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Operational Control

Establish, implement, monitor, measure, and maintain with change management control of functions, activities, and processes that can impact the environment.

Top management leads by ensuring that process activities that were identified as having significant environmental impacts or legal requirements put operational controls in place. Operational controls may be in the form of operating procedures, preventative maintenance, equipment controls, etc. that contribute to the prevention of pollution.

Consideration needs to be given not only to normal operations but also to abnormal and emergency situations, as well as ongoing improvements or projects. For example, when controlling air emissions from a manufacturing process you need process controls and procedures for operational control of the equipment, emergency plans, and standing operating procedures; when there is a shutdown of the equipment, there may be other operating controls that are required.

Facilities need to be designed and managed, taking into consideration the property in which they are situated and the surrounding areas: whether they are residential or industrial and the impact they have on the air, water, land, flora, and fauna. Operational procedures should also address suitable maintenance of equipment and continuing process capability and regulatory compliance. A preventative maintenance program could save time and money, materials, chemicals, energy, etc. if areas are routinely managed.

The environmental standard for ISO 14001 requires that operations related to identified significant environmental aspects, which are carried out in an initial environmental review when setting up an environmental management system, establish documented procedures to control situations where their absence could lead to deviations, stipulating the operating criteria. Documents assist in ensuring that internal controls are complete, properly approved, and maintained, and revised when changes occur.

The following are examples of operational control procedures that your organization may have in place: production/manufacturing, procurement, logistics, energy management, waste management, materials management (including capital asset disposal), chemical management, wastewater treatment, operation and maintenance of equipment (boilers, fume hoods, storage tanks/silos), real estate acquisition or construction (demolition, salvage), contractor orientation, facility management (snow and ice removal, pesticides), quality assurance, laboratory operations (calibration, sampling, cleaning), emergency preparedness, start-up and shut-down of equipment, facilities, or processes, research development, construction, and decommissioning of equipment and facilities.

It is important to have other documents that are utilized by the company tied with operations referenced to the appropriate procedures, such as the site plan for the facility, process flow diagrams, listing and location of sampling points, and manufacturer's operating manuals provided for specific equipment.

In some cases, you may need to work with suppliers or contractors, who may assist you in operational controls. It is essential that you work in close partnership with them to ensure that they maintain your EMS standards in such areas as disposal of waste materials, handling and disposal of hazardous materials, and conserving of energy and water resources. It is also important to ensure that they have the correct permits and are following the associated legal requirements.

As mentioned earlier, tied with the quality management, many managers today are close to retirement and if procedures or information about business operations are not captured on paper, they may be lost forever.

It is important when developing operational control procedures that the action items are simple and concise (short form if possible), outlining the sequence of the steps and the persons involved. Should specific forms or records be required, identify what they are and where they are kept. Generally, the workers responsible for the significant aspects under consideration will be responsible for implementing the controls, and it is important that they understand what is required; this can be accomplished through on-the-job training or specific classroom training.

Today there are many automated systems at work stations outlining the operational procedures for tasks.

It is important to have a process in place for management of change, as this triggers not only changes to documents but also the need to provide training to ensure competency of relevant personnel to perform activities in conformance with the new operational controls. It is also important to communicate with appropriate contractors or suppliers related to applicable changes, as the organization is responsible for environmental impacts caused by them on their property. It is crucial then to ensure that contractors and suppliers are aware of your EMS requirements and abide by them.

Another area of concern tied to operation controls is when temporary or seasonal workers are hired to perform work within the organization. Many times young students are brought in for short periods of time, and the period of training and document review is then shortened. They can be a risk to the organization if they are not aware of your environmental impacts and how they are to conduct themselves.


Focus: Environment – Prevention of Pollution

1 What activities within your organization can cause environmental impacts and has your organization implemented operational procedures for these areas?

a. How do employees, temporary employees and contractors access them?

b. How do you monitor that these operational controls are being followed?

c. What nonconformances are tied with operational control at your facility?

2 How do you ensure that appropriate workers and contractors are aware of your operational procedures?

a. Orientation programs

b. Contractor programs

c. Visitor programs

3 Facility management is an important area to ensure environmental impacts are managed. Who is responsible for this at your organization? What programs are in place to track energy and water consumption?

4 When developing operational procedures, who is responsible for writing the procedures and who is responsible for approval of the procedures? How often are procedures reviewed and by whom?

5 How do you manage changes that occur within your organization and ensure that these are updated in the operational procedures?

6 How do you encourage your suppliers to improve their environmental performance and support your initiatives?

a. Do you encourage your suppliers to have an EMS that meets ISO 14001?

b. Do you ask your supplier for copies of its operational procedures related to the work it is providing? Or copies of permits and certificates?

c. How do you ensure that your suppliers are meeting legal requirements tied to the environment?

d. Do you use supply-chain software (e.g., for electronic document exchange, such as purchase orders, sharing of information on invoices, tracking inventory, determining when products are to be delivered)?

7 What operational programs do you have in place for the following?

a. Facilities

b. Preventative maintenance

c. Contractors

d. Production processes. Design reviews (environmental)

e. Equipment performance and emissions monitoring

8 Do your procedures define who has the authority and responsibility for activities, and when, how, and with what resources they are to be performed?

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