# Presentation: 247966

## ISO 14001 EMS Surveillance Audit Briefing

**Presented to Science Council**
**George Goode, EMS Program Manager **
**5/14/02**

**P2C4**

## Purpose

**	****Provide schedule for upcoming EMS Surveillance Audit and overview of what managers and groups need to know**

## 1st EMS Surveillance Audit

- Audit scheduled for June 4-7 (Tues-Fri)
- Registrar: NSF-Intn’l Strategic Registration, Ltd
- Two Auditors onsite for four days
- Surveillance Audit Scope: ISO 14001
- Checking to see if we’re maintaining the EMS
- “...review of select sitewide programs, sampling of facilities/operations...”
- “verification of corrective actions taken by BNL in response to minor nonconformances identified during registration.”

## ISO 14001 EMS 17 “Elements”

**ENVIRONMENTAL POLICY**
**PLANNING**
- _Aspects & Impacts_
- Legal & Other Requirements
- _Objectives & Targets_
- _Environmental Management Programs_
***Pollution Prevention***
**IMPLEMENTATION**
- _Structure & Responsibilities__* *_
- _Training, Awareness & Competence_
- _Communications_
***Community Outreach***

- EMS Documentation
- Document Control
- _Operational Control_
- Emergency Preparedness & Response
**CHECKING/CORRECTIVE ACTION**
- _Monitoring & Measurement_
- _Nonconformance & Corrective/Preventative Actions_
- Records
- _Environmental Audits_
***Compliance Assurance***
_**MANAGEMENT REVIEW**_
- Continuous Improvement

## Audit Scope

**Facility Audit Focus is on**
- Environmental Aspects
- Objectives & Targets and EMPs (action plans)
- Operational Controls (OCFs)
- Monitoring and Measurement
- Non-Conformance, Corrective/Preventive Action
- EMS Audits and Management Review
**Management Interview Focus is on**
- Objectives & Targets, Structure & Responsibility, Communication
**The Lucky few:**
- ESHQ-ESD, CAD, EM, NSLS, and Plant Eng (limited)
- P. Paul, T. Sheridan, DOE-BAO interviews

## EMS Audit Prep: Policy

- Know 5 Commitments in the BNL Environmental Stewardship Policy ...*and how they apply to your work*
***Pollution Prevention*** initiatives
- that you are implementing
- Regulatory ***Compliance*** requirements
- that apply to your operations
- Spills, ***Clean-Up*** or legacy issues
- Involvement in ***Community Outreach***
***Improvements*** in Environmental Programs
- Caps on Beam Stops, Tank upgrades
- Groundwater protection & monitoring
- Sewage Treatment Plant upgrades

***BNL’s ***
***Environmental ***
***Commitments***

***P******2******C******4***

## Know your Organization’s “Environmental Aspects”
Identified and evaluated via the Work Planning Process
Experimental Reviews (1.3.5)
Non-Routine Work Planning (1.3.6)
Process Assessments of industrial processes
Summarized on Aspects Spreadsheet
Waste Generation: Hazardous, Radioactive, Mixed, Medical, Industrial
Radioactive & Non-radioactive Air Emissions and Liquid Effluents
Energy use, water consumption, noise
See subject area https://sbms.bnl.gov/standard/0m/0m00t011.htm
Operational Controls applied to significant aspects
Documented on Operational Control Forms
Managed in accordance with Lab requirements (SBMS Subject Areas, permits, etc.
Other internal controls, e.g.,  Preventive maintenance, Dept. procedures, etc

- Identified and evaluated via the Work Planning Process
- Experimental Reviews (1.3.5)
- Non-Routine Work Planning (1.3.6)
- Process Assessments of industrial processes
- Summarized on Aspects Spreadsheet
- Waste Generation: Hazardous, Radioactive, Mixed, Medical, Industrial
- Radioactive & Non-radioactive Air Emissions and Liquid Effluents
- Energy use, water consumption, noise
- See subject area https://sbms.bnl.gov/standard/0m/0m00t011.htm
**Operational Controls** applied to significant aspects
- Documented on Operational Control Forms
- Managed in accordance with Lab requirements (SBMS Subject Areas, permits, etc.
- Other internal controls, e.g.,  Preventive maintenance, Dept. procedures, etc

**EMS Audit Prep: Environmental Aspects & Impacts and Operational Controls**

## Know your Organization’s “Environmental Objectives and Targets”...
Flow down from Laboratory Critical Outcomes, Objectives, Performance Measures (CO/O/PM) and ESD Environmental Priorities
Based on BNL Policy Commitments (P2C4)
Submit  Pollution Prevention proposals to the P2 Council
Compliance with Environmental requirements
Close out Facility Review Disposition Project issues
Other organizational specific: community outreach, cleanup, etc

...and your action plans to achieve your objectives
also linked to Laboratory CO/O/PM
assigns responsibility, resources, and milestones
documented as “Environmental Management Program Plan” or in Self Assessment Plan

- Flow down from Laboratory **Critical Outcomes**, Objectives, Performance Measures (CO/O/PM) and ESD **Environmental Priorities**
- Based on BNL Policy Commitments (P2C4)
- Submit  Pollution Prevention proposals to the P2 Council
- Compliance with Environmental requirements
- Close out Facility Review Disposition Project issues
- Other organizational specific: community outreach, cleanup, etc
- ...and your **action plans** to achieve your objectives
- also linked to Laboratory CO/O/PM
- assigns responsibility, resources, and milestones
- documented as “Environmental Management Program Plan” or in Self Assessment Plan

**EMS Audit Prep: Objectives & Targets, and Action Plans**

## EMS program manager = George Goode
Know your Management Rep on EMS
responsible for coordinating EMS implementation and reporting progress and performance to management
Know your Environmental Responsibilities (R2A2)
Comply with Laboratory policies, standards, and procedures, and regulatory requirements.
Maintain awareness of environmental impact of work, and apply pollution prevention and waste minimization techniques.
Identify potential hazards, environmental concerns, and unsafe conditions or practices in work or at work site, and implement or suggest controls to minimize risk.
Respond to emergency situations, alarms, or occurrence in an appropriate manner.
Know how environmental issues are communicated

- Know your Management Rep on EMS
- responsible for coordinating EMS implementation and reporting progress and performance to management
- Know your Environmental Responsibilities (R2A2)
*Comply with Laboratory policies, standards, and procedures, and regulatory requirements.*
*Maintain awareness of environmental impact of work, and apply pollution prevention and waste minimization techniques.*
*Identify potential hazards, environmental concerns, and unsafe conditions or practices in work or at work site, and implement or suggest controls to minimize risk.*
*Respond to emergency situations, alarms, or occurrence in an appropriate manner.*
- Know how environmental issues are communicated

**EMS Audit Prep: Structure & Responsibility **

## Know about your EMS Audits and Other E-Assessments
included in your Self Assessment Plan
EMS Audit
regulatory compliance assessments
via Tier I inspections
other focused compliance audits (Drinking Water, Air, Work Planning, PCB, Radioactive Waste)
method to track corrective actions to closure (Use Family ATS!!)
Ensure follow up and closure
Participate in your Management Review
“Annual Report” of environmental programs and performance 
Senior manager involvement is a requirement
role is to judge the effectiveness, suitability, and adequacy of their EMS
Make recommendations for improvement
Follow up on suggestions from minutes

- included in your Self Assessment Plan
- EMS Audit
- regulatory compliance assessments
- via Tier I inspections
- other focused compliance audits (Drinking Water, Air, Work Planning, PCB, Radioactive Waste)
- method to track corrective actions to closure (Use Family ATS!!)
- Ensure follow up and closure
**Participate in your Management Review**
- “Annual Report” of environmental programs and performance
- Senior manager involvement is a requirement
- role is to judge the effectiveness, suitability, and adequacy of their EMS
- Make recommendations for improvement
- Follow up on suggestions from minutes

**EMS Audit Prep: EMS Assessments & Management Review**

## Auditee Tips and Techniques

- Answer the question posed
- Take time to think and formulate your response
- If you don’t understand the question ask for clarification
- If it is a Yes / No question, answer “yes” or “no”
- If you want someone present, request it
- It’s okay to say “I don’t know”
- Don’t oversell your expertise
- If you are not the key contact on the subject, defer to others
- Don’t answer questions if you are not personally knowledgeable

## Auditee Tips and Techniques

**Silence--do not feel obliged to fill void with verbiage**
- Don’t volunteer additional / tangential information
**Be Honest, Friendly, Polite, Respectful, and Professional**
- Be truthful about problems, but
- be sure to mention actions are planned or taken to correct problem
**Portray a Positive Attitude in Support of BNL changes**
- This is not a forum for airing your complaints
- use available channels--follow management chain
**Audits = findings = resources**
- Focus our resources on our Self Assessment findings & priority issues

## Frequently Asked Questions That You Can Expect An EMS Auditor To Ask

- EMS Training Forum

## Question # 1

**What is the official EMS Policy at BNL?**

-  _**Pollution prevention**_, waste minimization and resource conservation
-  Environmental _**compliance**_
-  Environmental _**clean up**_
** **_**Community outreach**_
_** **__**Continual improvement**_

**P2C4**

## Question # 2

**What do you know about EMS ?**

-  The environmental management system is the process/systems that we have implemented to support the BNL EMS Policy

## Question # 3

**What are the environmental aspects**
**related to your work ?**

-  The list of BNL environmental aspects includes:
- Regulated Industrial Waste	Sensitive/Endangered Species
- Hazardous Waste		 	Sensitive Habitats
- Radioactive Waste		Noise
- Mixed Waste			Historical Contamination (soil, GW)
- Regulated Medical Waste		Soil Activation
- Atmospheric Discharges		Transuranic Waste
- Liquid Discharges			 Water Consumption
- Storage & Use Of Chemicals	 Power Consumption
- Storage & Use of Radioactive Material

-  An environmental aspect is anything that can interact
- with the environment, either positively or negatively

## Question # 4

**How do you avoid potential environmental accidents in your work ?**

-  The BNL Work Planning System
-  By following internal SOPs

## Question # 5

**How do you prevent pollution in your daily work ?**

-  The BNL Work Planning System
- P2 is integrated into experimental reviews and other work planning processes
-  Participation in the BNL Recycling Program
- Managing hazardous and radioactive wastes according to BNL requirements.
- Practicing E-ALARA

## Question # 6

**What response / action would you take in the event of an environmental emergency ?**

-  Call ext - 2222 or ext – 911
-  Follow the Emergency Procedures

## Question # 7

**How are you made aware of new environmental **
**requirements that affect your daily work?**

-  Through your supervisor or the ECR

## Question # 8

**Are there environmental objectives and targets associated with your work? What is your role in achieving them?**

-  All staff who work in areas that have the potential for
- significant impact on the environment have been notified
- and trained

## Question # 9

**What are you environmental R2A2’s?**

** **_**Comply**_ with Laboratory policies, and  requirements
** **_**Implement**_ pollution prevention and waste minimization
** **_**Identify**_ potential hazards, and unsafe condition
** **_**Use**_ the Stop Work Order process
** **_**Respond**_ to emergencies and alarms

## Question # 10

**What environmental safe-guards (operational controls) do you have in your area? **

-  Operational Controls are routine work processes, which safeguard against faulty operations and environmental accidents
-   Examples:
-  Work Planning processes
-  Tier I inspections
-  Pre-job briefings
-  Preventative Maintenance

## Question # 11

**Are records available to show the operational controls are being maintained?**

-  Know what environmental records you keep
-  Some typical records in your area may be:
- Hazardous Waste Control Forms, Posted Air
- Permits, Logbooks, Work Planning Records,
- Inspection Checklists

## Question # 12

**Are contractors that perform work in your area made aware of the operational controls?**

-  The BNL work planning system captures the training
- requirements for contractors - if specific environmental
- training is required, then it will be noted in the work
- Planning

## Question # 13

**Are there any environmental measurements taken in your area that require calibrated equipment ? Is the equipment calibrated?**

-  The Radiological Control Group is responsible for maintaining survey instruments calibrated
- Be aware of any environmental monitoring equipment specific to your operations that requires periodic calibration

## Question # 14

**Is preventative maintenance performed on equipment ?  Are back-up systems available to provide continuous control of operations?**

-  Examples of equipment that may require periodic maintenance include leak detection equipment on storage tanks, air pollution control devices (HEPA filters), etc.
-   An example of continuous control would be the use of
- uninterruptible power supplies to back up controls for monitoring
- the flow and pressure in cooling water systems

## Question # 15

**How would you document an environmental **
**nonconformance?**

-  Follow internal procedures.
- Contact your Supervisor, ESH Coordinator, or EMS representative.