Environmental and Quality Systems Integration - Part 5 pdf

16 ©1998 CRC Press, LLC Monitoring and Measurement 16.1 INTRODUCTION In Appendix I, the entire ISO 14001 framework is mapped out and shows how all of the various elements of the standard interrelate. You will note that immediately downstream from Environmental Programs is the requirement to Monitor and Mea- sure. What this means is that you should have a system in place to measure and monitor the actual performance of your environmental objectives and targets and the progress of your environmental programs. The result of your monitoring and measuring is reported to your management review committee. The results of this data will determine how well your programs are maintaining compliance with your policy. 16.2 THE ISO 14001 REQUIREMENTS Element 4.5.1, Monitoring and Measurement , of the Environmental Management Standards states: The organization shall establish and maintain documented procedures to monitor and measure, on a regular basis , the key characteristics of its operations and activities that can have a significant impact on the environment. This shall include the recording of information to track performance, relevant operational controls and conformance with the organization’s environmental objectives and targets. Monitoring equipment shall be calibrated and maintained and records of this process shall be retained according to the organization’s procedures. The organization shall establish and maintain a documented procedure for periodi- cally evaluating compliance with relevant environmental legislation and regulations. There are several key points to keep in mind (highlighted) when implementing and integrating this requirement. The first is there must be a documented procedure that will define how, who, what and when. The second was alluded to in the introduction and that is the requirement to use the system to track performance, controls and performance. The third requirement is that all environmental equipment used to monitor and measure must be calibrated in order to ensure the accuracy of the data. The fourth requirement is related to Element 4.3.2 in that you must monitor compliance to environmental regulations. ©1998 CRC Press, LLC 16.3 RELATIONSHIP TO ISO 9001 The primary section in ISO 9001 relating to the ISO 14001 requirements is found in 4.20, Statistical Techniques . Specifically, ISO 9001 states: 4.20.1, Identification of Need The supplier shall identify the need for statistical techniques required for establishing, controlling and verifying process capability and product characteristics. 4.20.2, Procedures The supplier shall establish and maintain documented proce- dures to implement and control the application of the statistical techniques identified in 4.20.1. It has been my experience, however, that the integration of the ISO 14001 requirements into the ISO 9001 procedure was very difficult. The primary reason for this is that Element 4.20, Statistical Techniques , requires an “identification of need” that is not based on whether or not a process is “significant.” Unless you also become familiar with the guideline document, ISO 9004, you may miss where the connection with ISO 14001 occurs. ISO 9004, the guideline document, states in Section 10 the following: Section 10.1.2 Verification of the quality status of a … process, … processed material, service, or environment should be considered at important points in the production sequence to minimize effects of errors and to maximize yields. Section 10.1.3 Monitoring and control of processes should relate directly to fin- ished product specifications or to an internal requirement, as appropriate … In all cases, relationships between in-process controls, their specifications and final product specifications should be developed … Thus, the ability to integrate ISO 14001 with ISO 9001 can only be accomplished if you fully understand the guidelines provided in ISO 9004 — your ISO 9001 procedure(s) should reflect ISO 9004 information. 16.4 A MONITORING AND MEASURING PROCEDURE The primary key to complying with the ISO 14001 requirements is to establish a documented procedure that establishes what you are going to do, how you plan to do it, why you are doing it and when it will be done. If you do not have an adequate procedure within the ISO 9001 framework to build upon, I would suggest that you write another procedure to satisfy just the ISO 14001 requirements and then work at a later date on developing an integrated procedure. Although the intent of this book is to show you examples of how integration can be done, there are instances where the initial efforts may be much more difficult than anticipated. This may be due to the fact that there isn’t a specific ISO 9001 procedure for monitoring and measurement. As you can see from Table 16.1, the correlation of the ISO 14001 requirements occurs in several different areas of ISO 9001 and, since ISO 14001 requires a documented procedure, integration may be difficult at first. This was my ©1998 CRC Press, LLC TABLE 16.1 Correlation of “Monitoring and Measurement Requirements” ISO 9001 ISO 9004 ISO 14001 Section Requirement Section Requirement Section Requirement 4.20.2 4.20.2 Documented procedure consistent with the requirement; Documented procedure to implement and control application of statistical techniques. 10.1.4 11.4 Documented test and inspection procedures should be maintained for each characteristic to be checked; Processes that are important to product quality should be planned, approved, monitored and controlled. 4.5.1(i) Documented procedure to monitor and measure 4.11.2 (a) 4.20.1 Define measurements to be made; Need for statistical techniques for establishing, controlling and verifying process capability and final product characteristics. 10.2 Operations associated with product or process characteristics that can have a significant effect on product quality should be identified. 4.5.1(i) Monitor key characteristics that can have a significant impact 4.2.3 (f) Identification of suitable verification at appropriate stages. 10.1.2 Verification of the quality status at important points in the production sequence to minimize effects of errors. 4.5.1 (i) Track performance 4.9 (d) Monitoring and control of suitable process parameters 10.1.4 All in-process and final verifications should be planned and specified. 4.5.1 (i) Track relevant operational controls 4.10.4 Specified inspection and testing results meet specified requirements 10.1.3 Monitoring and control of processes should relate directly to finished product specifications 4.5.1 (i) Track conformance with objectives and targets 4.11.2 (a) 4.11.2 (b) Select appropriate measuring equipment; Calibrate monitoring equipment 13.2 Procedure for the control of inspection, measuring and test equipment 4.5.1 (ii) Calibrate monitoring equipment 4.9 (c) Compliance with reference standards/codes 19 (a) 19 (b) 19 (d) Identify relevant safety standards; Carrying out design evaluation tests and prototype (or model) testing for safety; Developing a means of traceability to facilitate product recall. 4.5.1 (iii) Documented procedure to evaluate environmental legislation compliance. * (i) denotes paragraph ** (a) denotes subsection of element ©1998 CRC Press, LLC own experience — too much time and effort was needed to bring the two standards together. With an ISO 14001 audit looming on the near horizon, I could not put too much effort into figuring out how to work with the ISO 9001 documents. The result was an EH&S-specific procedure for monitoring and measurement. In this section, I have provided a rough draft of an EH&S-specific monitoring and measurement procedure based on the procedure template I have been using in several of the previous chapters. The referenced document numbers, of course, are made up. You will note that I have also included the “reporting” requirements found under Element 4.4.1 for the management representative. In addition, I would like to take this particular opportunity to show that all of the procedures I have provided need not be concerned with just environmental issues, but can also include your com- pany’s health and safety requirements. If you or your department has responsibility for health and safety as well, it makes sense for you to write your procedures to cover environmental, health and safety requirements. If international health and safety stan- dards are ever developed (see Chapter 21), you would have done a lot of preparation beforehand. So with this in mind, let’s take a look at an EH&S-specific procedure. Purpose This procedure is intended to identify and document the monitoring, measurement and reporting requirements for the aspects and/or impacts of the company’s environmental, health and safety programs. Scope This procedure applies to all of the company’s environmental, health and safety programs. Definition of terms • ARB Air Resources Board • VOC Volatile Organic Compound • POC Precursor Organic Compound • EPA Environmental Protection Agency • OSHA Occupational Safety and Health Administration • RCRA Resource Conservation Recovery Act which regulates all haz- ardous waste from “cradle to grave.” • EH&S Aspects those elements of the business’ activities, products and services which can interact or impact with the environment, people and property. • Environmental, Health and Safety Committee The organizational body within the company which has the responsibility for reviewing the status of the company’s environmental, health and safety programs on a periodic basis (need to specifically identify) and making recommenda- tions/suggestions for corrective actions and improvements. • TWA Time Weighted Average Reference documents Company Documents • QAP 12345, Corrective and Preventive Action Procedure • QAP 67891, Management Review Procedure ©1998 CRC Press, LLC • QAP 13579, Calibration Control of Measuring and Test Equipment • SOP 24681, EH&S Controlled Documents • SOP 13963, Waste Minimization and Pollution Prevention Program • SOP 14843, Air Sampling Regulatory • 22 CCR Chapter 1, Article 1, Waste Management Act • 22 CCR Section 67750, Hazardous Waste Source Reduction and Manage- ment Review Act • ARB Rules and Regulations 1-543, 2-1-403 and 1-404 International Standards and Practices • ISO 14001, Element 4.3.1, Environmental Aspects • ISO 14001, Element 4.5.1, Monitoring and Measurement • ISO 9001, Element 4.11, Control of Inspection, Measuring and Test Equipment • ISO 14001, Element 4.4.1, Structure and Responsibility EH&S precautions • Personnel who are responsible for obtaining monitoring and measurement data in areas or at processes which pose actual or potential significant hazards should observe all personal protective equipment requirements. Precedence This procedure shall only be superseded by specific and required conditions or data collection techniques as prescribed by local, state and/or federal regulations. Responsibilities Environmental, Health, and Safety Manager • Approve all outside vendors who have been contracted to conduct mon- itoring and measurement of an environmental, health or safety subsystem. • Approve all EPA approved analytical laboratories including test methods, equipment requirements, etc. • Provide final approval of any reports and/or data submitted by an outside contractor. • Submit reports of monitoring and measurement data to appropriate local, state or federal regulatory agencies as required. • Communicate the monitoring and measurement requirements to appropri- ate personnel. • Assist in establishing the systems, procedures and forms to collect or assemble the monitoring and measurement data. • On a periodic basis (as prescribed in the procedure section) collect the data. • As prescribed either by regulatory requirements or internal procedures, report the data results to appropriate personnel. The reports may be used: — As an update of the status of department-specific objectives and targets; —For submittal for regulatory compliance; and/or ©1998 CRC Press, LLC — By the Management EHS Committee as an update of the status of the company’s overall objectives and targets. This review may result in a change in some objectives and targets and potential corrective actions stemming from nonconformances. • Distribute annual reports to company senior management for review and evaluation for the potential purposes of changing the Environmental, Health and Safety Policy, standards and guidelines, procedures and/or the estab- lishment of new annual objectives and targets. Company Employees • Ensure all logs, data collection forms, or computerized data collection systems are completed as required by the process. Department Management • Ensure personnel who are direct reporters understand and complete the requirements. Tools N/A Materials N/A Procedure A. Flowchart (Appendix A) B. Reporting Schedule (Appendix B) C. Environmental, Health and Safety Manager 1. Determines if the monitoring, measurement and/or reporting is per regulatory requirements or per other (company, divisional, site, corpo- rate, industry standard, etc.) D. EPA Requirements 1. Air Emissions (VOC and POC) shall be monitored on a monthly basis. Summary data is obtained by adding up the total quantity of VOC or POC chemical used during the previous month. The amount of VOC or POC chemical used over the previous 12 months shall not exceed the maximum quantity allowed under the CONDITIONS of the Permit-to-Operate issued by the ARB. Monthly reports are distributed for review to appro- priate departments, management, and the EH&S Committee. 2. Liquid and Solid Hazardous Waste is tracked using the RCRA- approved Hazardous Waste Manifest. The manifest is completed when- ever a hazardous waste is prepared and transferred from the facility. The quantifiable data on the form is logged into the EH&S department’s hazardous waste database. Monthly reports of department-specific waste generation are distributed for review and comparison against department goals and objectives. A summary report is reviewed on a monthly basis by the EH&S Committee. E. OSHA Requirements 1. Injuries and Illnesses are recorded as each event occurs. At the end of the second week of each month, the Worker Protection group distributes ©1998 CRC Press, LLC APPENDIX A. Procedure flowchart. ©1998 CRC Press, LLC APPENDIX B Reporting Schedule Table Monthly Quarterly Annually Data/Metric Dept. Team Corp. EH&S Senior Mgmt. EH&S Comm. Dept. Team Corp. EH&S Senior Mgmt. EH&S Comm. Dept. Team Corp. EH&S Senior Mgmt. EH&S Comm. 1. Air Emissions • • • • • • • • • • • 2. Liquid HazWaste • • • • • • • • • 3. Solid HazWaste • • • • • • • • • 4. Injuries/Illnesses • • • • • • • • • • 5. Noise Surveys • • • • • • 6. Air Sampling • • • • • 7. Process Ventilation • • • • 8. Utilities • • • • 9. Process Gas • • • • 10. Recycled Material • • • • ©1998 CRC Press, LLC the OSHA 200 log. Data from the log is analyzed to update department- specific and overall company metrics. Monthly reports are distributed per the schedule in Appendix B. 2. Noise Surveys are contracted out to an approved vendor. Area and personal dosimetry monitoring is required to provide measurement of a person’s exposure to noise based on an 8-hour Time Weighted Aver- age (TWA). Area monitoring is also conducted to assess community noise concerns from the facility. The draft and final reports are evalu- ated by EH&S with results distributed to appropriate personnel and management. Specific measurements may be used to implement control measures (engineering, administrative and/or personal protective equipment). 3. Air Sampling is conducted per the requirements detailed in SOP 14843. 4. Process Ventilation monitoring is conducted by an outside vendor. Measurements for flow rate, face velocity and/or capture velocity are conducted and subsequently posted on the source. The final report is reviewed by EH&S to assess and implement control measures for any part of the system which is deficient. F. Other Requirements 1. Utility Consumption data for power, water and natural gas is monitored by the local utility agencies. Results for the company are consolidated on a monthly basis by the Facilities Department and copied to the EH&S Department. Data analysis results are reported to the EH&S Committee on a monthly basis showing current performance against objectives and targets. 2. Processes Gas consumption is monitored by an in-line meter before entering the building and the total monthly volume is calculated. Data analysis results are reported to the EH&S Committee on a monthly basis showing current performance against objectives and targets. 3. The Recycling Program involves the separation of previously identified solid waste streams. The EH&S Department weighs each recyclable waste stream as it is transferred to an approved recycling vendor. The data is accumulated for analysis and is reported to the EH&S Com- mittee on a monthly basis. G. The EH&S Department determines if the monitoring of programs is to be done internally or externally (e.g., vendor or a corporate group). H. External Monitoring and Measurement 1. The EH&S Department contacts either the vendor or the appropriate corporate group. 2. The EH&S Department communicates with appropriate personnel or departments regarding the monitoring and measurement requirements. 3. The vendor conducts the monitoring and measurement. 4. The vendor submits a draft report to the EH&S Department. 5. Final draft is approved. 6. Report data is communicated to appropriate personnel (see Appendix B). ©1998 CRC Press, LLC I. Internal Monitoring and Measurement 1. The EH&S Department communicates with appropriate personnel or departments the monitoring and measurement requirements. 2. The EH&S Department assists in establishing the data collection sys- tem and collects the data. 3. Report data is communicated to appropriate personnel (see Appendix B). J. Department management and/or EH&S Committee modifies, updates or establishes new goals and objectives or implements corrective actions. 16.5 RECORDING OF INFORMATION Now that you have a procedure which defines the ISO 14001 requirements, the next step involves determining what kind of data you need to record and collect for reporting. When doing this, however, it is important to remember one of the basic requirements of Element 4.5.1: This shall include the recording of information to track performance, relevant oper- ational controls and conformance with the organization’s environmental objectives and targets. In other words, don’t spend your time recording and tracking data that will not provide you with any significant information and value — your data should relate back to your objectives and targets. In the next few sections I will provide some examples of spreadsheets and graphs which you might use as templates for setting up your own program. I will be focusing strictly on the recording and collection of environmental data in the areas of air emissions, hazardous waste, recycling, natural resources, and other community impacts. 16.5.1 A IR E MISSIONS Whether your company is located in an attainment or nonattainment area by the Air Resources Board and the EPA, the chemicals you emit into the atmosphere may perhaps have the greatest tendency to draw attention from your neighbors and the local regulatory agencies. This is especially true due to the large amount of media attention being given to the chemicals and industries creating global warming. If your company emits some form of vapor or gaseous substance (whether harmful or not), the local public and nongovernmental organizations (NGOs) will be paying much more attention to you. Thus having objectives and targets to minimize your emissions may be based solely on the influence of “other interested parties” and not because of any regulatory requirements — your objective may be to maintain a good relationship with your neighbors. In this first example, I am going to assume that you have a particular operation that requires a permit-to-operate from the local Air Resources Board. In addition, the permit-to-operate has requirements or conditions which must be met and that the condition is not to exceed the use of a given quantity of a Volatile Organic [...]... 23.03 57 0.07 65 0.191 57 .26 75 34.23 75 May 1.3 1.9 0. 15 18.3 0.09 2.7 0.02 24.46 61 0.0808 0. 157 61.2378 36.7778 June 1 1.7 0.14 19.6 0.11 3 0.03 25. 58 63 0.11 05 0.183 63.29 35 37.71 35 July 1.2 1.9 0.1 18 .5 0.12 3.2 0. 05 25. 07 65 0. 055 3 0.14 65. 1 953 40.1 253 August 1.3 2 0. 15 19.7 0.14 3.3 0.06 26. 65 69 0.0383 0.264 69.3023 42. 652 3 Sepember 1.4 2.6 0.18 20.3 0.11 3.2 0. 05 27.84 65 0.00 85 0.234 65. 24 25 37.40 25. .. 7,0 25 23,660 108,810 0.0026 0.0026 June 63 344 8,600 27,668 136,478 0.0023 0.0026 July 65 409 10,2 25 31,0 05 167,483 0.0021 0.0024 August 69 478 11, 950 26 ,55 5 194,038 0.0026 0.00 25 September 65 543 13 ,57 5 27,8 45 221,883 0.0023 0.0024 October 63 606 15, 150 29, 457 251 ,340 0.0021 0.0024 November 60 666 16, 650 25, 893 277,233 0.0023 0.0024 December 55 721 18,0 25 28,7 65 3 05, 998 0.0019 0.0024 Target 750 18, 750 ... 0. 05 27.84 65 0.00 85 0.234 65. 24 25 37.40 25 October 1 .5 2 .5 0. 15 21.4 0.12 3.1 0.07 28.84 63 0.0383 0.2 63.2383 34.3983 November 1.6 2.7 0.18 22 0.16 3.1 0. 05 29.79 60 0.0128 0.28 60.2928 30 .50 28 December 1 .5 2 .5 0.19 22.3 0.18 3 .5 0.06 30.23 55 0.00 85 0.208 55 .21 65 24.98 65 14.6 26 .5 1.92 237.9 1 .53 35. 4 0.47 318.32 721 0 .54 85 2.176 723.72 45 4 05. 40 45 Total 70 60 50 40 30 20 10 0 Jan Feb March April May... Waste Sum (oz.) Parts Produced (Qty./1000) Total Parts (Qty/1000) Rate January 640 640 9,300 9,300 0.069 February 640 1,280 22,000 31,300 0.041 March 1280 2 ,56 0 25, 3 75 56,6 75 0.0 45 April 1280 3,840 28,4 75 85, 150 0.0 45 May 1920 5, 760 23,660 108,810 0. 053 June 256 0 8,320 27,668 136,478 0.061 July 1280 9,600 31,0 05 167,483 0. 057 640 10,240 26 ,55 5 194,038 0. 053 August Sepember 0 10,240 27,8 45 221,883 0.046... tables and charts, this information allows you to track performance ©1998 CRC Press, LLC TABLE 16.4 1997 Solid Waste Generation Month Tons Sum Total Total Cost ($ 25/ ton) Production (ϫ M) Total Prod (ϫ M) Monthly Rate Annual Rate January 48 48 1,200 9,300 9,300 0.0 052 0.0 052 February 60 108 2,700 22,000 31,300 0.0027 0.00 35 March 55 163 4,0 75 25, 3 75 56,6 75 0.0022 0.0029 April 57 220 5, 500 28,4 75 85, 150 ... Waste and Recycling Metrics Month White Paper Cardboard Plastic Metal Glass Newspapers Mixed Paper Total Recycled Solid Waste Hazardous Waste Air Emissions Net Waste Net Impact January 1.1 2.1 0.11 20.3 0. 15 2 .5 0.01 26.27 48 0.0297 0.106 48.1 357 21.8 657 February 1.2 2.2 0.21 19.4 0.12 2.8 0.02 25. 95 60 0.04 25 0.128 60.17 05 34.22 05 March 0.9 2.4 0.22 18 .5 0. 15 2.4 0.04 24.61 55 0.0468 0.0 85 55. 1318 30 .52 18... Days to Comp 4/30/97 3/30/97 43 3/ 15/ 97 2/ 15/ 97 2/ 15/ 97 1 2/ 15/ 97 3/21/97 3/21/97 2 3/20/97 1 4/06/97 4/06/97 4 4/10/97 3 6/ 15/ 97 5/ 31/97 15 5/30/97 Area Source Request Class 9 7-0 01 1/30/97 Joe S QC ISO 9001 audit Personnel are not certified to SOP #123 45 3 9 7-0 02 2/ 15/ 97 Peter K Health & Safety OSHA inspection Machine guard does not adequately protect operator 1 9 7-0 03 3/18/97 Pat D Cell 1 ISO 14001... two standards have a requirement to write and implement a procedure to identify and maintain all quality and environmental records These documents can be in either hardcopy (paper) or softcopy (computer/electronic) form as long as they are readily available and retrievable by personnel who need them 18.2 COMPARISON OF THE STANDARDS Table 18.1 shows a side-by-side comparison of the two standards and you... Once per week 0.4–0 .5 Low 6–7 Once a month 0.2–0.3 Rare 5 6 Once a quarter Very rare 4 5 Every six months 0. 05 0.1 0.1–0.2 Extremely rare 3–4 Once a year 0.01–0. 05 None 1–3 Decade or more . 30 .50 28 December 1 .5 2 .5 0.19 22.3 0.18 3 .5 0.06 30.23 55 0.00 85 0.208 55 .21 65 24.98 65 Total 14.6 26 .5 1.92 237.9 1 .53 35. 4 0.47 318.32 721 0 .54 85 2.176 723.72 45 4 05. 40 45 CHART 5. Waste and recycling. 0. 15 2 .5 0.01 26.27 48 0.0297 0.106 48.1 357 21.8 657 February 1.2 2.2 0.21 19.4 0.12 2.8 0.02 25. 95 60 0.04 25 0.128 60.17 05 34.22 05 March 0.9 2.4 0.22 18 .5 0. 15 2.4 0.04 24.61 55 0.0468 0.0 85 55. 1318. 25. 58 63 0.11 05 0.183 63.29 35 37.71 35 July 1.2 1.9 0.1 18 .5 0.12 3.2 0. 05 25. 07 65 0. 055 3 0.14 65. 1 953 40.1 253 August 1.3 2 0. 15 19.7 0.14 3.3 0.06 26. 65 69 0.0383 0.264 69.3023 42. 652 3 Sepember