# Presentation: 549405

## Federal Organizational-Level EMS WorkgroupOverview and Status

- James Wozniak (DLA) Steve Woodbury (DOE)

- Federal Environmental Symposium East & West
- June 3 & 17, 2008

## Overview

- New language in E.O. 13423
- Typology of EMSs(What distinct types of EMS exist?)
- Questions and Answers
- Auditing

## New Language in EO 13423

- EO 13148 previously required ' **“at all appropriate facilities”**
- The Interagency Workgroup clarified this definition to include “organizations”
- EO 13423 requires ' **“at all appropriate organizational levels”**

## Confusion of Terminology

-    Workgroup members used many different terms
- We used *different* terms for the *same* thing
- We used the *same* term for *different *things

- Facility EMS

**Site EMS**

**Enterprise EMS**

**Corporate EMS**

- Agency-Wide EMS

**Office EMS**

*Multi-Site EMS*

- Program EMS

- Umbrella EMS

**Headquarters EMS**

## The EMS Typology

**Facility**

**Multi-Site Organization**

**Higher-Tier**

## Facility EMS

- Other terms used:
- appropriate facility
- site EMS
- single-site  organization EMS
- office EMS

**EMS**

**Notes:**
This is the traditional facility-level or site-level EMS.  The scope is typically defined by a single organization, with its activities defined by a discrete “fence-line.” 

This could be a ‘headquarters facility’ EMS, if the emphasis is on the facility operations, as opposed to the headquarters programmatic functions.

## Multi-Site Organization EMS

- Other terms used:
- enterprise EMS
- corporate EMS
- agency-wide EMS
- multi-site EMS
- program EMS

**EMS**

**Notes:**
The scope of this EMS is a broader organization, which encompasses multiple facilities or operating units (or organizations).  
[They need not each constitute an “appropriate facility.”]  
The key attribute is that the significant environmental aspects of the activities, products and services of all the units are managed as part of a single EMS.

Functionally, the EMS still has to reach down to workers at all the units and activities encompassed by the organization.

Audit of the EMS includes an audit at an appropriate sampling of sub-units. 

## Higher-Tier EMS

**HIGHER-TIER EMS**

- Other terms used:
- umbrella EMS
- corporate EMS
- agency-wide EMS
- headquarters EMS
- program EMS

**Notes:**
Here, individual facilities (or organizations) maintain their own '.  However, an additional EMS is created to address issues which are best addressed at a higher level of the organization. 

The scope of the ‘top tier’ EMS is those issues best addressed at the higher level of the organization;  it does not encompass all ‘facility-level’ issues.

The scope and the interfaces (roles and responsibilities) between the levels need to be defined consistently from both levels.

Each EMS needs to be audited.

## Questions and Answers Document

- The Workgroup is developing a Q&A document
- Draft questions have been circulated for review
- Will include examples of how different Federal agencies have structured their EMSs will be included

## Auditing a Multi-Site Organization EMS

- The International Accreditation Forum provides requirements and guidelines for auditor-certification organizations.
- IAF has issued requirements for the certification of multiple sites based on sampling  [IAF MD 1:2007].  The document defines (among other things)
- ‘multi-site organization’
- when a multi-site organization is eligible for sampling
- sampling methodology and sample sizes

## Summary of Workgroup Activities

- Developed a typology of EMSs
- will include examples from Federal agencies
- Developing a Q & A document
- Reviewing implications of multi-site EMSs for EMS audits

## For Further Information Contact:

- James WozniakDefense Logistics Agency703-767-6277
-     _james.wozniak@dla.mil_
-  Steven WoodburyDepartment of Energy202-586-4371_steven.woodbury@hq.doe.gov_

- Federal Organizational-Level EMS Workgroup

- BACKUP SLIDES

## Certification of Multiple Sites Based on Sampling

- Mandatory Document issued by the International Accreditation Foundation
- Establishes requirements for certifying audit organizations
- Provides a useful benchmark

## Multi-Site Organization

*Multi-site organization* – an organization having
- an identified central function  (hereafter referred to as a central office – but not necessarily the headquarters of the organization) at which certain activities are planned, controlled or managed and
- a network of local offices of branches (sites) at which such activities are fully or partially carried out.
- – IAF MD1:2007 Multiple Site Sampling, § 1.5

## Eligibility for Sampling

- “Normally ... audits ... should take place at every site of the organization that is to be covered by the certification”
- However, sampling may be used  “where an organization’s activity subject to certification is carried out
- in a similar manner at different sites,
- all under the organization’s authority and control”
- – IAF MD1:2007, § 0.2

## Eligibility for Sampling (cont.)

- Processes at all the sites must be substantially of the same kind, and have to be operated to similar methods and procedures  [§3.0.1]
- Where processes in each location are not similar (but are clearly linked) the sampling plan shall include at least one example of each process [§3.0.1]
- Management system shall be under a centrally controlled and administered plan and be subject to central management review  [§3.0.3]
- Not all organizations meeting definition of “multi-site organization” are eligible for sampling [§3.0.6]

## Factors Which may Restrict Use of Sampling

- Risk or complexity of activities
- Size of sites
- Variations in local implementation of the management system
- – [§3.0.8]

## Partly selective, to include a representative range of sites [§5.1.1]
At least 25% selected at random [§5.1.2]
Selection may include considerations such as  [§5.1.4]
Results of previous internal audits and management reviews
Records of complaints and other relevant aspects of corrective and preventive action
Variations in the size of sites
Variations in work procedures
Complexity of the management system and processes conducted at the sites
Environmental issues and extent of aspects and associated impacts 
Differences in regulatory requirements
Geographical dispersion

- At least 25% selected at random [§5.1.2]
- Selection may include considerations such as  [§5.1.4]
- Results of previous internal audits and management reviews
- Records of complaints and other relevant aspects of corrective and preventive action
- Variations in the size of sites
- Variations in work procedures
- Complexity of the management system and processes conducted at the sites
- Environmental issues and extent of aspects and associated impacts
- Differences in regulatory requirements
- Geographical dispersion

- Selection of Sample

## Minimum Size of Sample

- For low-to medium risk activity, with <50 employees at each of n sites  [§5.2.3]
- Initial audit:  square root of the number of remote sites   s = √ n   (rounded up)
- Surveillance audit:  s = 0.6 √ n  (rounded up)
- Re-certification audit: same as initial audit (where management system has proved effective, may be reduced to s = 0.8 √ n  (rounded up)
- Central office shall be audited during each audit, and annually as part of surveillance  [§5.2.5]

##  Size or frequency of sample shall be increased if risk analysis indicates special circumstances in respect of factors such as:
Size of site and number of employees (e.g. > 50 employees at a site)
Complexity or risk level of the activity and the management system
Variations in working practices
Significance and extent of aspects and associated impacts 
Records of complaints and other relevant aspects of corrective and preventive action
Results of internal audits and management review
– [§ 5.2.6]		

- Size of site and number of employees (e.g. > 50 employees at a site)
- Complexity or risk level of the activity and the management system
- Variations in working practices
- Significance and extent of aspects and associated impacts
- Records of complaints and other relevant aspects of corrective and preventive action
- Results of internal audits and management review
- – [§ 5.2.6]

- When to Use a Larger Sample

## When the organization has a hierarchical system of branches (e.g. head (central) office, national offices, regional offices, local branches) the sampling model defined above applies to each level
Example:

- 4 national offices
- 27 regional office
- 1700 local branches

- visited at each audit cycle
- s = 2;  minimum 1 at random
- s = 6;  minimum 2 at random
- s = 42;  minimum 11 at random
- – [§ 5.2.7]

- When the organization has a hierarchical system of branches (e.g. head (central) office, national offices, regional offices, local branches) the sampling model defined above applies to *each level*
- Example:

- Sampling A Hierarchical Organization