ISO 14001

Environmental Management System (EMS)

Auditing Overview for the
Department of Interior

Linda Baetz, EMS-LA and Jim Wood, P.E., EMS-LA

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