Environmental aspects – What evidence exists that the organization has established, implemented and maintains (a) procedure(s) to identify the environmental aspects of its activities, products or services within the defined scope of the Who was involved in determining aspects?
Were air emissions, posshible ground and surface water contamintation, landfill issues, use of natural resources, raw materials and energy considered as well as community issues such as noise, traffic and odor?
Are current, planned and modified activities considered? Look for potential aspects that have not been taken into consideration and ask why they were not considered. How are significant environmental aspects determined?
Does the decision making process take into consideration inputs and outputs, normal and abnormal operating conditions, start ups and shut downs, actual influences, potential influences and potential emergency situations, as well as those that are beneficial to the environment?
Does the decision making process take into consideration the amount of control and influence the organization has over its aspects? Look for procedures.
How/when are aspects reviewed and maintained; changes to processes, changes to regulations, introduction of new raw materials?
Does the documentation reflect this change?
Legal and other requirements – Has the organization established, implemented and do they maintain a procedure(s) to identify and have access to the applicable legal requirements and other requirements to which the organization subscribes, related to its environmental aspects and determined how these requirements apply to its environmental aspects?
What is the procedure regarding this requirement? How does the organization know what regulations and requirements they may be subject to? Do they subscribe to industry newsletters or websites? Do they have a third party environmental service monitor regulations for them and alert them as to any changes?
Is there a list of applicable rules and regulations?
Who is responsible for keeping this information updated and current?
Does the list include any voluntary standards?
How does the organization ensure it is complying with these regulations?
Speak with people in the organization to determine if they are aware of any regulations.
Did the organization consider national, international, state and local rules and regulations?
Does the organization have any agreements with public authorities, or with customers?
Do they subscribe to any voluntary guidelines or industry practices such as Responsible Care?
What process does the organization have for reviewing requirements to make sure they are current in the face of changing processes and business requirements?
Do regulations include such things as Federal Title V or Synthetic Minor, State Emissions Inventory and Permit Fee Program, Regulated Toxic Air Pollutants ENV-A 1400, SARA Title III Toxic chemical releases, SARA Title II Tier II report, Federal EPA clean water act, National Pollution Discharge Elimination systems (NPDES) and Storm water program permit?.
Check the organization’s objective and targets to determine if requirements are included. Was the selection of significant aspects based partially on applicable legal requirements and other requirements?
Objectives, targets and programs – Are the objectives and targets measurable, where practical, and consistent with the environmental policy, including the co mmitments to prevention of pollution, to compliance with applicable legal requirements and with other requirements to which the organization subscribes, and to continual improvement?
How does the organization develop objectives and targets? Who is responsible for developing them? What types of things were taken into consideration during development? Were reducing the creation of waste, reducing the release of specific elements to the air, reducing ground water contamination, reducing use of raw materials by reducing rework and scrap, taken into consideration? Was promoting awareness within
the organization and the surrounding community considered?
Do the objectives and targets reflect the vision of the EMS policy? Are they consistent with the policy?
Do they include commitments to the prevention of pollution and compliance with applicable rules, requirements and
regulations?
Have measurable targets been defined? If not, why not?
Are targets both short and long term?
What factors does the organization consider in setting objectives and targets? How are significant impacts considered? Are legal and other requirements, available technology, financial, operational and business requirements considered? Were interested parties involved in the development of objectives? If so, how?
How were objectives developed? Who participated in their development?
Has the organization established, implemented and does it maintain a program(s) for achieving its objectives and targets, including designation of responsibility for achieving objectives and targets at each relevant function and level of the organization and the means and time-frame by which they are to be achieved?
What plans have been developed to achieve objectives and targets? Do plans include responsibility for achieving the objectives and targets? Do plans reflect objectives and targets at lower levels of the organization? Does the plan include its own targets and timelines for reaching them?
Look at plans. Is there one for every objective and target? What happens when something doesn’t go
according to plan? Is corrective action taken?
How is management kept informed of the progress towards the targets?
How are employees informed of the progress towards the targets?
Look for graphs, information in newsletters, meeting minutes, and posters.
How does the organization plan to achieve objectives and targets?
Have responsibilities been defined?
Have time lines been defined?
How is progress monitored? Is it measurable?
