ISO14001and Environmental Management Systems

How to Set up an Environmental Management System that Includes Spill and Firewater Containment to ISO14001 Standards. Plus how to make it valid all the year round.

ISO14001: 2004, like ISO9001 is not a regulation or legally required standard but a set of formal documented procedures that make up an environmental management system (EMS) that is subject to a third party audit.

A company that has been accredited under ISO14001 and publishes this fact is making a public statement to investors, shareholders and stakeholders alike that the company is doing its best and is actively and demonstrably striving to improve its care of the environment, its impact on its neighbours and its sustainability.

As a consequence any business that operates under ISO14001 should pose a lower risk to the environment, investors, lenders, insurers and employees alike as it should be well equipped with tools and procedures to either eliminate or mitigate any incident to prevent it from becoming a disaster and must work under all the year round, 24/7 and under all expected weather conditions including snow and ice.

The Model

The model used by the standard can be summarised as a continuous as Plan-Do-Check-Act (PDCA) sequence where the cycle never stops and continuous improvement is always expected.

Whereby:

Plan: establish the risks, objectives and processes necessary to deliver results in accordance with the organisation's environmental policy to meet the essential requirements legislation such as the Environmental Liability Directive plus your businesses own goals.

Do: implement the processes, by way of example, installing a fully automatic spill and firewater containment system to give your site 24/7 protection.

Check: monitor and measure processes against environmental policy, objectives, targets, legal and other requirements, and report the results. By way of example this could include the testing of the spill and firewater containment system with a simulated incident and report on its effectiveness.

Act: take actions to continually improve performance of the environmental management system. This could by way of example be the addition of an automatic reporting system that informs key staff out of hours about an incident on the site.

What is Required to achieve ISO14001

The following is a rough guide that we have compiled to assist newcomers to ISO14001 and EMS. The advice we give is given in good faith and will be your first step to obtaining ISO14001 accreditation.  We advise that those serious about gaining formal accreditation should register with an approved certification body such as the BSI.

As with all standards, ISO14001 requires you to formally document key areas of your business with regards to environmental policy and to keep documentary evidence (records) that demonstrate you are operating according to the requirements of the standard. The standard itself takes a risk assessment based approach to environmental management.

Finally, remember to implement and to maintain an EMS to ISO14001 you will need to take as a minimum the following steps, all of which will require resources, dedication and commitment.

1. Build an understanding of your environmental impacts and performance.

Questions you should be asking yourself include:

What are your waste streams?

This would assist you in minimising waste and identifying risks associated with stored materials. For example WEEE is a major hazard and if stored in any quantity poses a    major risk of fire and hence generates a requirement to contain the subsequent firewater.

What regulations and legal requirements do you have to meet?

This would include H&S and the Environmental Liability Directive as a bare minimum. You need to look at all your processes and identify the risks. Do you have a car park, if so there should be an oil interceptor that will pose a risk! Do you have liquid deliveries of foodstuffs, heating oils etc, if so there is a risk of a spill and this could enter the drainage system? Do you store flammable materials, this could be anything from paper through to mattresses? If yes then you have a major fire hazard and a risk of firewater that must be contained all the year round under all weather conditions.

How much energy do you use?

Is there any waste? Do you have a monitoring and targeting package in place, if not you may need to install one.

What environmental consideration is given to the design of your products, services and the purchasing of raw materials?

Do you purchase locally - if not you should consider the carbon footprint of global shipping? Do your processes use chemicals that if spilt pose a hazard to the environment? If so you may need a spill containment system. All EIL products are designed and manufactured in the UK.

What do your neighbours think of your business?

Containment not only applies to spills and firewater! It also includes noise, smoke, vibration, radiation, light, bio-hazards and dust. We can certainly contain your spills, firewater and even water borne bio-hazards but you may have to seek additional assistance from other suppliers to keep your neighbours happy.

2. Write a policy statement that communicates your environmental values to Stakeholders - it needs to be placed in public and if you are doing things right you have nothing to worry about!

Your policy statement needs to be consistent, comprehensive and appropriate with the nature and size of you business.

You policy also needs to include a commitment to continual improvement and prevention of pollution and its mitigation. A classic example of this is a policy that includes methodology to proactively contain spills and firewater on site and then to arrange for their safe disposal.

Your must in Include a commitment to comply with any legal requirements or other commitments relating to the environment. Ignorance of legal duties is no excuse and keeping yourself abreast of new and changes in legalisation is a duty. How many of you knew about the ELD before reading this article, our guess is not many!

Finally, your policy should provide a framework for setting and reviewing environmental objectives and targets

3. Conduct an environmental risk assessment and rank the risks:

By performing a formal risk assessment you should be able to identify risks. You should try to prioritise them for action. This risk assessment should be documented along with its conclusions and the date on which it was conducted. If no risk is found then this should be stated and the date of the assessment recorded. Remember risks can change.

4. Identify risk areas for improvement.

The standard requires that you identify environmental impacts that can be improved. You also need to set objectives for improvement with quantifiable targets for that improvement and carry out periodic measurement and reviews to ensure you are meeting the goals set.

Accidents cannot be prevented, but spills and firewater can be contained and controlled.

5. Implement management programs to achieve the objectives.

Once you have established your environmental objectives you need to inform and engage your staff in the implementation process

This is important if the objectives are complex as all staff involved will need to know what they

should be doing to make the improvement happen, and when.

6. Monitor and Measure.

All environmental impacts identified should be monitored, measured and reviewed periodically. Hazards and legalisation are dynamic and new risks are continuously identified. By way of example, the consequences of firewater were virtually unheard of a decade ago - now its containment must form part of your EMP in order to achieve compliance with the ELD.

The results of the reviews should be used to identify improvements to the management system programs and other procedures within the management system - the implementation of the Plan-Do-Check-Act cycle described earlier. Part of the review process will include formal management reviews with a fixed agenda set by the standard where senior management are able to review and influence the progress of the Environmental Management System.  To enable these tasks to be managed in a consistent way and as the standard requires, and to ensure the Plan-Do-Check-Act cycle is repeated over time, the standard requires that you have formal procedures in place to describe how you do the following:

Identify those aspects of your business that may or do affect the environment, and what the impact of these activities have under both normal circumstances and in the event of something going wrong, such as a spill or during a fire. This review must be documented and repeated on a regular basis.

Identify any legal or other requirements which apply to your business and ensure these are complied with. Your evaluation of compliance must be repeated periodically and documented. This could be a programme to inspect oil interceptors, test alarms, test your containment system, etc.

Train you staff so they fully understand your environmental management system and their individual duties. Further, inform them of the consequences of their failure to adhere to procedures - this may include the likely environmental damage and possible prosecution of staff which may in extreme cases lead to imprisonment under the power of the ELD. Your staff also need to know what to do and who to inform when things go wrong, this may include the installation of dissemination software such as our Alertcoms.

Communicate your environmental policy to all staff, and respond to external requests for information relating to your environmental performance. You should decide how much information you publish in the public domain - there are always limits so be realistic. Don't be embarrassed by the fact that you have processes that pose an environmental  risk, providing you have mitigation procedures and apparatus in place you have done your duty.

Establish a programme of revisions and control the revision level of documents which form the Environmental Management System. Also control all documents that provide evidence of compliance so they can be accessed at all times.

Exercise operational control of those parts of your business that have significant environmental impact. Install apparatus and procedures that will mitigate accidents such as spills. Unfortunately it is not possible to prevent accidents so you must mitigate their effect. In the case of spills and firewater you are obliged to contain them on site and if the volumes are likely to exceed a few gallons you will most likely have to use the drainage based containment system such as our DrianstopperTM.

Monitor and measure your environmental impact, and the performance of your Environmental Management System.

Deal with problems within the business which may have an environmental impact, including assessing the effectiveness of mitigation techniques. Don't be afraid to simulate incidents to test your readiness. Both the DrainstopperTM and FlapstopperTM systems include test modes.

Plan and conduct periodic audits of your environmental management system and procedures. Make certain that apparatus is properly maintained and tested. Keep records of all maintenance and test procedures

7. Ready for the Audit!

Once the Environmental Management System is in place and the mitigation apparatus such as DrainstoppersTM and FlapstoppersTM are installed and have been in operation for a period sufficient for evidence of their effectiveness to have been accumulated, it is possible to submit the system for certification.

Auditing will involve engaging the services of a third party certification body who will send in their auditors to review what you have done and confirm that it is operating in the way you have defined, and that it meets the requirements of the standard. If this audit is successful, then your business will be recommended for certification.

Remember if you dont shut your plant down in bad waether, the plan must demonstrably be able to operate with for example snow and ice on the ground. Try to explain how you will use a drain mat out doors and you may have difficulty!


8. What are the other benefits?

There are many benefits to be gained from implementing an Environmental Management System and achieving third party certification to ISO14001  The most significant are:

Demonstration of legal and regulatory compliance

Demonstration to stakeholders of your commitment to the environment

Demonstration of an innovative and forward thinking approach

Increased access to new customers and business partners

Better management of environmental risks, now and in the future

Potential reduced public liability insurance costs

Cost reductions

Good Luck and remember if in doubt ask we offer consultancy services in a number of areas of fire and pollution control.

 

Remember Pollution Risks Increase Under Near Artic Conditions!

The recent spate of Arctic conditions which  swept across most of the UK and Northern Europe during the 2009/10 winter, brought with it a series of major difficulties for companies attempting to deploy conventional spill and pollution control apparatus such as drain mats and absorbents. Even the most diligently prepared emergency teams struggled to locate drains under inches of snow. However, locating the drain is only the first of many problems! Have you considered how much time it would take to dig away snow and to chip away ice from a frozen drain with a shovel or the consequence of using a blowtorch? Further, what about the risks on a site with spilt or stored petrochemicals? Finally, what about the risk of entrapped methane within the drain? One spark let alone a naked flame and you could become history and the incident has become a disaster!   

Fact, the risk of a spill is greatly increased with extreme weather conditions and with snow cover plus iced up drains it can become impossible to legally keep your site operating and if you do you could find yourself standing "very thin ice" with regards to the validity of emergency response procedures and conformance under ISO14001.

Thankfully trying to find a spill or firewater containment system which works in all weather conditions is no longer a problem. Environmental Innovations Limited, a UK based designer, manufacturer and installer, can pre-install one of their DrainstopperTM or FlapstopperTM spill and firewater containment systems in the drain ready for action at the press of a button.

Apart from the basic moral responsibility to protect the environment the new stringent Polluter Pays Principle at the heart of the new European Environmental Liabilities Directive (ELD 2004/35/EC) makes no allowance for ignorance or extreme weather conditions when it comes to instigating fines or allocating potentially massive remuneration costs. So it's vital that when developing your Emergency Response Procedure that it will be engineered to work all the year round, 24/7 in all weather conditions otherwise you will be obliged to stop operations at the sight of the first snowflake of winter!