Understanding Initial Environmental Review Process

Initial Environmental Review

What exactly is an Initial Environmental Review? It provides a snapshot of a company s performance at a particular point in time. It highlights a company s environmental impacts allowing action to be taken where it is most required. The purpose is to find and evaluate as many areas as possible in which the company can improve its environmental performance.

Approach and methods: Process maps outlines the process requirements (i.e. resources) and the outputs including wastes, emissions and by-products that serve as a baseline for identifying environmental aspects. Inputs: raw materials; energy, resources Outputs: emissions; by-products; wastes PROCESS

Process Map:

Process Map:

Assessment of Significant Aspects

6 Criteria for Assessment of Significance Legislative / regulatory obligation Risk to the Environment Occurrence of incidents Actual and potential nuisance/harm International and/or resource usage / resource management issues Lack of information or data to make satisfactory appraisal

Examples of aspects and impacts Activity/Product/Service Aspect Impact Handling of hazardous chemicals Potential chemical spill Soil/land contamination Stamping process employing electricity driven equipment Use of electricity Resource depletion Maintenance of process equipment Disposal of rags tainted with oil/grease Soil and land contamination Effluent from Sn/Pb plating Disposal of effluent water Water Pollution

Steps in evaluating environmental aspects SELECT AN ACTIVITY, PRODUCT OR SERVICE IDENTIFY THE ENVIRONMENTAL ASPECT IDENTIFY THE ENVIRONMENTAL IMPACTS EVALUATE THE SIGNIFICANCE OF THE IMPACTS

Criteria for significance evaluation 3 Evaluation criteria Criteria Severity (S) Occurrence (O) Detection (D) allocated points 10 10 10

Criteria for significance evaluation Significance evaluation rating system: ERPN = S x O x D Total maximum score = 1000 ERPN Environmental Risk Priority Number used to rank order environmental aspects

Definition Severity Is an assessment of the seriousness of the effect (environmental impact) to the cause (environmental aspect) to the environment. Occurrence How frequently the specific environmental aspect is projected to occur (the occurrence number has a meaning rather than a value) Detection Is an assessment of the probability that the existing operational control(s) or monitoring and measurement(s) will detect environmental aspect performance weakness, deterioration or degradation.

Severity (S) criteria S = S1 + S2 + + S6 S1:RESOURCE USAGE (2.0 PTS) 0.2 0.4 VERY MINIMAL USAGE, NEGLIGIBLE IN IMPACT WITH RESOURCE USAGE, 50 % OR MORE IS RECYCLED OR RE- REDUCTION PROGRAMS 0.8 WITH RESOURCE USAGE REDUCTION PROGRAMS IMPLEMENTED 1.2 RESOURCE USAGE WITH SOME CONTROLS BUT IS NOT DIRECTED CONSERVATION 1.6 RESOURCE USAGE WITH NO CONSERVATION 2.0 EXTRAVAGANT USAGE OF RESOURCES, NO CONSERVATION OR USED WITH TOWARDS CARE

Severity (S) criteria S = S1 + S2 + + S6 S2 HEALTH AND SAFETY ( 2.0 PTS) 0.0 NO CONCERN 0.5 RESULT TO IRRITATION / MINOR INJURY 1.0 RESULTS TO INJURY OR ILLNESS 1.5 SHORT TERM ACCUTE HAZARDS SUCH AS ACCUTE TOXICITY BY INGESTION, INHALATION OR SKIN ABSORPTION, CORROSIVITY OR OTHER SKIN OR EYE CONTACT HAZARDS OR EXPLOSION. USUALLY CONFINED IN THE HOSPITAL 2.0 LONG TERM HAZARDS, INCLUDING CHRONIC TOXICITY UPON REPEATED EXPOSURE. IN SOME CASES RESULTING FROM ACCUTE EXPOSURE. FATAL RISK OF FIRE EXPOSURE OR CARCINOGENIC S3 AIR POLLUTION (1.5 PTS) 0 NO EMISSION 0.5 CONTROLLABLE EMISSIONS WITH KNOWN NON-POLLUTING SUBSTANCES 1.0 UNCONTROLLED EMISSIONS WITH KNOWN POTENTIAL POLLUTING SUBSTANCES LIKE DEPLETING SUBSTANCES (ODS), CO2, NOX, SOX, LEAD, ACID FUMES. ETC,. 1.5 EMISSIONS AFFECTING STAKEHOLDERS OR OTHER INTERESTED PARTIES. MAINFESTED EXTERNAL COMPLAINTS OZONE BY INTERNAL OR

Severity (S) criteria S = S1 + S2 + + S6 S4:WATER POLLUTION (1.5 PTS.) 0 0.5 1.0 1.5 NO CONCERN CONTROLLED DISCHARGE WITH KNOWN NON-POLLUTIVESUBSTANCE UNCONTROLLED DISCHARGES WITH KNOWN POLLUTIVE SUBSTANCES DISCHARGES CAUSING COMPLAINTS FROM INTERESTED PARTIES LIKE REGULATORY AGENCIES, ETC., NEIGHBORHOOD, S5:GROUND, SOIL/LAND CONTAMINATION (1.5 PTS.) 0 0.5 1.0 NO DISCHARGES, EFFLUENT OR EMISSION WITH DISCHARGES OR EFFUENT WITH KNOWN NON-POLLUTIVE WITH DISCHARGES OR EFFLUENT WITH KNOWN POLLUTIVE SUBSTANCES SUBSTANCE BUT CONTROL IS IN PLACE. 1.5 NO MONITORING OF SOIL CONTAMINATION, WITH COMPLAINTS OR EVIDENCE OF AS SEEN VISUALLY. NO CONTROLS IN PLACE. DETERIORATION

Severity (S) criteria S = S1 + S2 + + S6 S6:NUISSANCE, DISTURBANCE OR AESTHETIC EFFECT (1.5 PTS) 0 0.5 1.0 NO CONCERN TOLERABLE LEVEL, NO INTERFERENCE, NORMAL WORK FLOW RESULTING TO WORK INTERFERENCE OR OCCASIONAL WORK STOPPAGE AFFECT THE OVERALL EFFICIENCY 1.5 CAUSING WORK STOPPAGES DUE TO NOISE, DISTURBANCE OR AESTHETIC EFFECT WHICH MAY UNTOLERABLE

Occurrence (O) Criteria RANKING PROBABILITY OF THE ASPECT TO OCCUR POINTS VERY HIGH MODERATE INCIDENT OR ACTIVITY HAPPENS DAILY AS PART OF THE PROCESS 10 OR COMPANY ACTIVITIES INCIDENT OR ACTIVITY HAPPENS AT LEAST 3 TIME A WEEK, AS PART OF AN ACTIVITY THAT IS NOT REGULR IN NATURE BUT OCCURS DURING THE WEEK. INCIDENT OR ACTIVITY HAPPENS AT LEAST 1X PER WEEK, AS THE INSPECTION IS REGULARLY DONE ON A WEEKLY BASIS. INCIDENT OR ACTIVITY HAPPENS AT MOST 2 X A MONTH DUE TO AN ACTIVITY THAT IS PLANNED OR SCHEDULED 9 8 7 INCIDENT OR ACTIVITY RE-OCCUR MONTHLY DUE TO ABNORMAL CONDITIONS OR AS A RESULT OF REGULAR CHECKS INCIDENT OR ACTIVITY RE-OCCUR QUARTERLY INCIDENT OR ACTIVITY RE-OCCUR SEMI-ANNUALLY INCIDENT OR ACTIVITY RE-OCCUR ANNUALLY 6 4 5 3 REMOTE OR USE IS DETERMINED PER FREQUENCY OF DISASTER OR ACCIDENT OF ANY KIND. OCCURS ON SOME BUT NOT ALL DISASTERS OR ACCIDENT OF ANY KIND. UNLIKELY TO OCCUR. NO RECORD OF INCIDENT OCCURS WHEN NATURAL DISASTER STRIKES OR ACCIDENT 2 1 0

Detection (D) criteria RANKING PROBABILITY OF THE ASPECT TO OCCUR POINTS ALMOST IMPOSSIBLE USE DUE TO THE UNCONTROLLED OCCURRENCE OF THE ASPECT NO KNOWN CONTROLS TO DETECT THE INCIDENT OR THE ABNORMAL 9 - 10 REMOTE SOME CONTROLS IMPLEMENTED. CONTROLS NOT DEFINED IN PROCEDURES BUT IS MONITIRED OR CHECKED IRREGULARLY 7 - 8 LOW MONITIRED REGULARLY BUT FREQUENCY MAY NOT BE ADEQUATE 5 6 TO DETECT THE INCIDENT OR ACCORRENCE DEFINED IN PROCEDURES. HIGH REGULAR MONITORS DONE. CONTROLS ARE DEFINED IN PROCEDURES 3 4 IMPLEMENTED AND MAINTAINED ALMOST CERTAIN CURRENT CONTROLS ALMOST CERTAIN TO DETECT THE INCIDENT 1 - 2 OR OCCURRENCE OF AN ASPECT. AUTOMATIC CONTROLS OR A DESIGNATED PERSONNEL TO MONITOR OR INSPECT THE CONTROLS IS DESIGNATED

4.3.2 Legal and other requirements Establish, implement and maintain a procedure to: a. identify and have access to the applicable legal requirements and other requirements to which the organization subscribes b. determine how these requirements apply to its environmental aspects

Categories of environmental legal requirements Air Quality Management Control of Toxic Substances and Hazardous Wastes Environmental Impact Assessment General Environment Solid Waste Management Water Quality Management Other requirements may include Customer requirements (e.g. RoHS) Requirements of trade associations Commitment to parent organizations

4.3.3 Objectives, targets and programme(s) Definitions Environmental objectives Overall environmental goal, consistent with the environmental policy that an organization sets itself to achieve. Environmental target Detailed performance requirement, applicable to the organization or parts thereof, that arises from the environmental objectives and that needs to be set and met in order to achieve those objectives.

4.3.3 Objectives, targets and programme(s) Establish, implement and maintain documented environmental objectives and targets at relevant function and level within the organization. In setting objectives, consider: Legal and other requirements Significant environmental aspects Technological options Financial, operational and business requirements Views of interested parties Consistent with the policy including commitment to the prevention of pollution. Commitments to continual improvement

4.3.3 Objectives, targets and programme(s) Establish, implement and maintain a programme(s) for achieving its objectives and targets. Programme(s) should include a. Designation of responsibility for achieving and targets at relevant functions and levels of the organization b. Means and time-frame by which they are to be achieved.

4.3.3 Objectives, targets and programme(s) ENVIRONMENTAL ASPECTS AND IMPACTS Objectives/targets- Quantified what and when Programmes Who, what, when, how, Resources, knowledge ENVIRONMENTAL POLICY LEGAL AND OTHER REQUIREMENTS INTERESTED PARTIES Policy commitment Reduce waste from operations COMMITMENTS OBJECTIVE 1 Reduce the waste generated By the organization in 3 years OBJECTIVE 1 OBJECTIVE 2 OBJECTIVE 3 Target 1 Reduce the total waste Generated by 50% in 3 years TARGET 1 TARGET 2 TARGET 3 Target 2 Reduce the packaging waste By 40 % in 2 years proogrammes Target 3 Reduce liquid waste by 30% In 2 years

4.4 Implementation and operation 4.4.1 Resources, roles, responsibility and authority Define, document and communicate roles, responsibilities and authorities in order for facilitate effective environmental management. Provide resources essential to the implementation and control of EMS. Appoint (a) specific management representative (s) with defined role, responsibility and authority for: a. Ensuring that the EMS is established, implemented and maintained. b. Reporting on performance of EMS to top management for review and as basis for improvement.

4.4 Implementation and operation 4.4.2 Competence, training, awareness Personnel performing tasks which cause significant impacts shall be competent Identify training needs All personnel whose work significant impact receive appropriate training or take other action

4.4 Implementation and operation 4.4.2 Competence, training, awareness Establish, implement and maintain procedure to make persons aware of a. b. Importance of conformity with the EMS Significant environmental aspects and related actual or potential impacts associated w/ their work Environmental benefits of improved personal performance Roles and responsibilities in achieving conformity Potential consequences of departure from specified procedure c. d. e.

4.4 Implementation and operation 4.4.3 Communication Establish, implement and maintain a procedure(s) for a. internal communication among the various levels and functions of the organization, b. receiving, documenting and responding to relevant communication from external interested parties.

4.4 Implementation and operation 4.4.4 Documentation a. b. Scope of the EMS c. Description of the main elements of the EMS and their interaction and reference to related documents d. Docs, including records, required by this standard e. Docs, including records, determined by the organization to be necessary to ensure the effective planning, operation and control of processes related to significant environmental impacts. Environmental policy, objectives and targets

4.4 Implementation and operation 4.4.5 Document Control a. b. Review and update as necessary and re-approve documents c. Ensure that changes and the current revision status of documents are identified d. Ensure that relevant versions of applicable documents are available at point of use e. Ensure that documents remain legible and readily identifiable f. External documents are identified and their distribution controlled (e.g. MSDS) g. Prevent unintended use of obsolete documents and apply identification if retained Approve documents for adequacy prior to issue

4.4 Implementation and operation 4.4.6 Operational Control a. Establish, implement and maintain documented procedure(s) to control situations b. Stipulating the operating criteria in the procedure c. Establish, implement and maintain procedures related to significant environmental aspects and communicate requirements to suppliers

4.4 Implementation and operation 4.4.7 Emergency Preparedness and Response a. establish, implement and maintain procedures to identify potential emergency situations and potential accidents b. respond to these situations and prevent or mitigate associated adverse environmental impacts c. shall periodically review, where necessary, revise procedure after the occurrence of accidents or emergency situations d. Shall periodically test such procedures where practicable

4.5 Checking 4.5.1 Monitoring and Measurement monitor and measure the key characteristics of its operations that can have significant environmental impact include the documenting of information to monitor performance, applicable controls and conformity with the organization s objectives and targets ensure calibrated or verified monitoring and measurement equipment is used and maintained

4.5 Checking 4.5.2 Evaluation of Compliance Establish, implement, and maintain a procedure for periodically evaluating compliance with applicable legal requirements. Shall evaluate compliance with other requirements to which it subscribes

4.5 Checking 4.5.3 Nonconformity, corrective action and preventive action Establish, implement, and maintain a procedure for dealing with actual and potential nonconformity and for taking corrective and preventive action. Procedural requirements: a. Identifying and correcting nonconformities and taking actions to mitigate their environmental impacts. b. Cause analysis and taking action in order to avoid their recurrence c. Evaluating the need for action to prevent nonconformities and implementing appropriate action to avoid their occurrence d. Recording results of CAPA e. Reviewing effectiveness of actions taken.

4.5 Checking 4.5.4 Control of Records Establish, implement and maintain a procedure for a. Identification b. Storage c. Protection d. Retrieval e. Retention f. Disposal of records Records shall remain legible, identifiable and traceable.

4.5 Checking 4.5.5 Internal Audit Establish programme(s) for periodic EMS audits to be carried out to: a. Determine if the EMS conforms to planned arrangement and has been properly implemented and maintained. b. Provide information on the results of audits to management. Frequency based on importance of activity concerned and results of previous audits Procedures covers scope, frequency, methodology , as well as responsibilities and requirements for conducting and reporting results. Audit system shall ensure objectivity and the impartiality of the audit process

4.5 Checking 4.5.6 Management Review Review the EMS to ensure continued suitability, adequacy and effectiveness. Assessing opportunities for improvement Inputs to management review: a. Internal audit results b. Evaluation of compliance to legal and other requirements c. Communication from external interested parties, including complaints d. Environmental performance e. Extent to which objectives and targets have been met f. Status of CAPA g. Follow-up action from previous management review h. Changing circumstances i. Recommendations for improvement

4.5 Checking 4.5.6 Management Review Outputs to management review: Decisions and actions related to possible changes to: Policy Objectives Targets Other elements of the EMS (continual improvement)