Gap Analysis Carrizal.

GAP ANALYSIS OF THE ENVIRONMENTAL MANAGEMENT SYSTEM.
Carrizal Mining, S. A. de C. V.
4.2 . ENVIROMENTAL POLICY

ISO 14,001 Requirements.
Evidence Required.
Top management shall define the

organizations environmental policy
and ensure that is:
a).- Is appropriate to the nature,
scale, and environmental impacts
of its activities, products or
services.
b).- Includes a commitment to
continuos
improvement
and
pollutions prevention.
c).- Includes a commitment to
comply
with
relevant
environmental legislation and
regulations,
and
any
other
requirement
to
which
the
organization subscribes.
Environmental policy written and signed

by Executive Coordinator.
Carrizal Mining.
Environmental System.
Gap.
The environmental policy was defined

after the significant environmental
aspects and impacts were identified.
The environmental policy includes a
explicit written commitment to prevent
pollution and continuos improvement.
The environmental policy includes a
explicit written commitment to comply
with Legal & other requirements.
Besides the company has a formal
process to identify and update its
applicable laws and regulations.
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4.2 . ENVIROMENTAL POLICY

Evidence Required.
Carrizal Mining.
Gap.
d).- Provides the framework for The environmental policy includes

setting and review environmental general objectives, associated with its
objectives and targets.
significant environmental aspects.
e).- Is documented, implemented The environmental policy must be
and maintained as well as approved by Top management, reviewed
communicated to all employees.
at least once a year by the ISO 14000
Environmental Committee and this
activity is documented with minutes, that
contains the preventive and corrective
actions decided. Must be communicated
to all employees
(all personnel knows were to access the
Environmental Policy, its significant
environmental aspects, objectives and
targets).
f).- Is available to the public.
The company has established a

procedure to attend any inquire,
regarding the environmental policy. The
document containing the policy is at the
main entrances of the facility.
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4.3 PLANING
4.3.1 Environmental Aspects.
Evidence Required.
a).- The organization shall establish

and maintain a procedure to
identify the environmental aspects
of its activities, products and
services; that can control and over
which it can be expected to have
an influence, in order to determine
those which have or may have a
significant
impact
on
the
environment.
There must be a documented procedure

to identify the significant environmental
aspects. Interview the ISO 14000
Environmental Committee to verify
implementation. Review the minute of
the meeting in which the ISO 14000
Environmental Committee, carried out
this activity and check the list of
significant
environmental
aspects
identified.
b).- The organization defines criteria

(legal, economic) to determine
which of the environmental aspects
are considered significant.
The minute of the ISO 14000

Environmental Committees meeting to
decide which environmental aspects are
significant, reflects discussions of the
criteria to be used and an analysis of
each environmental aspect of the
company.
Carrizal Mining.
Gap.
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4.3 PLANING
Evidence Required.
c).- The organization shall ensure

that, the environmental aspects
related to its significant impacts;
are considered when setting its
environmental objectives.
The significant environmental aspects

identified must have procedures for
operational control; objectives and
targets (established by the ISO 14000
Environmental Committee). Minutes of
all the required meetings. A list of all the
objectives and targets (all personnel
must know their objectives and targets).
Minutes of the meetings of the ISO
14000
Environmental
Committee,
evaluating the significant environmental
aspects of suppliers and contractors.
Area managers have a written list of all
area or functional area aspects and
significant aspects.
d).- the activities of suppliers and

contractors were considered when
establishing
the
significant
environmental aspects.
e).- Affected functional and
process area management will
maintain a current list of
environmental
aspects
and
significant environmental aspects.
Carrizal Mining.
Gap.
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4.3 PLANING
Evidence Required.
f).Significant
environmental
aspects should form the basis for
establishing:
process
and
management
controls;
environmental
improvement
programs and significant aspects
for further investigation and study.
g).- Environmental aspects should
be reviewed semi annually by the
ISO
14000
environmental
committee. New and changed
processes and activities will be
included.
Identified significant aspects should

have operational control procedure,
objectives
and
targets,
and
environmental management plans for
each significant aspect having an
objective and target.
Carrizal Mining.
Gap.
Environmental aspects are reviewed by

the ISO 14000 committee and
documented in meeting minutes at least
every six months. Documented review of
process changes, new processes,
constructions and/or new programs for
aspects and their significance.
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4.3 PLANING
4.3.2 Legal and other requirements.
Evidence Required.
The organization shall establish and

maintain a procedure, to identify and
have access to legal and other
requirements
to
which
the
organization subscribes; that are
applicable to the environmental
aspects of its activities, products and
services.
Facility will maintain all current
local regulations and ordinances by
either contacting the appropriate
authority or subscribing to a
regulatory update service.
Facility will maintain access to
national and state regulations by
contacting the appropriate authority
or subscribing to a regulatory update
service.
Facility procedure defines how Facility

will
identify
appropriate
legal
requirements, and have access to current
versions.
Carrizal Mining.
Gap.
Written process to get local regulation,

i.e. letter to agency requesting updates or
Internet access.
Written process to get national and state
regulations, i.e. letter to agency
requesting updates, update service
through hard copy or Internet access.
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4.3 PLANING
4.3.3 Objectives and targets.
Evidence Required.
Facility considered the following in

establishing objectives and targets:
technological options, financial,
operational
and
business
requirements.
Facility establishes its objectives
well detailed, concrete and verifiable.
ISO
14000
environmental
committee
minutes
reflect
discussion and decision made for
Carrizal Mining.
Gap.
Objectives have well established the

indicators for follow up its
objectives advance.
Facility has to communicate its List in the area of the objective and
environmental objectives and targets targets applicable to them.
to the people on the floor.
Facility has considered legal and ISO 14000 meeting minutes reflect
other requirements in establishing discussion and decision made for
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4.3 PLANING
4.3.3 Objectives and targets.
Evidence Required.
Facility has considered the views of

interested parties in establishing
Facility objectives and targets are
consistent with environmental policy
and include a commitment to
prevention of pollution.
Does the procedure to select
objectives and targets consider
corrective actions in case they are not
achieved.
ISO 14000 meeting minutes reflect

discussion and decision made for
Objectives and targets linked to policy.
Objectives and targets

considers corrective actions.
Carrizal Mining.
Gap.
procedure
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4.3 PLANING
4.3.4 Environmental Program.
Facility
has
established
and
maintained a program for achieving
its objectives and targets.
Facility
has
established
and
maintained programs for achieving
each of its objectives and targets.
Evidence Required.
ISO 14000
minutes,
committees
Carrizal Mining.
Gap.
meeting
Program describing the task, responsible

individuals and the time frame by which
they are to be achieved are developed for
each objective and target.
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4.3 PLANING
4.3.4 Environmental Program.
Evidence Required.
New activities, products or services

are
reviewed
for
potential
environmental program plans and
controls.
Project originator reviews and
characterizes the environmental and
energy aspects of the project.
Facility has defined roles and
responsibilities with operations staff
for project review.
Documented review of process changes,

new process and /or new program plans
and controls.
Carrizal Mining.
Gap.
Record of project review environmental

checklist.
Defined roles for facility projects are
reviewed by the Environmental, Health
and Safety coordinator; operations
project review by operations staff.
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4.4 IMPLEMENTATION AND OPERATION.

4.4.1 Structure and responsibility.
Evidence Required.
The facility has defined the roles and

responsibility
and
authorities
assigned for the Environmental
Management System.
Facility management has appointed a
management representative with
defined roles to implement the
Environmental Management System.
Facility Environmental Management
Representative reports on the
performance of the Environmental
Management
System
to
Top
management
for
review
and
continuous improvement.
Organization
charts
and
roles,
responsibilities and authorities of
personnel for the Environmental
Management System.
A letter appointing an Environmental
Management System Representative
with
documented
roles
and
responsibilities.
Facility has meeting minutes, identifying
issues discussed and corrective actions
taken. May use quarterly reviews, best
fit in to schedule.
Carrizal Mining.
Gap.
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4.4.2 Training, awareness and competence.
Evidence Required.
The organization has identified

training needs for personnel whose
work may create a significant impact
or associated with a significant
aspect.
Written training needs, subject matter,

level of understanding, identify the
groups or job function. Subject matter
should include environmental training
required by law, procedure and work
instructions, and operational control.
Individual training records. Outline or
checklist of material covered in
procedures training. Training content
descriptions or materials used.
Facility shall have a procedure to

make all employees aware of
Importance of conformance with
policy and procedures, significant
impacts associated with significant
aspects, roles and responsibilities in
conformance with policy.
Carrizal Mining.
Gap.
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4.4.2 Training, awareness and competence.
Evidence Required.
Facility shall have a procedure to

make all of its employees aware of :
requirements of the Environmental
Management System, the potential
consequences of departure from
operating procedures, and emergency
preparedness and response.
Facility personnel performing task
that can cause significant impact or
associated with significant aspect
shall be competent on the basis of
education,
training
and/or
experience.
Individual training records. Outline or

checklist of material covered in
procedures training. Training content
descriptions or material used.
Carrizal Mining.
Gap.
Competence criteria by job function.
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4.4.3 Communication.
Evidence Required.
Carrizal Mining.
Gap.
Facility has a procedure for internal Facilities procedures outline two way
communication between the various communications from management to
levels and functions.
facility personnel and from facility
personnel to management on the
Environmental Management System,
policy, objectives and targets or potential
no conformance.
Internal communications procedures Records of internal communications on
will
be
used
to
facilitate permit conditions, regulations, and legal
implementation
of
regulatory, requirements.
company
policy
and
other
requirements.
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4.4.3 Communication.
The responsible persons should
develop a procedure to log external
communications and record the
responses to external communications
concerning the environmental aspects.
Environmental
Management
Representative
or
designated
individual
is
responsible
for
responding to inquiries from the
community and regulatory agencies.
Evidence Required.
Carrizal Mining.
Gap.
Procedure defines who is responsible for

receiving external communication and
how to foreword information, responsible
individual to respond to request. Requests
are logged on the external communication
log.
External communication to community .
and regulatory agency are logged in
communication log by Environmental
Management Representative or designee.
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4.4.4 Environmental Management System documentation.
Evidence Required.
Carrizal Mining.
Gap.
Facility has information in paper or

electronic form to describe the core
elements of the management system
and their interactions.
Information required: purpose, facility

history and description, facility policy,
overview
of
system
structure,
responsibilities, summary list of aspects,
program plan summaries, facility
procedures and a list of work
instructions.
Facility has information in paper or Information required: related records,
electronic form to provide direction inspections, forms, etc. are described and
to related documentation.
how they fit into the management
system.
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4.4.5 Document control.
Evidence Required.
Facility has a procedure for

controlling all documents required by
the Environmental Management
System.
Authorized personnel prior to use or
release review documents, records
and data for adequacy.
The document control manager or
designee maintains a master list of
documents, records and data.
Facility procedure that clearly defines

what a document is, and how to
handle/control current and obsolete
documents.
A record of review of documents for
adequacy by authorized personnel.
Carrizal Mining.
Gap.
Document control manger maintains a

master list of documents, indicating
revision dates, and who has authority for
changes or revisions.
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Evidence Required.
Carrizal Mining.
Each functional area manger or

designee should maintain a master
list of all Environmental System
documents and data relevant to their
area/function/process, as applicable.
Relevant documents are available at
the locations where they are needed.
Personnel ensure current versions are
available and used.
Obsolete documents are promptly
removed from all points of use or
otherwise assured against unintended
use.
Obsolete documents retained for
legal or preservation purposes are
properly identified.
Area managers have a written list of all

functional area documents.
Gap.
Documents are available within the area

used.
Personnel use current version of
documents.
Facility has a procedure to insure that
obsolete documents are removed from
use.
Facility follows
procedures.
record
retention
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Evidence Required.
Facility has a procedure for defining

responsibility
concerning
the
creation and modification of
documents.
Documentation shall be legible,
dated and readily identifiable,
maintained in an orderly manner and
retained for specified period.
The facility has a procedure to create

procedures.
Carrizal Mining.
Gap.
Facility follows record retention

procedures, and method for filing and
indexing to enable accessibility.
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4.4.6 Operational control.
Evidence Required.
Carrizal Mining.
Gap.
Facility has identified operations

associated
with
significant
Facility has planned maintenance in
order to ensure that they are carried
out under specified conditions.
Facility has a list of the operations,

processes or activities that are associated
with significant aspects.
Facility has maintenance schedules and
records of conducting maintenance on
operations, process or equipment
associated
with
significant
Operations
associated
with Procedures are established for process,
significant aspects have established activities or equipment that are
and
maintained
documented associated with significant aspects.
procedures to cover situations where
their absence could lead to deviations
from the policy, objectives and/or
targets.
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Procedures
conditions.
Evidence Required.
Carrizal Mining.
Gap.
stipulate
operating Procedures have operating conditions

stated
to
minimize
significant
environmental impacts.
Facility has a procedure related to the Facility has list of contractors providing
identifiable significant aspect of services that would affect the significant
goods and services used by the aspects,
and
documents
organization
and
communicate information/training provided.
procedures and requirements to
suppliers and contractors.
The need for contractor services is Record of supplier request for quotation
identified and the initiating party prepared by initiating party.
prepares request for quotation.
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Evidence Required.
Purchase requests should include a

work instruction to suppliers and
contractors.
The facility initiating activity
communicates acceptance of a
proposal,
to
the
purchasing
department.
The facility or initiating party shall
communicate
relevant
facility
specific environmental procedures,
work practices and requirements to
affected contractors prior to the
commencement of requested work.
Record of requests includes, work

instruction to supplier and contractors.
Carrizal Mining.
Gap.
Record notes accepting the service

requested.
Record of communicating relevant
procedures, work instructions to
contractors prior to conducting work.
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4.4.7 Emergency preparedness and response.
Evidence Required.
Carrizal Mining.
Gap.
Potential environmental incidents

and emergencies likely to occur at
the facility shall be identified by the
ISO
14,001
environmental
committee.
Record of potential environmental

incidents and emergencies review i.e.
ISO 14,001 environmental committee
meeting minutes, emergency response
plans, spill response and prevention
plans. Check aspects determination
matrix.
Methods to respond, mitigate and Emergency response plan defines
prevent releases that require an method for response, mitigation, and
emergency response shall be prevention of environmental releases.
established and maintained at the
facility with the appropriate response
personnel.
Roles and responsibilities for Emergency response plan defines roles
communications within the facility and responsibilities for communication
and for obtaining outside support to obtain outside support, such as phone
services (e.g. police, fire) shall be number list, radio frequencies.
established and maintained at the
facility.
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Evidence Required.
The procedures at the facility shall be

reviewed and revised on an annual
basis or as deemed necessary by the
ISO
14,001
environmental
committee.
Emergency response methods and
communications will be tested on an
annual basis or as necessary.
Record or review emergency response

plans annually or after an emergency
incident.
Carrizal Mining.
Gap.
Record of conducting emergency

response and communications test
annually.
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Evidence Required.
The facility emergency response

leader shall record information
necessary to be used in determining
corrective actions and preventive
actions and any improvement to
existing procedures that may be
needed.
Where
applicable,
regulatory
agencies shall be notified of
environmental incidents.
Record
of
emergency
response
corrective actions and preventive
actions.
Carrizal Mining.
Gap.
Record of external communications to

applicable regulatory agencies of
environmental
incidents.
External
communication log book.
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4.5 VERIFICATION AND CORRECTIVE ACTION

4.5.1 Monitoring and measurement.
Evidence Required.
Facility has documented procedures

for monitoring and measuring key
characteristics of its operations
associated with significant aspects.
Facility has records of metrics to
track
performance,
relevant
operational
controls
and
conformance with objectives and
targets.
Written procedure detailing what key

characteristic is and the metric collected.
Carrizal Mining.
Gap.
Record
of
key
characteristics
performance, i.e. graphs, tables.
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Evidence Required.
Monitoring
and
measuring
equipment shall be calibrated and
maintained and records retained.
Facility has documented procedures
for
periodically
evaluating
compliance
with
relevant
environmental
legislation
and
regulations.
Records of calibration and maintenance

retained in accordance with record
retention procedure.
Review Internal audit procedures, as
environmental review is incorporated
into Internal audit process.
Carrizal Mining.
Gap.
1 de 37


Evidence Required.
The environmental management

representative is responsible for
planning,
scheduling
and
implementing internal regulatory
compliance assessments, including
the identification of required
resources.
The facility specific regulatory
assessment documents will be
reviewed and amended based on
assessment findings and revisions to
the
environmental
regulatory
requirements.
The audit team will record audit
information, review with appropriate
personnel and issue corrective
actions requests as required.
Review Internal audit results, as

environmental review is incorporated
into Internal audit process.
Carrizal Mining.
Gap.
Record of review and amendments.
Evidence that process is being followed.
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Evidence Required.
Periodically,
the
environmental
management
representative
or
designee prepares and submits a
summary of audit results to the ISO
14,001 environmental committee for
review.
Upon completion of corrective
and/or preventive actions, the
responsible organization or activity
personnel furnish the environmental
management
representative
or
designee with a signed or
acknowledged corrective action
request.
Record of review, such as meeting

minutes, information reviewed.
Record of completed corrective actions

requests.
Carrizal Mining.
Gap.
1 de 37


4.5.2 Non conformance and corrective & preventive action.
Evidence Required.
Facility has a procedure for non

conformance and corrective and
preventive
actions
defining
responsibility and authority for
investigating
and
mitigating
environmental impacts.
Each activity within the facility is
responsible for identifying specific
techniques to identify the root cause
(s), take appropriate corrective or
preventive
action,
verify
effectiveness and prevent recurrence
where possible.
Facility records and changes in
documented procedures resulting
from corrective and preventive
actions.
Facility
procedure
defines
non
conformance, and assigns responsibility
for correction.
Carrizal Mining.
Gap.
Record of corrective action request.
Record of changes, revisions due to

facility actions for correction or
prevention measures taken.
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4.5.3 Records.
Evidence Required.
Facility has a procedure to identify,

maintain,
and
dispose
of
environmental records.
Each activity responsible for
maintaining a record has the
responsibility for establishing the
method for filing and indexing the
records for accessibility.
Each activity responsible for
retaining Environmental System
records maintains a master list of
Environmental
system
records
relevant to the area.
Facility has master list of environmental

records, retention times and maintains
access files.
Evidence of method of filing and
indexing environmental records at area
level.
Master list
records.
of
area
Carrizal Mining.
Gap.
environmental
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4.5.4 Environmental Management System Audits
Evidence Required.
Carrizal Mining.
Gap.
Facility has a program and procedure Review Internal Auditing procedure.

for
periodic
Environmental Confirm previous Internal Audit
Management System audits.
schedule
followed
schedule
in
procedure.
The environmental management Evidence and/or records of scheduling
representative or designee is and
implementing
internal
responsible for planning, scheduling environmental audits.
and
implementing
internal
environmental system audits.
An audit team will be formed whose Documented independence of auditor.
membership has no responsibility
within the organization or activity to
be audited.
An audit schedule will be developed Record of audit schedule for audits in the
for each organization or activity to be current year or three years cycle for all
audited.
elements.
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Evidence Required.
Audit frequency set on priority basis,

taking into account previous audit
results and the relative importance of
the activity or organization, and will
not be less than once per year for
each activity or organization.
The audit scope will be established
based upon the area and system
elements to be assessed.
During the audit, the audit team will
record audit observations, indicating
items
checked,
individuals
interviewed, any concerns identified
and any corrective or preventive
actions completed during the audit.
The audit team documents its
findings using the audit corrective
action request, indicating the related
ISO 14,001 element (s), the
nonconformance and all necessary
acknowledgments.
Evidence of audit frequency and

rationale for schedule and change to
schedule.
Carrizal Mining.
Gap.
Evidence of audit scope and criteria set

by facility.
Record of audit observations and
information
collected
during
environmental audit.
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Area representative will complete the
section for timed corrective or
preventive
action
and
return
information to audit team and
environmental
management
representative.
A closing meeting will be conducted
where summary of audit findings is
reported to audited organization and
activity management.
representative shall notify facility
management of potential regulatory
non-compliance.
The audit team will review corrective
actions and verify implementation
either by a future visit or during the
next planned audit at the discretion
of the audit team leader.
representative or designee submits
audit summaries for facility process,
area and functional management
review.
Evidence Required.
Carrizal Mining.
Gap.
Evidence of a closing meeting with area

management.
Evidence of notification.
Evidence or record to verify corrective

actions.
Record of audit summaries for functional

management review.
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Evidence Required.
Carrizal Mining.
Gap.
The environmental management Record of audit reports and ISO 14,001

representative or designee submits environmental
committee
meeting
audit results to the ISO 14,001 minutes.
environmental committee for review
and appropriate action.
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4.6 MANAGEMENT REVIEW.

The facility manager and the ISO
14,001 environmental committee do
management review.
representative will schedule this
meeting at least once each year.
The entire ISO 14,001 environmental
committee will participate in review.
All elements of the Environmental
System will be reviewed.
Evidence Required.
Carrizal Mining.
Gap.
Documented attendance.
Evidence of environmental management
representative scheduling meeting at
least once a year.
Documented attendance.
Record of meeting minutes.
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4.6 MANAGEMENT REVIEW.

Evidence Required.
Carrizal Mining.
Gap.
The meeting will be scheduled in Record of meeting agenda.

advance with a meeting agenda to
ensure appropriate preparation and
attendance.
ISO 14,001 environmental committee Review agenda identifying internal audit
will decide if any changes are needed in results. Record of meeting minutes and
the facility Environmental Management corrective actions or changes to system.
System to ensure that the plant'
environmental policy, objectives and
targets and other elements of the system
are covered.
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Gap Analysis Carrizal.

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GAP ANALYSIS OF THE ENVIRONMENTAL MANAGEMENT SYSTEM.

4.2 . ENVIROMENTAL POLICY

Top management shall define the

Environmental policy written and signed

The environmental policy was defined

GAP ANALYSIS OF THE ENVIRONMENTAL MANAGEMENT SYSTEM.

4.2 . ENVIROMENTAL POLICY

d).- Provides the framework for The environmental policy includes

The company has established a

GAP ANALYSIS OF THE ENVIRONMENTAL MANAGEMENT SYSTEM.

a).- The organization shall establish

There must be a documented procedure

b).- The organization defines criteria

The minute of the ISO 14000

GAP ANALYSIS OF THE ENVIRONMENTAL MANAGEMENT SYSTEM.

c).- The organization shall ensure

The significant environmental aspects

d).- the activities of suppliers and

GAP ANALYSIS OF THE ENVIRONMENTAL MANAGEMENT SYSTEM.

Identified significant aspects should

Environmental aspects are reviewed by

GAP ANALYSIS OF THE ENVIRONMENTAL MANAGEMENT SYSTEM.

The organization shall establish and

Facility procedure defines how Facility

Written process to get local regulation,

GAP ANALYSIS OF THE ENVIRONMENTAL MANAGEMENT SYSTEM.

Facility considered the following in

Objectives have well established the

GAP ANALYSIS OF THE ENVIRONMENTAL MANAGEMENT SYSTEM.

Facility has considered the views of

ISO 14000 meeting minutes reflect

Objectives and targets

GAP ANALYSIS OF THE ENVIRONMENTAL MANAGEMENT SYSTEM.

Program describing the task, responsible

GAP ANALYSIS OF THE ENVIRONMENTAL MANAGEMENT SYSTEM.

New activities, products or services

Documented review of process changes,

Record of project review environmental

GAP ANALYSIS OF THE ENVIRONMENTAL MANAGEMENT SYSTEM.

4.4 IMPLEMENTATION AND OPERATION.

The facility has defined the roles and

GAP ANALYSIS OF THE ENVIRONMENTAL MANAGEMENT SYSTEM.

4.4 IMPLEMENTATION AND OPERATION.

The organization has identified

Written training needs, subject matter,

Facility shall have a procedure to

GAP ANALYSIS OF THE ENVIRONMENTAL MANAGEMENT SYSTEM.

4.4 IMPLEMENTATION AND OPERATION.

Facility shall have a procedure to

Individual training records. Outline or

Competence criteria by job function.

GAP ANALYSIS OF THE ENVIRONMENTAL MANAGEMENT SYSTEM.

4.4 IMPLEMENTATION AND OPERATION.

GAP ANALYSIS OF THE ENVIRONMENTAL MANAGEMENT SYSTEM.

4.4 IMPLEMENTATION AND OPERATION.

Procedure defines who is responsible for

GAP ANALYSIS OF THE ENVIRONMENTAL MANAGEMENT SYSTEM.

4.4 IMPLEMENTATION AND OPERATION.

Facility has information in paper or

Information required: purpose, facility

GAP ANALYSIS OF THE ENVIRONMENTAL MANAGEMENT SYSTEM.

4.4 IMPLEMENTATION AND OPERATION.

Facility has a procedure for

Facility procedure that clearly defines