Sunday 5 February 2012

ISO14001 TIPS - Environmental Aspects' Data


EMS ISO14001 – TIPS.

Effectiveness of Quantifying Environmental Aspects in a Normalized Form for ISO14001 EMS

Background
The EMS is about managing environmental aspects in a systematic and justifiable manner that can control, reduce or eliminate its potential to cause associated, identified and/or probable environmental impact. Nonetheless, ‘from how much’, ‘to how much’ and ‘to what extent’, ‘who, how and whom’ and ‘until what and when’ are questions that should be addressed in MANAGING these significant environmental aspects in an EMS. Quantification of all the identified environmental aspects during the Initial Environmental Review are geared to addresses this.


Common Issue
However, data like 0.85g/Nm3 of Dust Particles into the atmosphere or 45mg/L BOD concentration into the stream, etc. doesn’t provide clear picture on ‘environment versus business’ i.e. what expense to the environment is involved in producing these product. This is one of the global issue that prompted conventions on Sustainable Development and Agenda 21. In this case, the impact to the atmosphere is a downstream affair. (I would love to discuss data pertaining to how much of the various environmental resources are being used to produce per unit Ton of this product too. In some industries, such as, our local Palm Oil Industry mainly uses renewable raw material resources.) The above example data is only applicable in verifying legal conformity. EMS is not just about complying with legal requirements. But, a normalized data is such as: 2.5kg of Dust Particles/MT C.P.O.(product) or 5.5kg BOD Load per MT of Product, for instance, is a comprehensive basis of an EMS.  It associates the measurable quantified impact to the environment involved to produce each unit of product. Hence, regardless of what the real-time production throughput or rates are, this figure remains fairly standard. And, how much of the dust enters the environment is proportional to the quantity of products produced during that time. In environmental sciences, it’s the load that matters and not just concentration. Pollution prevails due to pollution loads and not its concentration. (I’ve usually explained this in most of our training.) Thus, normalized data enables easier and more justifiable subsequent decision on available environmental management alternatives.
Example
Industrial Nature:                    Palm Oil Mill
Activity/Equipment:                Boiler
One Sample Aspect:              Dust Particles
Aspect                        Monitoring Data          Normalized Data
Dust Particles               0.85g/Nm3                   2.5kg/MT C.P.O.(product)
It is based on the Normalized Data, which is supposedly derived from a detailed Initial Environmental Review Process; subsequent Environmental Objectives, Targets and Program can be constructed more accurately and proportionally.

Rationale of Using Normalized Data for Aspects’ Quantification
Firstly, The 0.85g/Nm3 is derived from the routine environmental monitoring work called The Isokinetic Stack Sampling. This is also done on other stacks from this factory, such as, its incinerator. For other industrial activities, the same is performed for stacks originating from any fuel burning equipment, such as, the thermo-oil-heaters, furnaces, burners, oxidizers, and, from non-fuel-burning equipments such as dust collector systems (filterbag-houses, cyclones, ESP etc.). Thus, it is evident to us that these dust-particles can be generated and released from multiple origins. In this case, for a Palm Oil Mill, there are two main sources of dust particles i.e. from the boilers’ stacks and from the incinerators’ stacks. Upon a systematic and defined Aspects’ Impact Evaluation it was found that the dust from the Boilers’ Stacks are more significant and has been a legal issue with the DOE (Malaysian Department of Environment) for years. A number of recorded complaints were filed. However, this one didn’t quite make it to our Karam Singh Walia’s poem (Karam Singh is a journalist with the local TV3). So, how does one differentiate dust from these boilers’ stacks from those of the incinerators? Without a defined differentiation the resultant EMS procedures shall eventually cover those insignificant environmental aspects sources as well, thus, rendering most difficult management task in terms of monitoring costs, time and effort in data compilation, reporting and interpretation. Therefore, in the example of EMP below, you’ll observe the use of inventory numbers for each activity and its subsequent aspect, objective, targets and SOPs, all coming from a normalized data.
Secondly, the 2.5kg/MT C.P.O.(product) is a normalized data. This is not mandatory in an EMS and the ISO14001 didn’t request it specifically. However, this type of data is a crucial ‘reading’ that literally serves as a navigational bearing to an objective EMS that eventually be an economic benefit for the organization. This is also the fundamental of Environmental Performance Evaluation! As stipulated under ISO14031. In this example, it is translated as “2.5kg of Dust Particles are being generated from this factory every time it produces 1 Metric Ton of Crude Palm Oil.” Actually, this ideology is the basis of the LCA (Life Cycle Assessment) and the definition of ISO14001’s ‘Environmental Aspect’. In any EMS, this sort of Normalized Data is the very basis and fundamental EMS Map’ or compass. Imagine driving around without knowing where we are and where we are going! The EMS Certification is just like our Driving License or the vehicle fitness certificate, somewhat. But, where are we going? A joy-ride is non-objective and usually non-productive. So is a mere certification that is merely based upon a market drive. What’s the environmental due-diligence like? This is amongst the reason why we could still find an ISO14001 certified company that uses Paper Cups! This is where the applied environmental science should be instilled. Paper cups, especially from Vending-Machines which are not environmental friendly at all. Most of its constituents are petrochemicals’ derivatives and could upset the soil ecosystem upon dumping and may cause the release of mutagenic Furans and Dioxins when incinerated. Paper recycling involves the release of Dioxins! It enters some streams where ‘Ikan Patin’ is a delicacy!  Ironic however, they talk about Ozone Depletion, rise in sea-water, global warming, etc. more than what they could do to prevent or reduce it. So, bring mugs and glass from home! Install coffee, tea, milo, etc. mixers in the pantry, offices, canteen, etc. Further on, its busy-time for ‘patching-work’ when reassessment or recertification audit approaches. Revamp, rework, updating documents, including the ‘Sila Tutup Suis Setelah Menggunakan Bilik ini” (Please switch off all lights after using this room) signage be in place – is becoming a ‘decadent ritual’ in many organization. It’s a sort of cult when anticipating ISO14001 certification. The above is a typical example of resource conservation philosophy applied from a procrastinated mind-state. Changing to Low-voltage-high-lumens bulb is a smarter choice, plus the signage, would make an environmental sense, at the least. This is one point where the Malaysian Hibiscus Award is a justly and joyful pride to talk or brag about. Let’s now observe the follow-on example for this sample as displayed below.
Example - Objective
To reduce air pollution load from all production-related activity.
Naturally there are other environmental objectives for this organization. The above is just one of them.
Example - Target
Target Number: A2.1.1
To reduce and control emission of Dust Particles from Boiler operations from 0.85g/Nm3 @ 2.5kg/MT C.P.O.(product) to 0.80g/Nm3 @ 2.0kg/MT C.P.O.(product) by 31st December 1997.
There are a few more environmental targets that emerged from the above objective and this is just one of their targets.

Example - THE EMP
DEPT
AREA OR PROCESS
TARGET
PROGRAM MEASURES
A.2.1.1-
TARGET DATES
PIC OR WORK-GROUPS
COST
REMARKS
A2 - UTILITY
A.2.1 – Boiler
A2.1.1
Dust Particle Emission be reduced to 0.80g/Nm3 @ 2.0kg/MT C.P.O.(product) by 31st December 1997.
1. establish Working Group A211
28-02-97
Op. GM
5 man-days
Meeting
2. inspect boiler & stack on operating conditions and criteria.
15-03-97
WG A211, consulting engineer
5 man-days @ RM5000
Tech drawing
3. boiler and stack repair or maintenance
18-04-97
Contractor
RM10,000 @ 7 days downtime
To quote
4. verification inspection on dust collector system
01-06-97
WG A211 & consultant
5 man-days @RM5,000
Tech drawing & checklist
5. dust collector and filterbag repair
30-06-97
Contractor
RM7000 3 days downtime
To quote
6. commissioning verification
10-09-97
WGA211 & consultant
4 man-days @ RM3000
Checklist
7. emission test
15-09-97
Consultant
RM2500
Isokinetic stak sampling
8. report
15-11-97
WGA211
2 man-days
Format
9. review & up-date SOPs
20-11-97
WGA211
1 man-day
Revision
10. train boiler operator – new SOP
29-11-97
WGA211
1 man-day
Materials
Key
C.P.O = Crude Palm Oil
Nm3     = Normal (at localized STP) Cubic Metres
WG      = Working-group

Other Examples of Normalized Data Based on Industrial Types
OIL & GAS – OIL RIGS
10m3 of Drilling Mud per Barrel of Crude Oil
OIL & GAS – REFINERY
500L of Oil-Sludge per BST per Batch
PETROCHEMICAL
200m3 of Flared PE per 1000MT of Naptha
OLEOCHEMICAL
60kg of Spent Nickel Catalyst per MT of Palm Stearin
PLASTIC
2.0L of Spent Hydraulic Oil per 1000MT Plastic Products
FOOD & BEVERAGE
0.1kg BOD Load per Bottle of Product
PAINT MANUFACTURING
7L of Spent Xylene or 200L Paint Product
PRINTING
3pcs of Used Printing Roller per 5000MT Carton Boxes
AUTOMOBILE
1.5kg Paint Dust from Spray Paint Dept per Unit of Sedan Car Model 3.0L V6
ELECTRONICS
0.5kg of Solder Dross per MT of Assembled PCB
TEXTILE
2L of Spent Hydrogen Peroxide (L) per MT of Dyed Fabric
CONSTRUCTION
100kg of Waste Wooden Foam-work per Strata of 5000m2 Multi-storey Building
PULP & PAPER
3L Dioxin containing wastewater per MT of recycled paper
HAZARDOUS WASTE RECYCLER
2kg or residue per 1MT of recycled used lubricating oil
SECURE LANDFILL
7L Leachate per cell per year
POWER GENERATION
5.0kg of Fly-ash emission into an ESP per 1Million Mega Watts generated
CONCLUSION
A more accurate or representative Environmental Aspects’ Data is needed in establishing an EMS. The above EMP sample clearly shows that the vividness of a normalized Environmental Aspect’s data is serving as a true basis of the EMS. It’s like a compass in a yacht or a tachometer in a Lamborgini Murcielago. Furthermore, this EMP is a detailed version to help schedule what, who, when, how much, etc. is needed to get them done. This is only for one target. There could be a multiple of such EMPs if the management decided to manage all the identified significant aspects at once in the year’s certification cycle. Remember, the ISO14001:2004 didn’t set a mandatory requirement to manage all significant issues in one go. It’s the luxury of the organization to choose which significant aspect that they could manage in one certification cycle. But, all such decision needs to be recorded as a legible document serving as an evidence of such decision.
So, if there’s a need for an Operational Control Procedure (SOP) for any of the above program measure, then, the corresponding SOP and/or WIS (Work Instruction Sheet) shall be established, documented and train the related personnel on it.

That’s all folks for the meantime. Please do not hesitate to inquire whenever you need to.
Regards
Khalid Mohd Ariff
Sekitar Synergy Sdn Bhd

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