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DEFENSE LOGISTICS AGENCY SELF-DECLARATION PROCESS. James Wood, P.E., EMS-LA Linda Baetz, EMS-LA US Army Center for Health Promotion and Preventive Medicine Jean Shorett, PhD Defense Logistics Agency. VALIDATING THE EMS:. DOD/DLA EMS Policy Guidance.
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DEFENSE LOGISTICS AGENCY SELF-DECLARATION PROCESS James Wood, P.E., EMS-LA Linda Baetz, EMS-LA US Army Center for Health Promotion and Preventive Medicine Jean Shorett, PhD Defense Logistics Agency VALIDATING THE EMS:
DOD/DLA EMS Policy Guidance • DOD EMS Policy Guidance – Apr 2002 • ISO 14001 framework permitted, but not required • Safety & Occupational Health integration encouraged, but not required • DOD EMS Metrics Guidance – Jan 2003 • DLA EMS Policy Guidance – Jun 2004 • Mission-focused • 1SO 14001 by December 31, 2005
Validation of EMS (ISO 14001) • 3d Party Registration (DOD/DLA Policy) • No “routine” 3d party registration • Only pursued if “clear and documented benefit to mission” • Self-Declaration of EMS • Allowed under ISO 14001, Section 1 • OFEE Self-Declaration Guidance • DLA Self-Declaration Protocol
OFEE Guidance • OFEE Self-Declaration Protocol –Sep 2003 • Each Agency should develop Self-Declaration protocol NLT 31 Dec 2004 which includes: • Direction on the use of evaluation guides • Direction on the frequency of internal evaluations & independent review; make-up of the review team; independent reviewer qualifications; and requirement for the management to make an EMS self-declaration statement • Direction on documenting/using EMS evaluation results • A schedule for reviewing EMS self-declaration procedures
DEFENSE LOGISTICS AGENCY • Mission: Provide world-wide logistics support to DOD • Appropriate Facilities: 147 • Field Activities: • DLA HQC • Defense Supply Center Columbus • Defense Supply Center Philadelphia • Defense Supply Center Richmond • Defense Energy Support Center • Defense Distribution Center • Defense Logistics Information Service • Defense National Stockpile Center • Defense Reutilization and Marketing Service • Document Automation and Production Service
EMS Validation – DLA Approach • DoD EMS metrics already completed • EMS must be mission-focused and ISO 14001 conformant • Site Director concurs at key points • DLA EMS-Self Declaration has two parts • 3d Party Registration – ok with “clear and documented benefit to mission”
DLA Self-Declaration Protocol • DLA Protocol finalized in Dec 2004; undergoing update • Incorporates OFEE principles • Designed to validate both initial and continuing EMS conformance • Designed for both ongoing evaluation and continual improvement
DLA Self-declaration Process • External mission-focused EMS review • EMS conformance to ISO 14001:2004 • Part I – Web-based EMS documentation review • Part II – On-site EMS verification review (1/3 of activities over 3 yrs – then every 3 years) • 3rd party registration when clear (and documented) benefit to mission
DLA Self-declaration Process • Activity posts EMS documents on DLA EMS website • Activity EMS status briefed to Site Director • Site Director concurs – triggers web-based review of EMS by DLA Qualified Reviewers • Reviewers identify EMS documentation conformance or areas of non-conformance • Complete corrective actions briefed to Site Director • Site Director Self-Declares Initial EMS Conformance
DLA Self-declaration Definitions • DLA Qualified Reviewer-completed EMS audit training course (DLA-approved) • EMS Audit Team (independent) • Team leader (DLA Qualified Reviewer) • 1 or more reviewer (DLA Qualified Reviewer)
Part II: On-Site EMS Review • Identify scope – DLA EMS reviews are fence-to-fence • Ensure documentation & records are available • Ensure key individuals are available • Ensure employees are familiar with the DLA Activity’s Environmental Policy Statement (and the environ. considerations of their job) • Assign primary focal point for review team
During/After the On-Site EMS Review • Review team presents in-briefing/out-briefing to Site Director and EMR • Review team gathers evidence through document/records review, interviews, etc. • Review team documents EMS conformance and any findings of non-conformance • Review team prepares report of findings and EMS conformance status
Corrective Action (CA) and Documentation Process • EMR proposes CAs w/ Site Director concurrence to review team (w/i 30 days) • EMR w/ Site Director concurrence provides documentation to review team that CAs are complete • DLA HQ concurs with completion and issues “Recognition” of validated EMS
Summary • DLA used OFEE guidance to build Self-Declaration Protocol tied to continual improvement • Protocol validates EMS is mission-focused and ISO 14001-conformant • Two-phased EMS self-declaration process: - Web-based documentation review; - On-site independent review
Policy 2. Self-Assessment 3. Implementation Planning A policy statement which includes a missions focus has been prepared. A facility-wide EMS self-assessment (i.e., gap analysis) has been documented. A written implementation plan (with well defined dates, identified resources, and organizational responsibilities) has been prepared. DLA Metrics by 31 July 2004
4. List of Aspects 5. Awareness Training 3. Management Review A prioritized list of environmental aspects has been prepared. Appropriate DLA activity personnel have received awareness training. At least one documented management review has been performed. DLA Metrics by 31 Dec 2004