Now let's discuss the next step of the EMS process, checking and corrective action. Checking evaluates how you are doing and corrective action responds to any issues you identify. Questions to ask include:
If you properly set up the tracking mechanisms during the planning and implementation steps, checking only represents making sure everything is being done and evaluating results. This is where it all starts to tie together.
Checking and Corrective Action has four elements:
The first element in this phase is monitoring and measurement. This means that you track specific parameters that help:
At this point, be sure to focus on what you found was significant during the initial planning phase. Examples of items that you might measure include:
You may want to use databases to track production data. Employees can use a computer or complete daily or weekly logs that are then provided to administrative personnel for data entry. It's a good amount of work, but it supports the production quality program as well as the EMS.
You might ask who looks at all of this data and how is it used. Supervisors and managers use it for a variety of purposes, including determining if the company is in conformance with the EMS. The data is also useful to plan for purchasing raw materials, staffing, and similar items.
You could also post key data on a bulletin board to show how well the company is doing; sharing information with staff helps keep the EMS moving in a positive direction.
The image to the right shows an example of an EMS tracking chart for production lines. The chart shows water use normalized per square foot of parts plated.
No EMS is perfect. You will probably identify problems with your system (especially in the early phases) through audits, measurement, or other activities. In addition, your EMS will need to change as your facility adapts and grows.
Examples of non-conformance include:
To deal with system deficiencies, your facility needs a process to ensure:
EMS nonconformities and other system deficiencies, including legal noncompliance, should be analyzed to detect patterns or trends. Identifying trends allows you to anticipate and prevent future problems.
Key steps to identifying trends include:
Focus on correcting and preventing problems. Preventing problems is generally cheaper than fixing them after they occur. Start thinking about problems as opportunities to improve!
You will need to establish a method to determine the root causes of failing to conform. In some cases, the cause may be obvious, and in others, obscure.
EMS problems typically include:
Root cause analysis is a process by which you can identify causes and preventive actions. For instance, if a spill occurs several times in your raw material transfer area, you would attempt to identify the root cause of the spill occurring so that you could address the cause and prevent the spill in the future.
Root cause analysis can be used to describe a very formal analysis process, however, it also can mean something simpler, looking past the obvious or immediate reason for a nonconformance to determine why the nonconformance occurred.
The root cause diagram shown to the right will help you organize your thoughts when you analyze your facility’s potential for environmental impact. This analysis can be done by one person or by a group, with one person writing down the ideas produced.
For example, elements of work practices might contribute to the labor component. This diagram is a device to help organize the analysis of the cause of potential environmental impacts. Use it if it helps, but don't get hung up on trying to make it work.
Once you document a problem with respect to meeting targets, you must resolve it. Take action as quickly as possible. Make sure assigned responsibilities for actions and schedules are clear so that correction occurs in a timely manner.
Employees in the facility may recognize the need for corrective action and provide good ideas for solving problems. Find ways to get them involved in the improvement process. It’s important to determine whether a lapse is temporary or due to some flaw in the procedures or controls. For this reason, communicate any findings to employees and provide any follow-up training for changes in the procedures that may result.
The following is a checklist to help complete corrective action. Have you:
Here are some things to think about to expedite the determination of your facility’s corrective and preventive action process:
Remember, corrective actions should:
The checking and corrective action phase also includes records. As we discussed earlier, records are one level of EMS documentation. Records are objective evidence that prove EMS activities have been performed or that desired results have been achieved.
Records are objective and provide evidence of the results of following a procedure. For example, let’s say you have an Operational Control Procedure for a wastewater treatment plant. It states what you will do when you treat wastewater and how you will do it. The wastewater treatment system log sheets and database document that the procedure is followed and track your results; this comprises the record for that procedure.
Basically, records document that you are doing what you said you would do within your EMS, including:
When you audit the EMS, records are one type of documentation that will be reviewed.
Records provide a means of tracking the history of our EMS progress. Because they are part of the EMS and will be audited, EMS records must be kept in good order and should be readily retrievable. That is one reason that records are addressed in the EMS Document Control Procedure we discussed earlier. This brings us to the last item in the Checking and Corrective Action phase, EMS Audits.
Here’s a list of sample records that might be appropriate for your facility:
EMS audits check that the EMS system is implemented as planned. EMS audits are conducted internally or by outside parties to make sure the system is working or to support criteria related to certifications or participation in voluntary programs.
Compliance audits: An organization should periodically evaluate its compliance with the EPA, legal and other requirements applicable to its environmental aspects to ensure the commitment to compliance stated in its environmental policy statement. We encourage you to use this EMS Compliance Assessments Procedure (PDF) as a model for your own audit procedure.
Conformance audits: It should also conduct periodic conformance audits of its EMS to ensure that the system is structured and functioning in accordance with the ISO 14001 standard. You can open and use this EMS Conformance Audit Procedure (PDF) as a model for your own audit procedure.
Facilities which choose to implement an EMS that conforms to the ISO 14001 Standard can receive a formal registration. EMS auditors working for an organization that is accredited by ISO's Registrar Accreditation Board (RAB) will audit the facility's EMS to document that the EMS is implemented in conformance with the requirements of the standard. Once a facility passes the audit, they can claim that they are an ISO 14001 registered organization. The registration may help you compete with other companies in your industry. For example, most of the large automakers require that their suppliers are ISO 14001 registered.
If you have the time (1:20:51) take a look the two webinars below on EMS Auditing to Improve your EMS and Achieve Organizational Goals by the Washington State Department of Ecology.
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