Checking and Corrective Action

1. Checking and Corrective Action EPA Regions 9 & 10 and The Federal Network for Sustainability 2005

2. EMS Flow Policy Review Planning Checking Operation

3. Checking & Corrective Action Procedures shall be established for monitoring the EMS and correcting deviations. Requirements for procedures cover: • Monitoring and measurement • Nonconformance and corrective and preventive actions • Records • EMS audits

4. Monitoring and Measurement • Regularly monitor and measure operations and activities with potential environmental impacts • Record information tracking performance, relevant operational controls and conformance with the organization’s objectives and targets

5. Monitoring and Measurement (cont.) • Calibrate and maintain monitoring equipment and retain records of these activities • Establish procedures to evaluate compliance with relevant environmental legislation and regulations periodically

6. Nonconformance and Corrective and Preventive Actions Establish and maintain procedures for • handling and investigating nonconformance • taking action to mitigate impacts • initiating and completing corrective and preventive actions

7. Nonconformance and Corrective and Preventive Action (cont.) • Ensure corrective actions are appropriate and commensurate with risk • Record any changes resulting from corrective actions

8. Reasons for a Nonconformance • Implementation differs from documentation • System is not working • Requirement is not addressed

9. Records • Procedures must be maintained for the identification, maintenance and disposition of environmental records. • Environmental records include training records, audit results, reviews, monitoring records, waste disposal records, etc. • Records must be maintained to demonstrate conformance to EMS requirements.

10. Documents Offer guidance or explain actions to be carried out Can be changed Records – a special kind of document Provide verification of things that have happened Cannot be changed Documents vs. Records

11. Documentsare materials that provide management directions: internal standards and operating procedures process information organization charts emergency plans Recordsinclude product information training records incident reports complaints and responses audit results management review meeting minutes Documents vs. Records

12. Records Properly maintained records will • be legible • be identifiable • be traceable to the activity, services or product involved • be stored and maintained to be easily retrievable • be protected from damage, deterioration or loss • have the retention time recorded

13. EMS Audit An organization’s programs and procedures for periodic audits should address • audit scope • frequency and methodologies • responsibilities and requirements for • conducting audits • reporting of results

14. Audits should be scheduled regularly and based on the environmental importance of the activity and results of previous audits.