U.S. Army Center for Health Promotion and Preventive Medicine
Discussion Topics
EMS Requirement Background
Preparing for External EMS Audits Joint Compliance/EMS Audits Evolution of Army EMS Auditing Army EMS Audits Lessons Learned Army EMS Auditor Training (External & Internal Auditors)
EMS Requirement - Background
EO 13148 Required Federal Agencies to implement EMS EO 13423 Reinforced EMS implementation at all appropriate levels and EMS use as primary management approach OFEE EO 13423 Instructions Requires external audits [initial & follow-up (3-yr cycle)]
Preparing for External EMS Audits
(Phase I - Document Review Phase) Understand ISO 14001 Standard Review EMS Gap Analysis Results (and determine if gaps resolved) Understand your DOI-Agency specific EMS Manual/procedures Review of DOI-Agency specific EMS Manual/procedures (ISO 14001 conformance)
Preparing for External EMS Audits
(Phase II Internal Audit Phase) Conduct an internal EMS audit (using trained auditors) Implement corrective/preventive action(s) based on internal audit Understand the different types of nonconformance (i.e., major vs. minor) and the level of resources & commitment for resolution
Preparing for External EMS Audits
(Common Nonconformance Issues) ISO 14001, 4.1 (General Requirements) Has the scope of the EMS been documented?
Preparing for External EMS Audits
(Common Nonconformance Issues) ISO 14001, 4.2 (Environmental Policy) Does the policy address all of the mandatory commitments? Has the policy been communicated to all persons working on behalf of the organization (i.e., contractors & subcontractors)?
Preparing for External EMS Audits
(Common Nonconformance Issues) ISO 14001, 4.3.1 (Environmental Aspects) Are the aspects documented and kept up-to-date? Are the significant aspects taken into account in the EMS?
Preparing for External EMS Audits
(Common Nonconformance Issues) ISO 14001, 4.3.2 (Legal and Other Requirements) Do the legal and other requirements apply to the environmental aspects?
Preparing for External EMS Audits
(Common Nonconformance Issues) ISO 14001, 4.3.3 (Objectives, Targets, and Programs) Have significant environmental aspects been considered when establishing objectives/targets? Do the programs designate responsibilities, means, and time-frames to achieve objectives & targets?
Preparing for External EMS Audits
(Common Nonconformance Issues) ISO 14001, 4.4.1 (Resources, Roles, Responsibility and Authority) Has EMS Management Rep. been appointed? Have roles, responsibilities, and authorities been documented and communicated?
Preparing for External EMS Audits
(Common Nonconformance Issues) ISO 14001, 4.4.2 (Competence, Training, and Awareness) Has competence been determined for persons with potential to cause significant environ. impacts? Are training needs identified? Has awareness been provided to persons working on behalf of the organization?
Preparing for External EMS Audits
(Common Nonconformance Issues) ISO 14001, 4.4.3 (Communication) Do external communication procedures match actual business practices? Has the record of decision (regarding external communication of significant environmental aspects) been documented?
Preparing for External EMS Audits
(Common Nonconformance Issues) ISO 14001, 4.4.4 (Documentation) Does the EMS documentation include all of the mandatory requirements?
Preparing for External EMS Audits
(Common Nonconformance Issues) ISO 14001, 4.4.5 (Control of Documents) Do procedures (e.g., approval, review, update/re-approval, revision, removal of obsolete documents, etc.) match actual business practices? Are documents of external origin addressed?
Preparing for External EMS Audits
(Common Nonconformance Issues) ISO 14001, 4.4.6 (Operational Control) Have operational controls been developed for those activities & operations with significant environmental aspects? Are those operational controls being implemented at the user level?
Preparing for External EMS Audits
(Common Nonconformance Issues) ISO 14001, 4.4.7 (Emergency Preparedness and Response) Are emergency preparedness & response procedures periodically tested (where practicable)?
Preparing for External EMS Audits
(Common Nonconformance Issues) ISO 14001, 4.5.1 (Monitoring and Measurement) Are key characteristics of operations (that can have significant environmental impact) being monitored and measured? Are there calibration records for any associated monitoring and measurement equipment?
Preparing for External EMS Audits
(Common Nonconformance Issues) ISO 14001, 4.5.2 (Evaluation of Compliance) Is there a process for the periodic evaluation of compliance with legal and other requirements? Are records available of those periodic compliance evaluations?
Preparing for External EMS Audits
(Common Nonconformance Issues) ISO 14001, 4.5.3 (Nonconformity, Corrective Action & Preventive Action) Do procedures also address preventive actions? Do procedures address corrective & prev. action effectiveness? Do the procedures match the actual business practices?
Preparing for External EMS Audits
(Common Nonconformance Issues) ISO 14001, 4.5.4 (Control of Records) Do procedures address the retention times & disposal of records? Are records legible, identifiable, and retrievable?
Preparing for External EMS Audits
(Common Nonconformance Issues) ISO 14001, 4.5.5 (Internal Audit) Has an Internal Audit Program been implemented (e.g., schedule established; auditors identified & trained; audits conducted)? Does the selection of auditors & the conduct of the audits ensure objectivity & impartiality of the audit process?
Preparing for External EMS Audits
(Common Nonconformance Issues) ISO 14001, 4.6 (Management Review) Has the management review process been implemented? Does the management review process incorporate all of the required inputs?
Joint Compliance/EMS Audits
(Different Approaches) Army Environmental Performance Assessment System (EPAS) External Audits Active Component Installations Concurrent Compliance/EMS Audit Dedicated EMS Audit Team Separate Compliance & EMS Audit Reports
Joint Compliance/EMS Audits
[Different Approaches (Cont.)] Army EPAS External Audits Reserve Component Installations Installation Compliance Audit is Conducted First Follow-up EMS Audit (conducted months after the compliance audit) Root Cause Analysis (from compliance audit) is used to Formulate EMS Audit Plan
Joint Compliance/EMS Audits
[Different Approaches (Cont.)] Defense Logistics Agency (DLA) Compliance and EMS Audit Programs Separate Compliance & EMS Audit Schedules (no integration between compliance & EMS audits) DLA EMS Focus Multi-site Organizational EMS vs. Facilityspecific EMS
Joint Compliance/EMS Audits
(Key Points) Compliance auditing and conformance auditing are VERY different skills sets If joint compliance/EMS audits are conducted, the audit team needs to include dedicated EMS auditor(s) (with no compliance audit responsibilities)
Joint Compliance/EMS Audits
[Key Points (Cont.)] EMS Lead Auditor needs to have full responsibility for conduct of the EMS portion of the audit (e.g., preparing EMS audit, briefing results, preparing report, etc.) Compliance auditors may provide site-specific feedback (e.g., training records, current plans/procedures, operational controls, etc.)
Joint Compliance/EMS Audits [
[Key Points (Cont.)] If contractor EMS auditors are used, consider specifying that the auditors be RABQSA-certified (ensures level of competence) If contractor EMS auditors are used, consider Nondisclosure Agreements (prevents contractor from using DOI EMS practices in support of other clients)
Joint Compliance/EMS Audits
[Key Points (Cont.)] If EMS support contractors have assisted with the implementation of the EMS, do NOT use those same contractors to audit the EMS (avoids conflicts of interest) EMS support contractors can still be used to address audit findings (if needed), but they need to be independent of the audit
Evolution of Army EMS Auditing
FY 85 91: Army Environmental Audit Program (multiple protocols, compliance medias only) FY 92 00: Army Environmental Compliance Assessment System (ECAS) Program [standard protocol (TEAM Guide); Army Supplement to TEAM Guide (included Env. Program Mgt.)]
Evolution of Army EMS Auditing
(Cont.) ECAS Env. Program Mgt. evaluations included several components of an EMS audit FY 01 Present: Army EPAS Program [Army Supplement to TEAM Guide revised to include EMS section (ISO 14001)] Env. Program Mgt. assessors trained as EMS auditors
Army EMS Audits Lessons Learned
Many contractor-prepared EMS manuals/procedures do not reflect installation business practices Some Army Commanders equate EMS nonconformance to regulatory noncompliance Some Army installations tend to regard EMS as a Program vs. a management system
Army EMS Audits Lessons Learned
(Cont.) Command emphasis on EMS can vary with changes in installation leadership (integration of EMS with sustainability has worked well at some installations) Incorporation of tenants into host installation EMS can prove challenging.
Army EMS Auditor Training
(Training External Auditors) Army Environmental Command (AEC) hosts ISO 14001 Lead Auditor Course (open to potential auditors & funds attendance) EMS auditor trainees are assigned to participate in EMS audits (AEC funds travel) with experienced (e.g., USCCHPPM) EMS auditors until capable of serving as auditor
Army EMS Auditor Training
(Training External Auditors) Core Group of Experienced EMS Auditors Still Conduct the Majority of Army EMS Audits Expanding the Army Pool of Experienced Auditors is a Major Challenge (multi-year effort) EMS Auditor Pool MUST be Expanded (Core Group cannot support all Army EMS audits)
Army EMS Auditor Training
(Training Internal Auditors) General EMS internal auditor training (interview techniques, reviewing objective evidence, preparing findings, and practical exercise using generic manual) Installation-specific EMS internal auditor training (above basics of internal EMS audits & practical exercise using installation manual)
Questions Linda L. Baetz, EMS-LA (410) 436-5234 linda.baetz@us.army.mil James D. Wood, P.E., EMS-LA (410) 569-3325 jim.wood@us.army.mil