REPA cheat sheet

ISO 14001:2015 uses the High-Level Structure (HLS) with clauses 4-10: Context, Leadership, Planning, Support, Operation, Performance Evaluation, Improvement.

The PDCA cycle underlies ISO 14001: Plan (clauses 4-6), Do (7-8), Check (9), Act (10).

Key ISO 14001:2015 concepts: context of the organization, interested parties, compliance obligations, environmental aspects, risks and opportunities, lifecycle perspective.

Documented information replaces 'documents' and 'records'; must be maintained (procedures) and retained (evidence).

ISO 14001 requires top management to demonstrate leadership by taking accountability for EMS effectiveness, integrating EMS into business processes, and ensuring resources.

EMS scope must be documented and consider internal/external issues, compliance obligations, organizational units, activities, products, services, and authority/control.

Environmental policy must include commitments to protection of the environment, fulfillment of compliance obligations, and continual improvement.

Objectives must be measurable (if practicable), monitored, communicated, and updated; plans to achieve them include what, resources, who, when, how evaluated.

ISO 14001 does not establish absolute requirements for environmental performance; it requires a systematic approach and continual improvement.

Other standards: ISO 14004 (guidance), ISO 14031 (environmental performance evaluation), ISO 19011 (auditing management systems).

Compliance obligations include legal requirements and other requirements (e.g., permits, industry codes, agreements) that the organization must comply with.

Organizations must determine how compliance obligations apply, consider them in planning and operations, evaluate fulfillment, and maintain knowledge/understanding.

Key US environmental statutes: Clean Air Act (CAA), Clean Water Act (CWA), Resource Conservation and Recovery Act (RCRA), Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), Toxic Substances Control Act (TSCA), Emergency Planning and Community Right-to-Know Act (EPCRA).

CWA regulates discharges to waters of the US via NPDES permits; stormwater permits may be required for industrial activities.

RCRA regulates hazardous waste from cradle to grave; key elements: identification, generation, accumulation, manifest, treatment/storage/disposal permits.

CERCLA (Superfund) imposes liability for release of hazardous substances; reporting requirements include release reporting under CERCLA and EPCRA.

EPCRA requires emergency planning, MSDS/SDS submission, and Toxics Release Inventory (TRI) reporting for certain facilities.

Air permits: New Source Review (NSR), Prevention of Significant Deterioration (PSD), Title V operating permits for major sources.

International: EU Environmental Liability Directive, REACH (chemical registration), RoHS (hazardous substances in electronics), WEEE (e-waste).

Auditors must verify compliance with applicable legal and other requirements, including permit conditions and reporting deadlines.

Audit objectives: determine conformity, evaluate effectiveness, identify improvement opportunities, assess compliance.

Audit scope: boundaries such as organizational units, physical locations, activities, products, services, and time period; must be consistent with EMS scope.

Audit criteria: set of requirements used as reference (e.g., ISO 14001, legal requirements, internal procedures).

Risk-based audit planning: consider environmental aspects, compliance status, changes, previous audit results, and interested party concerns.

Audit plan includes: objectives, scope, criteria, dates, locations, audit team, allocation of resources, and audit methods.

Audit team selection: ensure competence needed, including environmental technical knowledge, legal knowledge, and audit skills; avoid conflicts of interest.

Document review: gather information on EMS documentation, previous audit reports, permits, monitoring data, and nonconformity records.

Sampling plan: determine appropriate sample sizes and methods to provide sufficient evidence; consider risk and volume.

Communication: establish contact with auditee, confirm logistics, and provide audit plan in advance.

Opening meeting: confirm scope, objectives, criteria, schedule, roles, and communication arrangements.

Evidence types: interviews, observation of activities, document review, records, data analysis, sampling, site walkthrough.

Audit sampling: select representative samples; consider risk, past performance, and variability; document sampling rationale.

Interview techniques: ask open-ended questions, verify understanding, cross-check with records and observations.

Observation: verify actual practices against procedures, look for deviations, and note conditions (e.g., spills, labeling, storage).

Document and record review: check version control, approval, availability, and retention.

Nonconformity: non-fulfillment of a requirement; categorize as major (systemic failure, significant risk) or minor (isolated lapse).

Audit evidence must be verifiable, objective, and recorded; findings should be based on evidence, not opinion.

Audit trails: trace from procedure to record to practice and vice versa to verify implementation.

Handling of evidence: ensure confidentiality, data protection, and integrity; do not alter records.

Use of checklists: aids consistency but must not limit the auditor's ability to follow up on unexpected findings.

Audit report content: objectives, scope, criteria, dates, locations, audit team, findings (conformities, nonconformities, observations), conclusions, and recommendations.

Nonconformity report: include requirement reference, evidence, and classification; avoid prescribing the solution.

Report distribution: define recipients, ensure confidentiality, and obtain auditee acknowledgment of factual accuracy.

Follow-up: verify implementation and effectiveness of corrective actions; may be desk review or on-site.

Corrective action process: root cause analysis, action plan, implementation, verification of effectiveness, and closure.

Audit findings should be written clearly, factually, and without blame; focus on system issues.

Audit conclusions: overall conformity, effectiveness of the EMS, and status of compliance obligations.

Records of audit and results must be retained as documented information.

Audit follow-up may be part of next audit or separate; timeliness depends on risk and severity.

Report should highlight good practices and opportunities for improvement.

Environmental aspect: element of an organization's activities, products, or services that interacts or can interact with the environment.

Environmental impact: change to the environment, whether adverse or beneficial, wholly or partially resulting from environmental aspects.

Aspect identification: consider normal, abnormal, and emergency conditions; lifecycle perspective (raw material, design, production, transport, use, end-of-life).

Significance determination: criteria may include severity, likelihood, regulatory requirements, scale, duration, and sensitivity of environment.

Risk and opportunities: determine risks and opportunities related to aspects, compliance obligations, and other issues; consider potential emergencies.

Methodology: use a risk matrix or scoring system; ensure consistency and documented criteria.

Lifecycle perspective: extend consideration beyond site operations to upstream and downstream, but not necessarily full LCA.

Emergency preparedness: identify potential emergency situations and response; test and review.

Aspects must be kept up-to-date when changes occur (new processes, materials, regulations).

Auditors verify that significant aspects are identified and controlled, and that objectives address them.

Pollution prevention hierarchy: source reduction > reuse > recycling > recovery > treatment > disposal.

P2 (pollution prevention) reduces or eliminates waste at the source; includes process changes, material substitution, and good housekeeping.

Environmental performance indicators (EPIs): measure against objectives; may be absolute or relative (e.g., per unit production).

Monitoring and measurement: calibrated equipment, documented procedures, and evaluation of results.

Energy efficiency, water conservation, and waste minimization are key performance areas.

Greenhouse gas (GHG) management: inventory (ISO 14064), reduction targets, and reporting.

Sustainable procurement: consider environmental criteria in purchasing decisions.

Emergency response and spill prevention: secondary containment, spill kits, and training.

Auditors should verify that monitoring data is reliable and that performance is evaluated against objectives.

Continual improvement: use data to identify trends and drive improvement.

Auditor competence: education, training, experience, and personal attributes; must be maintained through continuing professional development.

ISO 19011 provides guidance on auditing management systems, including principles: integrity, fair presentation, due professional care, confidentiality, independence, evidence-based approach, risk-based approach.

Environmental auditor knowledge: environmental science, technology, legal requirements, EMS standards, and audit techniques.

Ethics: avoid conflicts of interest, maintain confidentiality, report truthfully, and do not accept gifts that could influence judgment.

Independence: auditors should not audit their own work; impartiality is essential.

Due professional care: exercise reasonable care and judgment; do not exceed competence.

Confidentiality: protect information obtained during audit; use only for audit purposes.

Fair presentation: report findings accurately, without bias, and include dissenting views if unresolved.

Auditor evaluation: monitor performance, review reports, and provide feedback.

Certification schemes (e.g., for EMS auditors) require demonstrated competence through examination and audit experience.