Initial Review Of Gap Analysis In ISO 14001

A fundamental concept of the ISO 14001 EMS Standard is continual improvement of environmental performance. Before you can plan for improvement, you must first determine the current state of the organization’s environmental programs.

The initial review or gap analysis is, in itself, a microcosm of a well-organized approach to the entire ISO 14001 EMS development process. Each specification of the standard must be reviewed, including policy, legal requirements, training, objectives and targets, operational control systems, document control, auditing, management review, and corrective action.

The review should take into account the culture, products, marketing strategies, and other specifics of the organization. In all cases, consideration should be given to the full range of operating conditions, including possible incidents and emergency situations that may be encountered.

The ability of suppliers and subcontractors to comply with the Organization’s EMS program and applicable regulatory requirements should also be evaluated. It is strongly recommended that the initial review consider energy use, financial accounting, and information systems so that these issues may be integrated into the EMS program.

To effectively begin the Initial Review, several things must happen. First, Management should issue a company-wide announcement of intent and endorsement. This should include estimates of the time required to complete the Initial Review, and time required to complete the entire project. Second, the project leader should be identified and vested with ample authority for completion of the project.

The Initial Review is a review of all pertinent documents, from which an accurate plan is designed for the EMS Gap Analysis.

All information from the review, including deviation from regulatory requirements and adverse impacts on the environment, should be identified along with policies, programs, procedures, training and work instructions, and operational controls.

A portion of the project team should begin to assemble a registry of appropriate regulations identified during the Initial Review. All pertinent national, state, local and self-subscribed requirements should be assembled. They should be compared with identified environmental impacts.

An Initial Review is also important in ensuring that EMS design is compatible with all current organizational management structures and operations wherever possible. This is especially important where the EMS interfaces with the site’s existing health and safety, accounting, computer systems, purchasing, energy utilization and other management programs. The focus will be to achieve operational efficiencies that ensure environmental improvements and maximize cost reductions.

Initial Review outputs will be:

· An EMS Gap Analysis Design that details where existing environmental management procedures must be further investigated to determine conformance with the Standard.

· A review of the site’s overall environmental management strengths/weaknesses.

· A schedule of events for the Gap Analysis.

The gap analysis allows for a quick but comprehensive assessment of the facility’s existing environmental management practices and procedures, and compares them

with the requirements of the Standard. To perform the Gap Analysis, a standard template tailored for that specific purpose is used. The template is a questionnaire with a three way scoring system, which develops a final rating of the current programs of the site as they compare with the sections of the Standard. The score from this questionnaire and investigative template identifies which areas of the EMS might be enhanced to improve environmental performance and comply with the Standard.

Based on the results of the Gap Analysis, the project schedule and design may require modifications. Modification should precede further systems development. Using the results of the Gap Analysis, the EMS developmental process can now begin.

This may involve modifying existing procedures, adapting other business procedures such as those designed for health and safety, accounting, or risk management to environmental utilization. At certain points, new procedures will be required.

Prior to embarking on EMS development, always remember that the more flexible your EMS is, the easier it will be to implement and the more flexible it will be in the future.

EMS AUDITING CONCEPTS AND ISO 14000

The Environmental Management System (EMS) audit is based on the generic concept of auditing. Simply put, an audit, any audit, is the comparison of actual conditions to expected conditions, and a determination as to whether one is in conformance or not in conformance. This is the same philosophy used to perform financial, quality, regulatory compliance, and systems audits. It is prudent to first review what the common elements are in order to better understand why audits are different.

There are several definitions of audit components that are common to any type of audit. ISO 14001 defines these terms for EMS audits, but they apply in other cases also. As a matter of fact, the ISO committee decided not to create auditing standards for other types of audits, such as compliance audits, although it was originally considered. The main reason for deleting the work items was because the concepts and processes defined in 14011, originally intended for EMS audits, were generic enough to be applied “as is” to other types of audits.

An audit is fundamentally a comparison of audit evidence to audit criteria to determine findings. The evidence is the objective information collected through interviews, visual reconnaissance, and documentation review. The audit criteria are the expectations or “rules” of how conditions should be. It is the criteria that distinguish one audit from the next. For example, in compliance auditing, the criteria are the regulations. With an EMS audit, the criteria would be the description of the expected system elements. In this case, the EMS criteria would be that described in ISO 14001, the specification standard.

When evidence is compared to criteria, one can determine whether the audited entity does or does not conform. This determination is a finding, and a finding can either be one of conformance, or non-conformance. Therefore, an audit will always produce findings, even if what is being audited is in full conformance with criteria.

Other key definitions to be aware of with auditing are: objectives, scope, auditee, client, and auditor. The audit objective(s) is simply why you are conducting an audit; usually the reason is to demonstrate conformance to stated criteria. The audit scope is what entity is being audited, and can be a company, a site, or unit within a site or company.

In the ISO 14000 realm, there is a clear distinction between the auditee and client. The auditee is the entity being audited. The client is the party commissioning the audit. For example, a client can be the customer, and the auditee a supplier to that customer. In ISO 14000, this distinction is important because the client sets the scope, objectives, and plan for an audit, not the auditee, although it is expected the auditee will be involved and cooperate.

The auditor is the one actually collecting evidence and determining findings. The auditor can be comprised of several individuals on a team. There are requirements in ISO 14001 that state that those performing functions within the EMS, such as the auditors, be qualified in their tasks. This means the auditors must have received training in EMS auditing. However, there may be audit team members who do not have the training, but are on the team because of some unique expertise, such as process, language, or regulatory knowledge.