Internal EMS Auditing at Naval Installations

1. Internal EMS Auditingat Naval Installations

2. Navy EMS Overview • All “appropriate facilities” must implement an EMS that conforms with ISO 14001 by 30 SEP 09 • Conformance is verified by 2nd party audit (initial and then every three years) • Internal EMS Audit required annually • Appropriate facilities may be a single installation or a group of installations • There are 94 navy “appropriate facilities” • 74 in United States • 20 Overseas • Examples of facility types: • Naval Air Station • Naval Amphibious Base • Naval Support Activity • Naval Submarine Base • Naval Shipyard • Naval Weapons Stations

3. Typical Navy Practices • Navy Installations are very similar to a small town • Range from 80 to 80,000 personnel • Typical Practices • Waste Disposal • Waste water treatment • Fuel Combustion (boilers, generators) • Oil Transfers • Recycling • Construction activities • Painting • Blasting • Vehicle Maintenance • Ordnance Training

4. EMS Audit Criteria • Requirements • Evaluate conformance with ISO 14001 • Evaluate conformance with OPNAV 5090.1C – Chapter 3 • Intent • Evaluate implementation of defined system • Effectiveness • Evaluate effectiveness of EMS to fulfill environmental policy

5. Picking the Right Team • Auditors need appropriate training • Navy policy requires lead auditor to have completed ANSI-RAB Lead Auditor course or Navy Conducting EMS Review Course • Auditor attributes: • Impartial to area auditing • Ethical • Open-minded • Diplomatic / Tactful • Observant • Decisive • Self-Reliant • Background in Compliance Note: Try to pick auditors with background in regulations that apply to the significant aspect they’re auditing!

6. Document Review is Critical • Before the audit begins, review: • Environmental policy • EMS procedures • Results of previous audits • Results of internal and external compliance evaluations • Status of Objectives and Targets • Operational Control procedures • Checklists? • EMS Auditing is more than following a checklist, it’s about evaluating the effectiveness of a system • Checklists may be helpful, though, to ensure that all areas are covered (i.e. evaluating conformance with complex operational control procedures)

7. Conducting the Audit • Interview personnel with roles and responsibilities in procedures: • Are they familiar with their role • Does what they do match what the procedure says they do • Do they have documentation to demonstrate conformance (if needed) • Interviewing shop personnel / evaluating operational control: Standard questions: • Tell me about what you do here? • What are the biggest environmental issues here (i.e. SEAs)? • Are there any regulations that you have to follow? • Do you have a procedure that tells you how to do that? • Have you had training? Documentation of training? • What can you tell me about the installation’s environmental policy? • Do you know of any environmental goals associated with ____? • What would you do if something went wrong (i.e. spill)?

8. Reporting Audit Results & Corrective Action • Conduct daily out brief with environmental staff at minimum • Conduct formal out brief with Installation Commanding Officer, Public Works Officer, and Environmental Manager, describing: • Scope of audit • Evaluation criteria • Noteworthy practices (what are they doing well?) • Audit findings • Findings associated with regulatory compliance should be tied back to a weakness in one or more ISO 14001 element • EMS non-conformances must be corrected: • in accordance with the installations corrective action procedure • for corrective actions requiring long-term action, a plan of action & milestone must be developed and progress tracked periodically

9. Getting Top Management Involved • Distill the EMS concept down to terms they can relate to: • “Say what you do and do what you say” • The Plan-Do-Check-Act Model • Continual Improvement • How is EMS going to help their organization? • Cost savings – give examples • Improved relations with regulators – give examples • Documentation of processes – reduced impact of personnel turnover • Acknowledge personnel for achievements • Report EMS successes within and outside of the organization