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
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
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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