GreenUp Academy

Leadership Responsibilities of ISO 14001:2015

The new version of ISO 14001 puts an incredible amount of emphasis on the top management of an organization. Previously, it was still well known that unless the top management is on board in terms of implementing and environmental management system (EMS), it’s nearly impossible to have an effective and well functioning EMS. The terms “top management”, “senior management” and “leadership team” have been used interchangeably in this article.

Based on my experience in five (5) different countries of auditing and consulting, I’ve witnessed some different scenarios:

1. Top management feels like the EMS and ISO 14001 certification is useless and nothing but a paperwork burden, a waste of time and energy. EMS is implemented at its bare minimum. The only reason it’s implemented is either because a customer or corporate requires it.

2. Top management appointed a person with no environmental background or training to implement the EMS on their own, and the person does not have the resources, the authority or the knowledge to do anything. In addition, the appointees are not supported by top management.

3. Top management is heavily involved and hands-on in implementing the EMS. They support the environmental department, they walk the talk, and they established a good bridge between the environmental department and the operations.

Of course, these are not the only scenarios that can be seen out there! It’s not that hard to guess which EMS will function well and be successful right? You guessed it, it’s number 3!

It’s so important to understand that without the full involvement and support of the top management, it just won’t work!

Let’s take a quick look of what ISO 14001:2015 requires from top management:

  • Overall responsibility of the EMS effectiveness
  • Ensuring that the strategic direction of the organization is in line with the EMS objectives, environmental policy, internal and external issues of the organization, EMS intended outcomes and interested parties and their requirements from the organization
  • Allocation of proper resources: human, financial, knowledge and any other resource that would be required to effectively implement the EMS
  • Being knowledgeable about the regulatory compliance status of their organization
  • EMS has to be integrated with the company’s activities. EMS needs to be interlinked with business instead of being implemented separately. It’s the senior management responsibility to make this become a reality.
  • Effective EMS communication
  • Effective EMS support
  • EMS continual improvement

There has to be demonstrable evidence for these requirements. Obviously, trying to get ready three days before a registrar audit may not be a good idea!

How can the leadership team demonstrate these requirements? There are so many different ways. I will share the ones that I witnessed working the best for different companies:

  • Periodic environmental site inspections (weekly, monthly, etc.) They could be alternated among the leadership team members.
  • Staff meeting agendas including EMS items
  • Giving priority to EMS issues and corrective actions. It never looks good when an auditor comes on site, and observes that the EMS corrective actions have not been fixed for months, and no action was taken by the senior management.
  • Leadership team attending ISO 14001:2015 or other EMS related courses (i.e. webinars, internal auditor, regulatory, etc.)
  • Leadership team understanding ISO 14001:2015 requirements including EMS and regulatory expectations
  • The visibility of adequate resource allocation at a facility: evaluation of compliance is conducted by competent people with proper background, the EMS is not individualized (facility-wide high engagement level), EMS representatives are well trained, etc.
  • Holding management teams accountable
  • Applying effective enforcement
  • Each senior management team will be responsible for an environmental program. For example, the plant manager can own the stormwater program, and the director of operations can own the hazardous waste program, etc. They can delegate the requirements of these programs, however, ultimately, they would be responsible of correct and compliant implementation of those programs.
  • Aligning operational key performance indicators with EMS objectives and actions planned.
  • Incorporating EMS requirements into performance reviews, bonus structures throughout the organization.

These are just a few examples.

My advice to environmental staff who are working on ISO 14001: Please make sure that your leadership team is aware of all these requirements.

My advice to the members of the leadership team: Please understand and be aware of ISO 14001:2015 requirements and the environmental regulatory responsibilities of your company including the needs and expectations of all your interested parties.

Please support your environmental folks by empowering them with proper resources and authority. Always remember that establishing, implementing and maintaining an EMS is never only one person’s job, but it belongs to the entire company and ultimately, you, as the leadership team of the organization, are responsible for the success of your EMS.

Thanks for reading and good luck!

Mel DeGregorio                                                                                                                                  ISO 14001:2015 Lead Auditor

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Memories from GreenUp Academy’s March 7-9, 2018 ISO 14001:2015 Implementation and Internal Auditor Course in Daytona Beach

Dolphins racing with our boat

Who says we have to do the training in a conference room when we can do it on a boat? We are in Florida after all!

We start out in our conference room here in Daytona Beach, then we take the course to sometimes to a cafe with an ocean view or a rooftop bar for with a panoramic view…

We definitely continue our course on a lovely boat cruising around, observing dolphins, pelicans and other wildlife in the area, while conducting our group work…

We offer delicious breakfast, and a variety of fun refreshments to look forward to throughout the day!

Come learn with us and have fun at the same time… Click here to see our upcoming course schedule

We completed this session with flying colors! Check us out! These pictures are from the last day of our training where we conducted parts of the mock audit while touring the beautiful Intercoastal Waters of Daytona Beach…

Florida Pelicans

Florida Pelicans – We are responsible to protect the environment including the wildlife. Isn’t it what ISO 14001 all about?

White pelicans

White Pelicans

Internal auditing at its best!

Internal auditing at its best!

Boat Tour

Boat Tour

Captain Charlie gave us a great tour

Captain Charlie, the one and only, always gives us a great tour! Thank you Captain Charlie!

 

 

Course Schedule

Below, please click on each link to see the schedule:

ISO 14001:2015 – How to Master a Smooth Transition?

ISO 14001:2015 Implementation and Internal Auditor Course

14001:2015 Implementation 6-Hour Live Webinar

Live Webinar: “Stormwater Regulatory Compliance”

Live Webinar: “How to Manage Universal Waste?”

Live Webinar: “EPCRA Tier II Reporting Demystified”

Live Webinar: “Hazardous Waste Management Simplified”

EPA Region 1 EPCRA /RMP/GDC Training Presentation

Environmental Protection Agency Region 1, created a presentation regarding Emergency Planning Community Right-to-Know (EPCRA), Risk Management Plan (RMP) and General Duty Clause (GDC).

I would like to personally thank Mr. Len Wallace, who is an amazing EPCRA Guru and so much more for this presentation. I have been attending his workshops as a consultant for years. He always has been an incredible resource, and has been so pleasant to speak with while sharing his knowledge.

Here it is:

EPCRA by EPA Region 1

 

 

EPCRA Tier II Reporting

EPCRA Tier II Reporting

Hello,

Today is January 9th. The submission due date of March 1st for EPCRA Tier II reporting is approaching fast! Let’s have a refresher on Emergency Planing Community Right-to-Know Act (EPCRA) Tier II reporting requirements. Here is what we are going to talk about on this article:

  • EPCRA History
  • EPCRA Section 312 – Tier II Reporting Requirements
  • Lead-Acid Battery Reporting
  • Reporting Tips
  • Most common findings and issues regarding EPCRA Section 312
  • Resources

EPCRA History                                                                                                                                    You might have heard the same regulation as SARA Title III, Right-to-know report, chemical inventory reporting or EPCRA Section 312. They all refer to the same regulation. To find out about the history of EPCRA, check out these links:

30 years of EPCRA by the US Environmental protection Agency (EPA)

EPCRA through time by National Association of SARA Title III Program Officials.

EPCRA was passed by the Congress in 1986 two (2) years after an industrial disaster occurred in Bhopal, India. Check out this video to find out more about this disaster:

Bhopal, India Disaster

EPCRA Section 312 – Tier II Reporting Requirements  

These requirements have been codified under 40 CFR 370. Let’s take a look at EPCRA Tier II requirements: In a nutshell, according to these requirements, if you stored:

1- Any hazardous chemical (per OSHA Hazard Communication standard) in the quantity of 10,000 lbs or more (no list, all OSHA hazardous chemicals required to have an SDS) or

2- Any Extremely Hazardous Substance (EHS – listed under 40 CFR 355 Appendices A & B) in the quantity of 500 lbs or threshold planning quantity (TPQ- see the EPA Consolidated List of Lists, whichever is less, at any one time at your site from January 1st until December 31st, you have to report this chemical the following year by March 1st to the:

1- State Emergency Response Commission (SERC),
2- Local Emergency Planning Committee (LEPC) and
3- Local Fire Department

* Please refer to the regulation for retail gas station requirements regarding diesel fuel and gasoline at retail gas stations.

Check out under the resources below to find out more about Tier II reporting requirements.

Lead-acid Battery Reporting                                                                                                         

One of the most widely missed reporting requirements is reporting the lead-acid batteries. These batteries could be found in electric industrial trucks such as forklifts, and other industrial or construction vehicles.

The battery acid (sulfuric acid) in the electric forklift batteries is an EHS, and most importantly, whenever there is an EHS stored on-site, it has to be aggregated to see whether or not it exceeded the reporting threshold.

To calculate the quantity of the sulfuric acid, you can either:
– Check the SDS for the batteries,
– Call the manufacturer or
– As a rule of thumb, (I’ve learned this at an EPA training), you can take about 20% of the weight of the battery and calculate the amount of sulfuric acid

Remember to add up all other sulfuric acid that you stored during the previous calendar year at your site, to find the total quantity. Usually, one electric forklift battery could weigh about 2500-3000 lbs. so, even if you have just one forklift, you might be required to report.

Over reporting is not an issue, however, under reporting or not reporting at all is a violation of a Federal Act (EPCRA). EPCRA section 325 allows for civil and administrative penalties ranging from up to $21,916 – $164,3671 per violation per day when facilities fail to comply with the requirements.

There you have the Tier II reporting in a nut shell. There are so many other details, of course, to keep in mind. Everything you read above is my interpretation of the associated regulation. Please do not take this article as legal advice. Always refer to the most current regulation and consult with your attorney for any legal advice.

Based on my nationwide experience and observations, my goal is just to bring your attention to this very important regulation. Here is my advice:

Make sure you understand fully how to report and what to report to prevent any miscalculations or wrong reporting. If you choose to do the reporting on your own, great, just make sure you fully are comfortable with EPCRA Section 312 in its entirety. For a great refresher, check out our two (2) hour live webinar:

“EPCRA Tier II Reporting Demystified”

Reporting Tips:

  • Check with your state to find out the state specific reporting requirements
  • Check on the changes for the reporting year 2017
  • Identify your SERC, LEPC and Local Fire Department and confirm with each entity especially with the LEPCs to ensure that they are the right place to submit your report
  • Ensure that you have an adequate chemical inventory
  • Ensure that you accurately calculate the chemical quantities
  • Ensure that you aggregate the EHS present at your facility
  • Make sure that the Tier II report is signed by your responsible official (i.e. plant manager, president, director, etc.)
  • The report must be submitted by March 1st
  • Keep record of your submissions to all three authorities. If you mail it, send it certified or with trackable shipping service
  • Keep evidence of submission of the report by March 1st

Most common findings and issues regarding EPCRA Section 312 that I observed

  • Lead-acid batteries in the electric forklifts or other industrial equipment are not reported
  • Extremely hazardous substances are not aggregated to identify the final adequate reportable quantity
  • The proper Tier II software is not used.
  • “We stored the chemicals but we didn’t used them at all, so they’re not reportable”. The Tier II report is based on storing hazardous chemical or extremely hazardous substances on site, it’s not based on usage.
  • The Tier II report is submitted too late.
  • The Tier II report has not been sent to all three (3) authorities. Usually, LEPC or the local fire department submissions are missing.
  • The facility claims that they’ve submitted the Tier II report to all three (3) authorities, however, there is no evidence of submission.
  • Not following the requirements of EPCRA Section 302: If you have an EHS at your site at quantity more than the TPQ of that EHS, then, EPCRA Section 302 requirements would also apply. For example, one times submission of the EHS, mandatory meetings at the LEPC, etc. Please refer to EPCRA Section 302 requirements for further details.

Resources

The resources below should also help greatly:

List of Lists

State Tier II Reporting Requirements and Procedures:

State Emergency Response Commissions Contacts

Tier2 Submit Software

2017 Tier2 Submit Tutorial

EPCRA Fact Sheet

EPA’s e-Disclosure

If you need help, or prefer a third set of eyes to take a look at your chemical storage and applicable Tier II reporting requirements to your facility, call or email us. We would be happy to do it for you. We have been reporting EPCRA Tier II and TRI reports for our nationwide clients since 2008. Just let us know.

Thanks for reading!

meldegregorio@greenupconsultants.com

GreenUp Consultants, LLC – GreenUp Academy, LLC
Owner/ Principal Consultant
ChE, M.S.
Exemplar Global certified Lead Auditor:
EMS – OHSAS – EHS Regulatory Compliance
QMS – e-Stewards/R2/RIOS Lead Auditor

 

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