemented a
                            method for this external communication.

                            (NOTE: The purposes and benefits of communication include:
                                 demonstrating the organization's commitment and efforts to improve
                                      environmental performance, as well as the results of such efforts
                                 raising awareness and encouraging dialogue about the organization's
                                      environmental policy, environmental performance and other relevant
                                      achievements
                                 receiving, considering and responding to questions, concerns or other
                                      inputs
                                 promoting continual improvement of environmental performance.)

                            Verify that personnel are identified as responsible for contacting external
                            organizations/agencies about environmental management issues, including
                            emergency planning.

                            (NOTE: Examples of information to be communicated include:
                                 general information about the organization
                                 management statement if applicable
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                       environmental policy, objectives and targets
                       environmental management processes (including employee and interested
                            party involvement)
                       the organization's commitments to continual improvement and prevention
                            of pollution
                       information related to environmental aspects of products and services,
                            conveyed through for example environmental labels and declarations
                       information on the organization's environmental performance including
                            trends (e.g. waste reduction, product stewardship, past performance)
                       the organization's compliance with legal and other requirements to which
                            the organization subscribes, and corrective actions taken in response to
                            identified instances of noncompliance
                       supplementary information in reports, such as glossaries
                       financial information such as cost savings or investments in environmental
                            projects
                       potential strategies to improve an organization's environmental
                            performance
                       information related to environmental incidents
                       sources for further information, such as contact person(s) or websites.)

                (NOTE: For example:
                    Who tracks environmental permits and contacts the appropriate agencies
                         when renewal is necessary?
                    Who notifies the appropriate state and local entities of a spill/release?
                    How are personnel informed of a change in environmental managers or
                         permit requirements?)
                  What do you do if you receive environmental-related communication from
                   external parties?)

                (NOTE: Both auditors who are reviewing an EMS in the context of a regulatory
                compliance audit and auditors who are conducting EMS conformance audits must
                show restraint in how they comment and present valid findings. If a facility has a
                procedure for doing something, the organizations is doing what it says it will do,
                and that procedure appears to be working, then the facility is in conformance,
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                            whether or not the auditor happens to think that there is a better procedure. If
                            asked, the auditor can provide additional information as an addition to the
                            statement of fact that the site is in conformance with their chosen EMS model and
                            site-specific EMS implementation requirements.)

O7.30.4.US. Documentation   (NOTE: This checklist item is drawn from ISO 14001:2004, para 4.4.4, 4.4.5,
of EMS development and      4.5.4, Appendix A, para A.4.4., A.5.4; IS 14004:2004, para 4.4.4, 4.4.5, and
performance  should    be   4.5.4)
maintained (MP) [Added
July 2003, Revised April    Verify that the facility establishes and maintains records as necessary to
2005].                      demonstrate conformity to the requirements of its EMS and the results achieved.

                            (NOTE: Documentation should be collected and maintained in a way that reflects
                            the culture and needs of an organization, building onto and improving its existing
                            information system.)

                            Verify that EMS documentation includes:

                                   the environmental policy, objectives and targets
                                   description of the scope of the environmental management system,
                                   description of the main elements of the environmental management system
                                        and their interaction, and reference to related documents
                                   documents, including records, required by this International Standard
                                   documents, including records, determined by the organization to be
                                        necessary to ensure the effective
                                   planning, operation and control of processes that relate to its significant
                                        environmental aspects.

                            (NOTE: The level of detail of the documentation should be sufficient to describe
                            the environmental management system and how its parts work together, and to
                            provide direction on where to obtain more detailed information on the operation of
                            specific parts of the EMS.)

                            Verify that documents can be located.
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                Verify that records are and remain legible, identifiable, and traceable.

                Verify that documents required by the EMS are controlled.

                Verify that documents that are used which were originally created for purposes
                other than the EMS, are referenced in the system.

                (NOTE: Examples of documents include:
                     statements of policy, objectives and targets
                     description of the scope of the EMS
                     descriptions of programs and responsibilities
                     information on significant environmental aspects
                     procedures
                     process information
                     organizational charts
                     internal and external standards
                     site emergency plans
                     records.)

                Verify that the facility has established, implemented and maintains a procedure(s)
                for the identification, storage, protection, retrieval, retention and disposal of
                records.

                Verify that the facility has established, implemented, and maintains a procedure
                to:

                       approve documents for adequacy prior to issue
                       review and update as necessary and re-approve documents
                       ensure that changes and the current revision status of documents are
                            identified
                       ensure that relevant versions of applicable documents are available at
                            points of use
                       ensure that documents remain legible and readily identifiable
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                      ensure that documents of external origin determined by the organization to
                          be necessary for the planning and operation of the environmental
                          management system are identified and their distribution controlled
                      prevent the unintended use of obsolete documents and apply suitable
                          identification to them if they are retained for any purpose.

                (NOTE: Any decision to document procedures should be based on issues such as:
                     the consequences, including those to the environment, of not doing so
                     the need to demonstrate compliance with legal and with other requirements
                          to which the organization subscribes
                     the need to ensure that the activity is undertaken consistently
                     the advantages of doing so, which can include easier implementation
                          through communication and training, easier maintenance and revision,
                          less risk of ambiguity and deviations, and demonstrability and
                          visibility
                     the requirements of ISO 14001:2004.)

                (NOTE: Some obsolete documents may need to be retained for legal and/or
                knowledge preservation purposes.)

                (NOTE: Environmental records can include, among others:
                     complaint records
                     training records
                     process monitoring records
                     inspection, maintenance and calibration records
                     pertinent contractor and supplier records
                     incident reports
                     records of tests for emergency preparedness
                     audit results
                     management review results
                     external communications decision
                     records of applicable legal requirements
                     records of significant environmental aspects
                     records of environmental meetings
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                       environmental performance information
                       legal compliance records
                       details of nonconformities and corrective and preventive actions
                       permits, licenses, or other forms of legal authorization
                       results of operational controls
                       communications with interested parties.)

                (NOTE:     The primary focus of organizations should be on effective
                implementation of the EMS and on environmental performance, not on a complex
                document control system.)

                (NOTE: The following questions are examples to assist in verifying conformance
                to this requirement and may or may not be appropriate at an individual facility.
                         How does the organization’s record/information management system make
                             environmental information available to the employees when they need
                             it?
                         What is your procedure for controlling all documents required by the EMS
                             to ensure they can be located?
                         How do employees access EMS documentation needed to conduct their job
                             activities?
                         How are environmental management procedures identified, documented,
                             communicated, and revised?)
                         What records exist to demonstrate that authorized personnel have approved
                             EMS documents for adequacy?
                         How has the EMS documentation been integrated into the overall business
                             management documentation?
                         What procedures exist to ensure that up-to-date documents are available
                             where they are needed?
                         Who is responsible for implementing these procedures?
                         How are changes to this procedure made when operations or activities
                             change?
                         What records does your EMS generate?
                         How are these records identified within your EMS procedures?)


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                                  (NOTE: Both auditors who are reviewing an EMS in the context of a regulatory
                                  compliance audit and auditors who are conducting EMS conformance audits must
                                  show restraint in how they comment and present valid findings. If a facility has a
                                  procedure for doing something, the organizations is doing what it says it will do,
                                  and that procedure appears to be working, then the facility is in conformance,
                                  whether or not the auditor happens to think that there is a better procedure. If
                                  asked, the auditor can provide additional information as an addition to the
                                  statement of fact that the site is in conformance with their chosen EMS model and
                                  site-specific EMS implementation requirements.)

O7.30.5.US.         Operations,   (NOTE: This checklist item is drawn from ISO 14001:2004, para 4.4.6, Appendix
activities, and processes at a    A, para A.4.6; ISO 14004: 2004, para 4.4.6)
facility/organization should be
planned and managed to align      Verify that operations, activities, and processes at a facility/organization are
with EMS policy, objectives       planned and managed to align with EMS policy, objectives and targets.
and targets (MP) [Added July
2003, Revised April 2005].        (NOTE: A facility might use operational controls to:
                                       manage identified significant environmental aspects
                                       ensure compliance with legal requirements and other requirements to
                                            which the organization subscribes
                                       achieve objectives and targets and ensure consistency with its
                                            environmental policy, including the commitment to prevention of
                                            pollution and continual improvement,
                                       avoid or minimize environmental risks.)

                                  (NOTE: A facility should evaluate those of its operations that are associated with
                                  its identified significant environmental aspects and ensure that they are conducted
                                  in a way that will control or reduce the adverse impacts associated with them, in
                                  order to fulfill the requirements of its environmental policy and meet its objectives
                                  and targets. This should include all parts of its operations, including maintenance
                                  activities.)

                                  Verify that the facility has identified, and plans, those operations that are
                                  associated with the identified significant environmental aspects consistent with its
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                environmental policy, objectives and targets, in order to ensure that operations are
                carried out under specified conditions, by:

                       establishing, implementing and maintaining a documented procedure to
                            control situations where their absence could lead to deviation from the
                            environmental policy, objectives and targets
                       stipulating the operating criteria in the procedure
                       establishing, implementing and maintaining procedures related to the
                            identified significant environmental aspects of goods and services used
                            by the organization and communicating applicable procedures and
                            requirements to suppliers, including contractors.

                (NOTE: For example, if there is a target of 50% solid waste reduction, recycling
                options have to be readily available throughout the facility/operation.)
                (NOTE: Examples of operations include:
                       acquisition, construction or modification of property and facilities
                       contracting
                       customer service
                       handling and storage of raw materials
                       marketing and advertising
                       production and maintenance processes
                       purchasing
                       research, design, and development engineering
                       storage of products
                       transportation
                       utility processes [e.g. energy and water supply, recycling, waste and
                             wastewater management].)

                (NOTE: A common approach to establishing operational controls includes:
                     choosing a method of control
                     selecting acceptable operating criteria
                     establishing procedures, as needed, that define how identified operations
                          are to be planned, carried out and controlled
                     documenting these procedures, as needed, in the form of instructions,
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                                            signs, forms, videos, photos, etc.)

                                 (NOTE: The following questions will assist in verifying conformance to this
                                 requirement.
                                        Who has been identified and given authority to oversee and implement the
                                            policy?
                                        How do the management units within the organization implement the
                                            policy?
                                        How is the environmental policy implemented throughout the
                                            organization?)
                                        Are individuals aware of the environmental policy? How were they made
                                            aware?
                                        What does the environmental policy mean to individuals?
                                        What is your procedure for specifying operating criteria in the documented
                                            procedures for the activities that must be carried out under controlled
                                            conditions?
                                        How do personnel ensure that these operations are carried out in
                                            accordance with specified operating criteria?)

                                 (NOTE: Both auditors who are reviewing an EMS in the context of a regulatory
                                 compliance audit and auditors who are conducting EMS conformance audits must
                                 show restraint in how they comment and present valid findings. If a facility has a
                                 procedure for doing something, the organizations is doing what it says it will do,
                                 and that procedure appears to be working, then the facility is in conformance,
                                 whether or not the auditor happens to think that there is a better procedure. If
                                 asked, the auditor can provide additional information as an addition to the
                                 statement of fact that the site is in conformance with their chosen EMS model and
                                 site-specific EMS implementation requirements.)

O7.30.6.US.               The    (NOTE: This checklist item is drawn from ISO 14001:2004, para 4.4.7, Appendix
facility/organization should     A, para A.4.7; ISO 14004, para 4.4.7.)
have       procedures      and
agreements in place to prepare   Verify that the facility/operation has identified potential emergencies and
for      and     respond    to   developed procedures for preventing them and responding to them.
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emergencies (MP) [Added
July 2003, Revised April   Verify that the facility does respond to actual emergency situations and accidents
2005].                     and prevent or mitigate associated adverse environmental impacts.

                           Verify that the facility periodically reviews and, where necessary, revises its
                           emergency preparedness and response procedures, in particular, after the
                           occurrence of accidents or emergency situations.

                           Verify that the procedure(s) take into account potential consequences of abnormal
                           operating conditions, potential emergency situations and potential accidents.

                           Verify that the facility also periodically tests such procedures where practicable.

                           Verify that, if needed, formal agreements have been made with local fire
                           departments and/or HAZMAT response teams for services.

                           (NOTE: In developing emergency procedure(s), the facility should include
                           consideration of:
                                  the nature of on-site hazards, e.g. flammable liquids, storage tanks and
                                       compressed gases, and measures to be taken in the event of spillages
                                       or accidental releases
                                  the most likely type and scale of an emergency situation or accident
                                  the potential for an emergency situation or accident at a nearby facility
                                       [e.g., plant, road, railway line]
                                  the most appropriate method(s) for responding to an accident or emergency
                                       situation
                                  internal and external communication plans
                                  the action(s) required to minimize environmental damage
                                  mitigation and response action(s) to be taken for different types of accident
                                       or emergency situation
                                  the need for a process(es) for post-accident evaluation to establish and
                                       implement corrective and preventive actions
                                  periodic testing of emergency response procedure(s)
                                  training of emergency response personnel
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                      a list of key personnel and aid agencies, including contact details (e.g. fire
                           department, spillage clean-up services)
                      evacuation routes and assembly points
                      the potential for an emergency situation(s) or accident(s) at a nearby
                           facility (e.g. plant, road, railway line),
                      the possibility of mutual assistance from neighboring organizations.)

                (NOTE: The following questions will assist in verifying conformance to this
                requirement.
                       What procedures have been established to identify potential accidents and
                          emergency situations?
                       What procedures have been established to identify the responses to
                          accidents and emergency situations?
                       How are these procedures maintained?
                       How are these procedures periodically reviewed for adequacy?
                       What are the training plans for these procedures?
                       What are the organizational procedures for preventing the environmental
                          impacts associated with identified potential accidents and emergency
                          situations?
                       What are the organizational procedures for mitigating the environmental
                          impacts associated with identified potential accidents and emergency
                          situations?
                       How do you ensure that these procedures cover all environmental impacts?
                       How do you ensure that there is a clear link between potential accidents,
                          emergency situations, and their environmental impacts?
                       What is your process for reviewing the prevention and mitigation
                          procedures, especially after process or operational changes?
                       How are the emergency preparedness and response procedures reviewed
                          and revised for adequacy after an occurrence of an accident or
                          emergency situation?
                       How are key staff made aware of specific emergency preparedness and
                          response procedures? How are the changes made to these procedures?
                       How often does the organization test emergency preparedness and
                          response procedures?
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                                        How do you ensure that these procedures are tested wherever practicable?
                                        What records are available for emergency response testing?

                                 (NOTE: Asking employees the following questions will assist in verifying
                                 conformance to this requirement.
                                       What do you do in case of a procedural nonconformance?
                                       What do you do in case of an emergency?)

                                 (NOTE: Both auditors who are reviewing an EMS in the context of a regulatory
                                 compliance audit and auditors who are conducting EMS conformance audits must
                                 show restraint in how they comment and present valid findings. If a facility has a
                                 procedure for doing something, the organizations is doing what it says it will do,
                                 and that procedure appears to be working, then the facility is in conformance,
                                 whether or not the auditor happens to think that there is a better procedure. If
                                 asked, the auditor can provide additional information as an addition to the
                                 statement of fact that the site is in conformance with their chosen EMS model and
                                 site-specific EMS implementation requirements.)

O7.30.7.US.               The    (NOTE: This checklist item is drawn from ISO 14001:2004, para 4.6.2, and ISO
facility/organization should     14004, para 4.6.2.)
integrate            continual
improvement as a part of its     (NOTE: Continual improvement is accomplished through the achievement of
EMS (MP) [Added April            environmental objectives and targets and the overall enhancement of the
2005].                           environmental management system or any of its components.)

                                 Verify that, as a part of the continual evaluation of environmental performance
                                 and the performance of the EMS, opportunities for improvement are identified.

                                 (NOTE: Opportunities for improvement can be identified by analyzing the root
                                 causes(s) of EMS deficiencies.)

                                 (NOTE: Some useful sources of information for continual improvement include:
                                      experience gained from corrective and preventive actions

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                       external benchmarking against best practices
                       intended or proposed changes applicable to legal requirements and other
                            requirements to which the organization subscribes
                       results of environmental management system and compliance audits
                       results of monitoring of key characteristics of operations
                       results of progress towards achieving objectives and targets
                       views of interested parties, including employees, customers and suppliers.)

                Verify that, when opportunities for improvement are identified, they are evaluated
                to determine what actions should be taken.

                Verify that the actions for improvement are planned, and changes to the EMS are
                implemented in accordance with those plans.

                (NOTE: Improvements need not take place in all areas simultaneously.)

                (NOTE: Examples of improvements include:
                     establishing a process for evaluating new materials to promote the use of
                          less harmful materials
                     improving an organization's process for identifying applicable legal
                          requirements so that new compliance requirements are identified in a
                          more timely fashion
                     improving employee training on materials and handling to reduce an
                          organization's generation of waste
                     introducing waste water treatment processes to allow water reuse
                     implementing changes in default settings on reproduction equipment to
                          print two-sided copies at a printing office
                     redesigning delivery routes to reduce fossil fuel consumption by
                          transportation company(ies)
                     setting objectives and targets to implement fuel substitution in boiler
                          operations and reduce particulate emissions.)




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EMS

O7.40
Monitoring and Measuring

O7.40.1.US.               The    (NOTE: This checklist item is drawn from ISO 14001:2004, para 4.5.1, Appendix
facility/organization should     A, para A.5.1; ISO 14004, para 4.5.1.)
have a procedure to check on
the key characteristics of its   (NOTE: This involves more than an environmental compliance audit, although
operations that can have a       environmental compliance auditing is a component of EMS implementation.)
significant      environmental
impact (MP) [Added July          Verify that the facility has established, implemented and maintains a procedure to
2003, Revised April 2005].       monitor and measure, on a regular basis, the key characteristics of its operations
                                 that can have a significant environmental impact.

                                 (NOTE: Key characteristics are those that the facility needs to consider to
                                 determine how it is managing its significant environmental aspects, achieving
                                 objectives and targets, and improving environmental performance.)

                                 (NOTE: Monitoring involves collecting information, such as measurements or
                                 observations, over time. Measurements can be either quantitative or qualitative.)

                                 Verify that the procedure includes the documenting of information to monitor
                                 performance, applicable operational controls and conformity with the
                                 organization's environmental objectives and targets.

                                 Verify that the facility ensures that calibrated or verified monitoring and
                                 measurement equipment is used and maintained and associated records are
                                 maintained.

                                 (NOTE: Monitoring and measurements can serve many purposes in an EMS,
                                 such as:
                                        tracking progress on meeting policy commitments, achieving objectives
                                             and targets, and continual improvement
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                       developing information to identify significant environmental aspects
                       monitoring emissions and discharges to meet applicable legal requirements
                           or other requirements to which the organization subscribes
                       monitoring consumption of water, energy or raw materials to meet
                           objectives and targets
                       providing data to support or evaluate operational controls
                       providing data to evaluate the organization's environmental performance
                       providing data to evaluate the performance of the environmental
                           management system.)

                (NOTE: The following questions are examples to assist in verifying conformance
                to this requirement and may or may not be appropriate at an individual facility.
                         How do you determine the key characteristics of the organization’s
                             operations and activities that can have a significant impact on the
                             environment?
                         What procedures are used to regularly monitor and measure these key
                             characteristics?
                         What process do you use to develop these procedures?
                         How do you revise old procedures or add new procedures when changes to
                             products, processes, or activities occur?
                         How is environmental performance regularly monitored?
                         How are operational controls regularly monitored?
                         How is conformance with the organization’s environmental objectives and
                             targets regularly monitored?)

                (NOTE: Both auditors who are reviewing an EMS in the context of a regulatory
                compliance audit and auditors who are conducting EMS conformance audits must
                show restraint in how they comment and present valid findings. If a facility has a
                procedure for doing something, the organizations is doing what it says it will do,
                and that procedure appears to be working, then the facility is in conformance,
                whether or not the auditor happens to think that there is a better procedure. If
                asked, the auditor can provide additional information as an addition to the
                statement of fact that the site is in conformance with their chosen EMS model and
                site-specific EMS implementation requirements.)
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O7.40.2.US.             The     Verify that the facility/organization monitors key activities and tracks their
facility/organization should    performance in relation to the EMS.
monitor key activities and
track their performance in      (NOTE: For example, if the reduction of liquid solvent use is a target of the EMS,
relation to the EMS (MP)        the facility/organization should be able to review statistics on liquid solvent
[Added July 2003].              procurement and waste disposal.)

                                (NOTE: The following questions are examples to assist in verifying conformance
                                to this requirement and may or may not be appropriate at an individual facility.
                                         How do you measure progress toward achieving the program’s objectives
                                             and targets?
                                         How are the specific actions to attain targets prioritized in order of their
                                             importance to the organization?
                                         How is EMS performance reported to top management for review and as a
                                             basis for continual improvement?)

                                (NOTE: Both auditors who are reviewing an EMS in the context of a regulatory
                                compliance audit and auditors who are conducting EMS conformance audits must
                                show restraint in how they comment and present valid findings. If a facility has a
                                procedure for doing something, the organizations is doing what it says it will do,
                                and that procedure appears to be working, then the facility is in conformance,
                                whether or not the auditor happens to think that there is a better procedure. If
                                asked, the auditor can provide additional information as an addition to the
                                statement of fact that the site is in conformance with their chosen EMS model and
                                site-specific EMS implementation requirements.)

O7.40.3.US.              The    (NOTE: This checklist item is drawn from ISO 14001:2004, para 4.5.2 and ISO
facility/organization should    14004:2004, para 4.5.2.)
periodically           assess
compliance       with   legal   Verify that, consistent with its commitment to compliance, the facility establishes
requirements as well as other   implements and maintains a procedure(s) for periodically evaluating compliance
requirements such as policy     with applicable legal requirements.
letter and memorandum (MP)
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[Added July 2003, Revised   Verify that the facility keep records of the results of the periodic compliance
April 2005].                evaluations.

                            Verify that the facility has established a frequency and methodology for
                            evaluation of compliance that suits its size, type and complexity.

                            (NOTE: Frequency can be affected by factors such as past compliance
                            performance or specific legal requirements.)

                            Verify that the facility evaluates compliance with other requirements (i.e., Army
                            Regulations, Bureau/Agency memorandum, policy letter) to which the facility is
                            required to comply.

                            (NOTE: The facility may wish to combine this evaluation with the above
                            mentioned evaluation of legal compliance or to establish a separate procedure(s).)

                            Verify that the facility keeps records of the results of the periodic evaluations.

                            (NOTE: Under Section 402 of EO 13148, each agency that did not have an
                            established regulatory environmental compliance audit program had to develop
                            and implement a program to conduct facility environmental compliance audits by
                            21 April 2001 and begin auditing at its facilities within 6 mo of the development
                            of that program. The EO does not establish an audit frequency or scope but
                            encourages Agencies to:
                                    conduct audits not less than every 3 years from the date of the initial or
                                        previous audit
                                    base the scope on facility size, complexity, and the environmental aspects
                                        of facility operations
                                    as appropriate, include tenant, contractor, and concessionaire activities in
                                        facility audits.
                            Consult your Agency Supplement to TEAM for Agency-specific compliance audit
                            program details and requirements.)



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                                (NOTE: The following questions are examples to assist in verifying conformance
                                to this requirement and may or may not be appropriate at an individual facility.
                                         What is the organization’s process for ensuring compliance with relevant
                                             environmental legislation and regulations?
                                         What procedure does the organization use to identify its legal
                                             requirements?
                                         How does the procedure provide for identification and access to all
                                             applicable legal requirements?
                                         How does the organization keep track of changes to legal requirements?
                                         How are local regulatory requirements identified?
                                         What actions are taken on discovered compliance deficiencies?)

                                (NOTE: Both auditors who are reviewing an EMS in the context of a regulatory
                                compliance audit and auditors who are conducting EMS conformance audits must
                                show restraint in how they comment and present valid findings. If a facility has a
                                procedure for doing something, the organizations is doing what it says it will do,
                                and that procedure appears to be working, then the facility is in conformance,
                                whether or not the auditor happens to think that there is a better procedure. If
                                asked, the auditor can provide additional information as an addition to the
                                statement of fact that the site is in conformance with their chosen EMS model and
                                site-specific EMS implementation requirements.)


O7.40.4.US.               The   (NOTE: This checklist item is drawn from ISO 14001:2004, para 4.5.3 and ISO
facility/organization should    14004:2004, para 4.5.3.)
correct and prevent the
recurrence of noncompliance     Verify that the facility has established, implemented, and maintains a procedure
and process deficiencies (MP)   for dealing with actual and potential nonconformity(ies) and for taking corrective
[Added July 2003, Revised       action and preventive action.
April 2005].
                                (NOTE: Nonconformity is nonfulfillment of a requirement.)

                                Verify that known noncompliance is corrected to the extent possible within the

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                abilities of the facility/organization.

                Verify that the procedure includes requirements for:

                       identifying and correcting nonconformity(ies) and taking action(s) to
                            mitigate their environmental impacts
                       investigating nonconformity(ies), determining their cause(s) and taking
                            actions in order to avoid their recurrence
                       evaluating the need for action(s) to prevent nonconformity(ies) and
                            implementing appropriate actions designed to avoid their occurrence
                       recording the results of corrective action(s) and preventive action(s) taken
                       reviewing the effectiveness of corrective action(s) and preventive action(s)
                            taken.

                Verify that actions taken are appropriate to the magnitude of the problems and the
                environmental impacts encountered.

                Verify that the facility ensures that any necessary changes are made to EMS
                documentation.

                Verify that process deficiencies are reviewed and determination is made as to
                whether the process needs to change or not.

                Verify that the facility/organization identifies and responds to the root cause of a
                deficiency and not only the deficiency itself.

                (NOTE: Situations may occur where part of the system may not function as
                intended or environmental performance requirements are not met. Examples of
                such situations can include:
                        system performance:
                            failure to establish environmental objectives and targets
                            failure to define responsibilities required by an environmental
                              management system, such as responsibilities for achieving objectives

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                                            and targets or for emergency preparedness and response
                                         failure to periodically evaluate compliance with legal requirements
                                      environmental performance:
                                         energy reduction targets are not achieved
                                         maintenance requirements are not performed as scheduled
                                         operating criteria [e.g. permitted limits] are not met.)

                               (NOTE: Both auditors who are reviewing an EMS in the context of a regulatory
                               compliance audit and auditors who are conducting EMS conformance audits must
                               show restraint in how they comment and present valid findings. If a facility has a
                               procedure for doing something, the organizations is doing what it says it will do,
                               and that procedure appears to be working, then the facility is in conformance,
                               whether or not the auditor happens to think that there is a better procedure. If
                               asked, the auditor can provide additional information as an addition to the
                               statement of fact that the site is in conformance with their chosen EMS model and
                               site-specific EMS implementation requirements.)


                                    COMPLIANCE CATEGORY:
                                  OTHER ENVIRONMENTAL ISSUES
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     REGULATORY                                             REVIEWER CHECKS:
    REQUIREMENTS:                                              December 2005

EMS

O7.50
Management Review

O7.50.1.US.             The    (NOTE: This checklist item is drawn from ISO 14001:2004, para 4.5.5, Appendix
facility/organization should   A, para A.5.5; ISO 14004:2004, para 4.5.5.)
have a system to review the
EMS as a whole (MP)            Verify that the facility/organization has an EMS audit to ensure the EMS is

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[Added July 2003, Revised   functioning as intended.
April 2005].
                            Verify that internal audits of the EMS are conducted at planned intervals to
                            determine whether the EMS:

                                   conforms to planned arrangements for environmental management
                                       including the requirements of ISO 14001
                                   has been properly implemented and is maintained,

                            (NOTE: Internal audits may also be performed to identify opportunities for
                            improvement.)

                            Verify that internal audits of the EMS are conducted at planned intervals to
                            provide information on the results of audits to management.

                            (NOTE: Internal audits of an EMS can be performed by personnel from within
                            the facility/organization or by external persons selected by the
                            facility/organization, working on its behalf. In either case, the persons conducting
                            the audit should be competent and in a position to do so impartially and
                            objectively. In smaller facilities/organizations, auditor independence can be
                            demonstrated by an auditor being free from responsibility for the activity being
                            audited.)

                            Verify that audit programs are planned, established, implemented and maintained
                            by the organization, taking into consideration the environmental importance of the
                            operations concerned and the results of previous audits.

                            (NOTE: Each internal audit need not cover the entire system as long s the audit
                            program ensures that all organizational units and functions, system elements and
                            the full scope of the EMS are audited periodically.)

                            Verify that audit procedures are established, implemented, and maintained that
                            address:

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                       the responsibilities and requirements for planning and conducting audits,
                            reporting results and retaining associated records
                       the determination of audit criteria, scope, frequency and methods.

                Verify that the selection of auditors and conduct of audits ensures objectivity and
                the impartiality of the audit process.

                Verify that management periodically reviews the EMS and looks specifically at:

                       environmental performance
                       the ability to support mission and priorities.

                (NOTE: The results of the internal EMS audit can be provided in the form of a
                report and used to correct or prevent specific nonconformities, fulfill one or more
                objectives of the audit programmer, and provide input to the conduct of the
                management review.)

                (NOTE: The following questions are examples to assist in verifying conformance
                to this requirement and may or may not be appropriate at an individual facility.
                         What are the means to ensure the organization’s commitment to continual
                             improvement?)
                         How has the policy been revised as a result of management review
                             activities?)
                         How are audits scheduled to ensure adherence to all aspects of the EMS?
                         How do audits determine whether or not the EMS conforms to planned
                             arrangements for environmental management, including EMS
                             requirements?
                         What procedures have been established to provide information on the
                             results of audits to top management?
                         How do the audit procedures require that the audit cover the full scope of
                             the system being audited?)

                (NOTE: Both auditors who are reviewing an EMS in the context of a regulatory

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                                  compliance audit and auditors who are conducting EMS conformance audits must
                                  show restraint in how they comment and present valid findings. If a facility has a
                                  procedure for doing something, the organizations is doing what it says it will do,
                                  and that procedure appears to be working, then the facility is in conformance,
                                  whether or not the auditor happens to think that there is a better procedure. If
                                  asked, the auditor can provide additional information as an addition to the
                                  statement of fact that the site is in conformance with their chosen EMS model and
                                  site-specific EMS implementation requirements.)


O7.50.2.US.                Top    (NOTE: This checklist item is drawn from ISO 14001:2004, para 4.6 and ISO
management           of     the   14004:2004, para 4.6.)
facility/organization should be
involved     in     the   EMS     Verify that management participation in EMS goes beyond declaration of a policy.
implementation beyond the
declaration of a policy (MP)      (NOTE: Examples include:
[Added July 2003, Revised             management participation in environmental committees
April 2005].                          inclusion of targets specific to management in the EMS
                                      allocation of funds for EMS-related issues
                                      attendance at management focused EMS training.)

                                  Verify that top management reviews the facility’s EMS at planned intervals to
                                  ensure its continuing suitability, adequacy and effectiveness.

                                  (NOTE: Each facility can decide for itself those who will participate in the
                                  management review.)

                                  Verify that reviews include assessing opportunities for improvement and the need
                                  for changes to the EMS, including the environmental policy and environmental
                                  objectives and targets.

                                  Verify that records of the management reviews are retained.

                                  (NOTE: Input to management reviews shall include:
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                       results of internal audits and evaluations of compliance with legal
                            requirements and with other requirements to which the organization
                            subscribes
                       communication(s) from external interested parties, including complaints
                       the environmental performance of the organization
                        the extent to which objectives and targets have been met
                       status of corrective and preventive actions
                       follow-up actions from previous management reviews
                       changing circumstances, including developments in legal and other
                            requirements related to its environmental aspects
                       recommendations for improvement.)

                (NOTE: The outputs from management reviews shall include any decisions and
                actions related to possible changes to environmental policy, objectives, targets and
                other elements of the EMS, consistent with the commitment to continual
                improvement.)

                (NOTE: Records of management review can include copies of meeting agenda
                items, lists of attendees, presentation materials or handouts, and management
                decisions recorded in a memo to file, reports, minutes, or tracking system.)

                (NOTE: The following questions are examples to assist in verifying conformance
                to this requirement and may or may not be appropriate at an individual facility.
                         How has top management reinforced organizational commitment to the
                             environmental policy?)
                         How has top management communicated organizational commitment to
                             the environmental policy?
                         What is the process for receiving and responding to employee concerns?)

                (NOTE: Both auditors who are reviewing an EMS in the context of a regulatory
                compliance audit and auditors who are conducting EMS conformance audits must
                show restraint in how they comment and present valid findings. If a facility has a
                procedure for doing something, the organizations is doing what it says it will do,
                and that procedure appears to be working, then the facility is in conformance,
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                whether or not the auditor happens to think that there is a better procedure. If
                asked, the auditor can provide additional information as an addition to the
                statement of fact that the site is in conformance with their chosen EMS model and
                site-specific EMS implementation requirements.)




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                                                                   Appendix 6-4

                                                          Major Components of an EMS
                                            (EMS Primer for Federal Facilities and ISO 14004, para 4.1.1)
                                (http://www.epa.gov/compliance/resources/publications/incentives/ems/emsprimer.pdf )
                                                       [Added July 2003, Revised April 2005]

The EMS detailed in ISO 14001 and ISO 14004 follows a ―Plan-Do-Check-Act‖ (PDCA) management model. See the following page for more details on
PDCA.


                                                                                       START




               Management                                                         Environmental
                 Review                                                               Policy

                                              Continual
                                              Improvement



                  Checking                                                     Planning
                                                                             Environmental Aspects
                 Monitor & Measure                                          Legal & Other Reqt’s
               Nonconformance & Corrective                                  Objective & Targets
                   & Preventative Actions                                    Environmental
                Records & EMS Audits                                         Management Program



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                                        Implementation and
PDCA is an ongoing, iterative process that enables an organization to establish, implement and maintain its environmental policy based on top management's
leadership and commitment to the EMS. After the organization has evaluated its current position in relation to the environment the steps of this ongoing process
are the following:

a) Plan: establish an ongoing planning process that enables the organization to:
         1) identify environmental aspects and associated environmental impacts
         2) identify and monitor applicable legal requirements and other requirements to which the organization subscribes, and set internal performance criteria
             where appropriate
         3) set environmental objectives and targets and formulate program(s) to achieve them, and
         4) develop and use performance indicators.

b) Do: implement and operate the EMS
         1) create management structures, assign roles and responsibilities with sufficient authority,
         2) provide adequate resources
         3) train persons working for or on behalf of the organization and ensure their awareness and competence
         4) establish processes for internal and external communication
         5) establish and maintain documentation
         6) establish and implement document control(s)
         7) establish and maintain operational control(s), and
         8) ensure emergency preparedness and response).

c) Check: assess EMS processes
        1) conduct ongoing monitoring and measurement
        2) evaluate status of compliance
        3) identify nonconformity and take corrective and preventive actions
        4) manage records, and
        5) conduct periodic internal audits.

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d) Act: review and take action to improve the EMS
         1) conduct management reviews of the EMS at appropriate intervals, and
         2) identify areas for improvement.

This ongoing process enables the organization to continually improve its EMS and its overall environmental performance.




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                                                                         Appendix 6-5
                                        USEPA Position Statement on Environmental Management Systems (EMSs)
                                                         (http://www.epa.gov/ems/policy/index.htm)
                                                                    [Added July 2003]

Background

In recent years organizations have increasingly adopted formal Environmental Management Systems (EMSs). The most common framework for an EMS is plan-
do-check-act, with the goal of continual improvement. EMSs provide organizations of all types with a structured approach for managing environmental and
regulatory responsibilities to improve overall environmental performance, including areas not subject to regulation such as resource conservation and energy
efficiency. EMSs can also help organizations better integrate the full scope of environmental considerations and get better results, by establishing a continuous
process of checking to make sure environmental goals are met. EMS implementation ensures that procedures are in place for taking remedial action if problems
occur. From a business perspective, they can often help make organizations more efficient and more competitive and help address other important issues such as
security at key facilities. EMSs do not replace the need for regulatory and enforcement programs, but they can complement them. EMSs can indicate
opportunities for EPA to streamline regulations, and be considered in compliance assistance, monitoring, and enforcement. First adopted by manufacturing
industries, EMSs are now being used throughout the private sector and, increasingly, by public agencies of many different types.

For the past several years, EPA has been involved in a wide range of activities designed to facilitate EMS adoption, including those based on ISO 14001 and
other models, and cooperative efforts with Canada and Mexico through the Commission on Environmental Cooperation. We are also leading research designed to
evaluate effectiveness of EMSs in various settings, and integrating EMSs into more of our own programs, including enforcement settlement agreements.

In 1999, EPA issued a major report entitled Aiming for Excellence: Actions to Encourage Stewardship and Accelerate Environmental Progress, which committed
that EPA "... will encourage organizations to use EMSs that improve compliance, pollution prevention, and other measures of environmental performance. We'll
continue evaluation efforts to learn more about which EMS elements and applications are most effective, and we'll determine how these systems might be used to
strengthen environmental programs and policies."

Most recently, EPA has developed EPA's Own EMS Policy for its own facilities to meet the goals set forth in Executive Order 13148 - The Greening of
Government Through Leadership in Environmental Management. Based on the practical experience and knowledge we have gained, it is becoming clear that
EMSs, when implemented diligently, can help improve environmental performance and foster other important benefits to organizations. Therefore, EPA is today
issuing an updated statement on EMSs along with an EMS Plan to guide Agency activities over the next several years.

Statement of Principles:

EPA's overall policy on Environmental Management Systems, like the EMS approach itself, will be guided by the principles of continual improvement and
learning, flexibility, and collaboration.




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       EPA will encourage wide spread use of EMSs across a range of organizations and settings, with particular emphasis on adoption of EMSs to achieve
        improved environmental performance and compliance, pollution prevention through source reduction, and continual improvement. We will support
        EMSs that are appropriate to the needs and characteristics of specific sectors and facilities.

       EPA will encourage organizations that use EMSs to obtain stakeholder input on matters relevant to the development and implementation of an EMS,
        and demonstrate accountability for the performance outcomes of their EMSs through measurable objectives and targets. Additionally, we will encourage
        organizations to share information on the performance of their EMSs with the public and government agencies, and facilitate this process where
        practicable.

       EPA will encourage the use of recognized environmental management frameworks, such as the ISO 14001 standard, as a basis for designing and
        implementing EMSs that aim to achieve outcomes aligned with the Nation's environmental policy goals and the principles of this Position Statement.

       EPA will work collaboratively with other key partners–including states, tribes, localities, industry, and non-governmental organizations—as we
        implement this policy. EPA will support international EMS initiatives that will assist in increasing the use of EMSs in the United States. We will ensure
        that our decisions and our work as we implement this policy are transparent to all interested parties.

       EPA will lead by example, by implementing EMSs at appropriate EPA facilities.

       EPA will foster continual learning by supporting research and public dialogue on EMSs that help improve our understanding of circumstances where
        EMSs can advance the Nation's environmental policy goals. We will strive to collect better information on the application of EMSs, including how well
        EMSs meet environmental performance expectations; and the costs and benefits to organizations and the environment.

DATE: May 15, 2002
Signed: Christine Todd Whitman, Administrator




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                                                                          Appendix 6-6

                                                             Identification of Aspects and Impacts

                                                       (ISO 14001:2004, Appendix A, para A.3.1;
                                           ISO 14004:2004, para 4.3.1.2 through 4.3.1.5, and Annex A, Table A.1)
                                                                    [Added April 2005]

Almost all activities, products and services have some impact on the environment, which may occur at any or all stages of the activities, products or services life
cycle, i.e. from raw material acquisition and distribution, to use and disposal. Such impacts may be local, regional or global, short or long term, with varying
levels of significance.

Environmental Aspects

A facility/organization should identify the environmental aspects within the scope of its EMS, taking into account the inputs and outputs (both intended and
unintended) associated with its current and relevant-past activities, products and services, planned or new developments, or new or modified activities, products
and services. This process should consider normal and abnormal operating conditions, shut-down and start-up conditions, as well as reasonably foreseeable
emergency situations.

Facilities/organizations do not have to consider each product, component or raw material input individually. Grouping or categorizing activities, products and
services can assist a facility/organization in identifying common or similar environmental aspects. A grouping or category could be based on common
characteristics, such as organizational units, geographical locations, operations workflow, materials or energy use in product groups, or environmental media
affected (e.g. air, water, and land). To be useful, the size of a category should be large enough for meaningful examination, yet small enough to be clearly
understood. NOTE See ISO 14031 for examples of categories of activities, products and services.

Although there is no single approach for identifying environmental aspects, the approach selected could, for example, consider:
      a) emissions to air,
      b) releases to water,
      c) releases to land,
      d) use of raw materials and natural resources,
      e) use of energy,
      f) energy emitted, e.g. heat, radiation, vibration,
      g) waste and by-products, and
      h) physical attributes, e.g. size, shape, color, appearance.

In addition to those environmental aspects a facility/organization can control directly, a facility/organization should also consider aspects that it can influence,
e.g. those related to goods and services used by the organization and those related to products and services that it provides. Some guidance to evaluate control
and influence is provided below. However, in all circumstances it is the facility/organization that determines the degree of control and also the aspects it can
influence.



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To identify and have an understanding of its environmental aspects, a facility/organization should collect quantitative and/or qualitative data on the
characteristics of its activities, products and services such as inputs and outputs of materials or energy, processes and technology used, facilities and locations,
transportation methods and human factors (e.g. impaired vision or hearing). In addition it can be useful to collect information on
       a) cause and effect relationships between elements of its activities, products, and services and possible or actual changes to the environment,
       b) environmental concerns of interested parties, and
       c) possible environmental aspects identified in government regulations and permits, in other standards, or by industry associations, academic institutions,
           etc.

Consideration should be given to aspects related to the facility’s/organization's activities, products and services, such as
      design and development,
      manufacturing processes,
      packaging and transportation,
      environmental performance and practices of contractors and suppliers,
      waste management,
      extraction and distribution of raw materials and natural resources,
      distribution, use and end-of-life of products, and
      wildlife and biodiversity.

The control and influence over the environmental aspects of a product supplied to an organization can vary significantly, depending on the organization's market
situation and its suppliers. An organization that is responsible for its own product design can influence such aspects significantly by changing, for example, a
single input material, while an organization that needs to supply in accordance with externally determined product specifications may have little choice.

With respect to products provided, it is recognized that organizations may have limited control over the use and disposal of their products, e.g. by users, but they
can consider, where practicable, communication of proper handling and disposal mechanisms to these users in order to exert influence.

The process of identification and evaluation of environmental aspects should take into account the location of activities, cost and time to undertake the analysis,
and the availability of reliable data. The identification of environmental aspects does not require a detailed life-cycle assessment. Information already developed
for regulatory or other purposes may be used in this process.

This process of identifying and evaluating environmental aspects is not intended to change or increase an organization's legal obligations.

Possible information sources for determining environmental aspects and impacts include:

       a) general information documents, such as brochures, catalogues and annual reports,
       b) operations manuals, process flowcharts, or quality and product plans,
       c) reports from previous audits, assessments or reviews, such as initial environmental reviews or life cycle assessments,
       d) information from other management systems, such as quality or occupational health and safety,
       e) technical data reports, published analyses or studies, or lists of toxic substances,
       f) applicable legal requirements and other requirements to which the organization subscribes,
       g) codes of practice, national and international policies, guidelines and programs,
       h) purchasing data,

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       i) product specifications, product development data, Material/Chemical Safety Data Sheets (M/CSDS), or energy and material balance data,
       j) waste inventories,
       k) monitoring data,
       l) environmental permit or license applications,
       m) views of, requests from, or agreements with interested parties, and
       n) reports on emergency situations and accidents.

Significant Environmental Aspects

Significance is a relative concept; it cannot be defined in absolute terms. What is significant for one facility/organization may not be significant for another.
Evaluating significance involves applying both technical analysis and judgment by the facility/organization. The use of criteria should help a facility/organization
to establish which environmental aspects and associated impacts it considers significant. Establishing and applying such criteria should provide consistency and
reproducibility in the assessment of significance.

When establishing criteria for significance, an organization should consider the following:
      a) environmental criteria (such as scale, severity and duration of the impact, or type, size and frequency of an environmental aspect);
      b) applicable legal requirements (such as emission and discharge limits in permits or regulations, etc.);
      c) the concerns of internal and external interested parties (such as those related to organizational values, public image, noise, odor or visual degradation).

Significance criteria can be applied either to an organization's environmental aspects or to their associated impacts.

When developing information relating to its significant environmental aspects, the organization should consider the need to retain the information for historical
purposes as well as how to use it in designing and implementing its EMS.

NOTE: The determination of significant environmental aspects does not require an environmental impact assessment.

Environmental Impacts

Changes to the environment, either adverse or beneficial, that result wholly or partially from environmental aspects are called environmental impacts. The
relationship between environmental aspects and impacts is one of cause and effect. In some locations cultural heritage can be an important element of the
surroundings in which an organization operates, and therefore should be taken into account in the understanding of its environmental impacts.

Readily available information on the types of environmental impacts associated with an organization's environmental aspects may be adequate for some
facilities/organizations. Other facilities/organizations can choose to use cause-and-effect diagrams or flowcharts illustrating inputs, outputs or mass/energy
balances or other approaches such as environmental impact assessments or life cycle assessments.

Regardless of the approach chosen, the approach should be capable of recognizing
      a) positive (beneficial) as well as negative (adverse) environmental impacts,
      b) actual and potential environmental impacts,
      c) the part(s) of the environment that might be affected, such as air, water, soil, flora, fauna, cultural heritage, etc.,
      d) the characteristics of the location that might affect the impact such as local weather conditions, height of water table, soil types, etc., and

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       e) the nature of the changes to the environment (such as global vs. local issues, length of time for which the impact occurs, potential for impact to
           accumulate in strength over time).

Examples of activities, products and services and their associated environmental aspects and impacts

     Activity/Product/Service                         Aspects                     Actual and potential impacts


Activity: Road Construction

Mechanical compaction                  Emission of particulate matter to air   Pollution of air
                                       (dust)

Construction during heavy rain a       Discharge of soil and gravel to land    Additional depletion of non-
                                       and water                               renewable natural resources
                                                                               (replacement of gravel-small stones)

                                                                               Degradation of localized land

                                                                               Erosion of soil

                                                                               Pollution of water

                                                                               Degradation of wetland habitat

Activity: Boiler design (consideration of operational aspects)

Fuel efficiency                        Consumption of fuel                     Conservation of non-renewable
                                                                               energy sources (fossil fuels)

Low emissions                          Discharges to air                       Achievement of air quality
                                                                               objectives
Non hazardous materials                Disposal at end of life                 Avoidance of hazardous waste

Activity: Fossil-fuel-based boiler operations

Operation of boiler                    Consumption of heating oil              Depletion of non-renewable natural
                                                                               resources




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     Activity/Product/Service                        Aspects                    Actual and potential impacts

                                       Emission of sulfur dioxide (SO2),     Pollution of air
                                       nitrous oxide (N2O) and carbon
                                       dioxide (CO2) (i.e. greenhouse        Respiratory impacts on local
                                       gases)                                residents

                                                                             Acid rain impacts on surface water

                                                                             Global warming and climate change

                                       Discharge of heated water             Changes to water quality (e.g.
                                                                             temperature)

Storage of boiler fuel in              Discharge of oil to landa             Pollution of soil
underground tanks
                                                                             Pollution of groundwater

Delivery and transfer of heating oil   Uncontrolled release of heating oil   Pollution of surface water
                                       to surface water drainb
                                                                             Bioaccumulation of toxic substances
                                                                             in fauna

Activity: Agriculture — Grain cultivation

In field operations during growth      Consumption of water                  Depletion of groundwater supply
stage/phase
                                       Use of pesticides                     Pollution of soil

                                                                             Bioaccumulation of toxic substances
                                                                             in fauna resulting in chronic adverse
                                                                             health effects or species loss

                                       Emission of methane (i.e.             Global warming and climate change
                                       greenhouse gas)

Activity: Wastewater management

Agro food industry wastewater          Generation of sludge (which is        Soil correction through the addition
treatment                              applied in agriculture)               of nutrientsd


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                                                                                                                     Other Environmental Issues
     Activity/Product/Service                         Aspects                Actual and potential impacts

Product: Printer toner cartridge

Refillable toner cartridge             Use of raw materials               Conservation of resources

End of life — disposal                 Generation of solid wastec         Land use

                                       Recovery and reuse of components   Conservation of natural resources

Product: Air conditioner
Consumer operation of unit             Use of electricityc                Depletion of non-renewable natural
                                                                          resources

End of life – disposal                 Generation of solid wastec         Land use

                                       Recovery and reuse of components   Conservation of natural resources

Service: Maintenance and repair service

Chemical handling and use              Uncontrolled release during        Pollution of air
                                       emergency b
                                                                          Pollution of soil

                                                                          Injury to humans

Subcontracted air conditioner repair   Release of ozone-depleting         Ozone depletion
                                       substances (i.e. refrigerant)a

Service: Transportation and distribution of goods and products

Fleet operation                        Consumption of fuel                Depletion of non-renewable fossil
                                                                          fuels

                                       Emission of oxides of nitrogen     Pollution of air – ozone production –
                                       (NOx)                              smog

                                                                          Global warming and climate change




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     Activity/Product/Service                            Aspects                   Actual and potential impacts

                                         Generation of noise                    Discomfort or inconvenience to
                                                                                local residents

Routine fleet maintenance (including     Emission of oxides of nitrogen         Achievement of air quality
oil changes)                             (NOx)                                  objectives

                                         Generation of waste oil                Pollution of soil

a Abnormal conditions.
b Emergency conditions.
c Organization may be able to ―influence‖ aspect.
d Beneficial impact.




                                                                          Appendix 6-7

                      Examples of Activities, Products and Services and Their Associated Environmental Aspects, Objectives, Targets,
                                     Programs, Indicators, Operational Control, and Monitoring and Measurement.

                                                               (ISO 14004:2004, Annex A, Table A.2)
                                                                       [Added April 2005]

Aspects                 Objectives                Targets              Programs                Indicators             Operational Control   Monitoring and
                                                                                                                                            Measurement
Activity: Operation of fossil fuel-based boiler

Consumption of          Reduce the                Reduction of the     Installation of more    • Project plan         • Procedures for      • Quarterly
heating oil             consumption of            consumption of       efficient fuel          milestones             installation of       evaluation of
                        nonrenewable              heating oil (based   burners                                        modified burners      progress on project
                        resources                 on current year                              • Consumption of                             plan
                                                  consumption) by                              heating oil per        • Procedures for
                                                  20% within 1 year                            working hour of the    documenting and       • Monthly tracking
                                                                                               boiler                 recording oil         of oil consumption
                                                                                                                      consumption           rates
Discharge of heated     Minimize the              Reduce mean daily    Facility and design     • Daily mean           • Water quality       • Continuous
water                   negative impacts to       temperature of       engineers re-           temperature of water   sampling and          monitoring of

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                                                                                                                                     Other Environmental Issues
Aspects                Objectives             Targets                Programs                Indicators              Operational Control      Monitoring and
                                                                                                                                              Measurement
                       watershed quality      discharge water by 1   engineer operations     discharge               analysis procedures      temperature of
                       from elevated          °C by 2008             to extract and re-use                                                    discharge water
                       effluent temperature                          heat from               • Watershed water       • Sampling plan of
                                                                     wastewater (i.e. co-    quality parameters      marine organisms         • Quarterly
                                                                     generation)                                                              monitoring of
                                                                                             • Number and            • Co-generation          watershed water
                                                                                             diversity of marine     operational              quality
                                                                                             organisms               procedures

                                                                                                                     • Engineering
                                                                                                                     controls
Product: Air conditioner (consumer operation of unit and end of life — Disposal)

Use of electricity     Encourage the          Reduce the             Educate consumer        • Increased             • Design of effective    Survey of users
                       consumer to use less   operating              on impacts of           customer interest in    product material
                       energy                 temperature by 5%      excessive energy        energy use
                                              based on last year's   use through                                     • Use of electrical
                                              operating              distribution of         • Increased             energy
                                              temperature by end     energy-efficient        customer interest in
                                              of current year        materials with          new energy efficient    • Consideration of
                                                                     product (e.g. cost      products                customer energy
                                                                     savings, reduced                                efficiency requests
                                                                     environmental                                   in new product
                                                                     impacts)                                        design

Generation of solid    Reduce consumer        Achieve 35%            • Redesign product      • Quantity of           • Design control         • Quarterly
waste                  solid waste            reduction in           packaging               packaging material      procedures               monitoring of
                       generation from        packaging material     (Engineering Dept.,     per unit                                         quantity of
                       disposal of            for current product    6 months)                                       • Product packaging      packaging material
                       packaging by           line by 2008                                   • % reduction in        procedures               used (purchased
                       reducing quantity of                          • Implement             packaging material                               minus scrap)
                       packaging materials                           production changes      used for product line
                       used                                          (6 months)                                                               • Product units
                                                                                             • Estimated                                      shipped in product
                                                                     • Test run and full     reduction in                                     line
                                                                     production              consumer solid
                                                                                             waste generation
                                                                                             volume/unit


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                                                                                                                                        Other Environmental Issues
Aspects                Objectives               Targets                Programs              Indicators              Operational Control     Monitoring and
                                                                                                                                             Measurement
Service: Transportation and distribution of goods and products (fleet maintenance)

Emission of oxides     Increase positive        Achieve 25%            Identify key          • % on-time             • Maintenance           • Tracking of
of nitrogen (NOx)      impact on air quality    reduction of NOx       maintenance           maintenance             procedures              maintenance
                       by improving             emissions by 2008      parameters for                                                        frequency versus
                       effectiveness of fleet                          reduction             • NOx emissions/km      • Training of           schedule
                       maintenance                                                                                   maintenance
                                                                       • Revise                                      technicians             • Monitoring of
                                                                       maintenance                                                           vehicle fuel
                                                                       program to                                    • Computerized          efficiency
                                                                       incorporate key                               notification of
                                                                       reduction tasks                               scheduled               • Quarterly testing
                                                                                                                     maintenance             of vehicle emissions
                                                                       • Optimize fleet
                                                                       maintenance                                                           • Annual assessment
                                                                       schedule through                                                      of reductions
                                                                       computer program                                                      achieved

Generation of waste    Manage oily wastes       Achieve 100%           Develop and           • % of service centre   • Waste                 • Monitoring of
oil                    in conformity with       conformity with oily   implement waste       employees trained       management              service-centre
                       requirements             waste disposal         management            • Number of waste       procedures              employee training
                                                requirements at        training program at   disposal                                        conducted
                                                service centers        service centers       nonconformities         • Training program
                                                within one year                                                      for service centre      • Tracking of oily
                                                                                             • % of oily waste       employees               waste disposal
                                                                                             disposed per                                    quantities and
                                                                                             requirements                                    disposal methods

                                                                                                                                             • Quarterly
                                                                                                                                             assessments of oily
                                                                                                                                             waste management
                                                                                                                                             practices




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                                                  Appendix 6-8

                    Examples of Environmental Training That Can Be Provided by a Facility
                                        (ISO 14004:2004, para 4.4.2)
                                            [Added April 2005]


         Type of Training                          Audience                                Purpose
Raising awareness of the importance    Senior managers                        To gain commitment and alignment
of environmental management                                                   to the organization's environmental
                                                                              policy

Raising   general      environmental   All employees                          To gain commitment to the
awareness                                                                     environmental policy, objectives and
                                                                              targets of the organization and instill
                                                                              a sense of individual responsibility

Training in EMS requirements           Persons with responsibilities in the   To instruct on how to meet
                                       EMS                                    requirements, conduct procedures,
                                                                              etc.

Skills enhancement                     Employees with        environmental    To improve performance in areas of
                                       responsibilities                       the organization, e.g. operations,
                                                                              research and development, and
                                                                              engineering

Compliance training                    Employees whose actions can affect     To achieve compliance with
                                       compliance                             regulatory training requirements and
                                                                              improve compliance with applicable
                                                                              legal requirements and other
                                                                              requirements      to    which     the
                                                                              organization subscribes.




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