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GAP ANALYSIS 1S0 14001 2011-2012
Prepared by Baiq Dian Zoelaeha
GAP ANALYSIS CHECKLIST
ISO 14001 SYSTEM REQUIREMENT CURRENT PRACTICE AND FINDING EMS
SATISFIED
(Yes/NO/Partl
y)
Recommendation
I.ENVIRONMENTAL MANAGEMENT SYSTEM (EMS)
General
4.1 1 Is there a documented EMS which conforms to the
requirements of the ISO 14001 Standard
There is no formal documented environmental
management system exist within the company. Most of
formal EMS component are absent. Sound environmentally
practices mostly are coordinated by Environment
Department on the site; however, these practices are not
yet covered by well established system.
No The company should develop a
documented EMS in accordance with
ISO 14001 Standards requirements and
document existing environmental
practices
4.1 2 Is the EMS kept up to date Not applicable No The EMS should be kept up to date
4.1 2.1 Are all clauses of the standards addressed? Not applicable No The EMS should address all clauses and
sub clauses of ISO 14001 Standard
4.1 3 Is the EMS sufficiently implemented Not Applicable
No The EMS should address all clauses and
sub clauses of ISO 14001 standard
4.1 4 Are other environmental commitments addressed within
EMS
Not Applicable No The EMS should address the company
environmental commitments
4.1 5 Does the scope of the EMS cover all the company
activities, products and services?
Not Applicable No The EMS should cover all activities,
product and services of the company
II. ENVIRONMENTAL POLICY
4.2 1 Has the company top management defined, endorsed
and signed the policy
Top management of PT WBN has establish and signed the
environmental policy which become driven force of all
activities in all phase, pre construction, construction and
operation. However, the policy has not yet reflected into
objectives, targets and program in term of systematic
environmentally program activities.
Yes Policy is needed to be socialized to all
employees, contractor and sub
contractor.
2 Is the companys policy consistent with the corporate
policy
The policy was designed to follow the ERAMET
environmental charter and satisfy the current condition of
the areas where PT WBN exists. Moreover, the
environmental policy is consistent to the corporate policy
to establish best practices in term of environmental
management system.
Yes The head company (Eramet) has
determined the environment principles
and the policy is in line with the Eramet
environmental principles.
GAP ANALYSIS 1S0 14001 2011-2012
Prepared by Baiq Dian Zoelaeha
4.2.a 3 Does the policy sufficiently describe the company
activities, product and service
The policy covers commitment of the company to comply
all relevant regulations, to identify, assess, manage and
monitor all environmental risks, assess the potential
impacts of future activities, to monitor and control the
environmental impact, to conduct targeted and ongoing
research and monitoring of new technologies, to
continually improve environmental performance.
Yes Company commitment, activity
program, implementation plan,
monitoring plan and continuous
improvement process should be
imposed in the policy
4.2.a 4 Is the policy appropriate to the nature , scale and
environmental impact of its activities, products and /or
services
The policy was designed to be driven force for all activities
related to project. The project is to build the nickel and
cobalt processing
Yes
4.2.b 5 Does the policy include a commitment to continual
improvement of environmental performance
Yes
4.2.b 6 Does the policy include a commitment to pollution
prevention
Yes
4.2.d 7 Does the policy include a commitment to system
improvement
Yes
4.2.c 8 Does the policy provide a framework for setting and
reviewing environmental objectives and targets
Not yet
4.2.c Does the policy include a commitment to comply with
legal and regulatory requirement
Yes
4.2.f 9 Does the policy include a commitment to comply with
other requirement
Yes
4.2.f 10 Is the policy available to the public Not yet No The policy has not yet been published
to pubic through the website or to
employee.
GAP ANALYSIS 1S0 14001 2011-2012
Prepared by Baiq Dian Zoelaeha
11 Has the policy been updated as a result of audits/review Not Yet, so far there is no internal or external
environmental audit yet, therefore the policy is not from
the audits, however the environmental policy is updating
version which go along the ERAMET environmental policy.
No Internal audits should be incorporate in
the implementation of EMS, and if any
issues of improvement should
incorporate in the policy .
12 Has the policy been communicated to all (including
contractor and employees)
Not yet The
4.3 II. PLANNING ACTIVITIES
1.Environmental Aspects
4.3.1 1 Is there a method to identify and evaluate significant
environmental aspect that they can directly control?
So far, there is no specific methods to identify
environmental aspect impact, however, in the
environmental impact assessment report (AMDAL) and
ESHIA document, the general environmental aspect impact
have been identified.
Partly/No The company should establish a
procedure for identifying
environmental aspects and impact
relevant to all activities and operations
(including environmental aspect impact
from activities and operations of the
suppliers and contractors) under the
normal, abnormal and accidental and
emergency condition and establish a
system to evaluate the significance of
each environmental aspect. The
company should also establish a
register of the environmental aspect
impact and keep the register up to date.
4.3.1 2 Is there a method to identify and evaluate significant
environmental aspects that they can influence
General assessment in the AMDAL report and ESHIA
report, however the assessment was part of AMDAL
requirement.
No
4.3.1 3 Is there a sound method to allocate significance There is no specific method to allocate significance,
however in the ESHIA report, it describe the likelihood and
the magnitude of the impact, in way the combination of
highly likelihood and magnitude result in high significance.
No There should be a method to allocate
significance of environmental aspect.
Environmental aspect evaluated as
significant have to be either controlled
by appropriate operational controls or
improved by objectives and target
setting.
4.3.1 4 Is there a method to link objectives to these significant
aspects
Not applicable, since there are no specific of objectives
and target within environmental management system
No The top management has to consider
significant environmental aspects in
setting objectives and targets. Each
objective and target should cross-
reference to relevant significant
GAP ANALYSIS 1S0 14001 2011-2012
Prepared by Baiq Dian Zoelaeha
4.3.1 5 If yes, is it implemented and updated? Not yet No
4.3.1.A 6 Has an Initial environmental Review been carried out The IER is in progress Partly, the IER
is being
conducted
The company should complete the IER
4.3.1.A 7 Did the review cover the four key areas
legislation and regulatory requirements
an identification of significant environmental
aspects
an examination of all existing environmental
management practices and procedures.
An evaluation of feedback from the investigation of
previous incidents.
The IER was only conducted within environmental
department. The Review covers:
1. List of legislation and regulatory requirement
2. Document system and SOPs
3. Identification of activities and aspect
No
4.3.1.A 8 Has the method for identifying of environmental aspects
considered the following where relevant:
emission to air
releases to water
waste management
contamination of land
impact on communities
use of raw material and natural resources
use of chemical and storage
use of fuels
impact on biodiversity
impact on marine environment
impact on fresh water system
local environmental issues
Identification of environmental impact is mainly described
and listed in the AMDAL documents.
emission to air
releases to water
waste management
contamination of land
impact on communities
use of raw material and natural resources
use of chemical and storage
use of fuels
impact on biodiversity
impact on marine environment
impact on fresh water system
local environmental issues
Partly and has
not yet follow
the ISO
standard in
term of
registered,
analysis
likelihood and
risk rating.
Workshop for identification aspect and
impact. Prior to that, it is recommended
to have basic ISO 14001 training so that
the project team will understand and
aware of the ISO 14001 requirement.
4.3.1.A 9 Consideration on situation such as:
abnormal
normal
accidents
emergency condition
Yes, in the environmental impact assessment methods.
There are several SOP created in managing the emergency
response to natural disaster and accident.
Not yet
existed fully
When making identification of aspect
and impact, it should look the
significance in the different situation.
1 II. PLANNING ACTIVITIES
2. Legal and other requirements
4.3.2 2 Is there a method to identify and have access to:
legal and regulatory requirement
(permits/consents)
other requirements
Yes, legal and regulation are listed according to the
intended compliance.
Yes, partly
GAP ANALYSIS 1S0 14001 2011-2012
Prepared by Baiq Dian Zoelaeha
4.3.2 3 Is the method also used for products and services Not applicable No The project has not yet had product
(ferronickel), but the ore mining started
in January for Karkar, and Nurspera
4 How are these requirement kept up to date Not applicable No
5 Have they related the requirements to their activities,
products and services
Not applicable No
II.PLANNING ACTIVITIES
3. Objectives and targets, and programs
4.3.3 1 Is there a method to establish Objectives and targets Not yet No The company in general or the
environment project team need to
establish the objective and target of the
environmental management system
4.3.3 2 Are these objectives and targets set on a company wide
basis
Not applicable No Objectives are overall environmental
goals, arising from the environmental
policy, that an organization sets itself to
achieve, and which is quantified where
practicable, while targets should detail
performance requirement, quantified
where practicable, applicable to an
organization or parts, that arises from
the environmental objectives and that
needs to be set and met in order to
achieve those objectives
4.3.3 3 Are these objectives and targets set at each relevant
function and level within the company
Not applicable No
4.3.3 4 Do the objectives and targets consider:
Significant aspects
The legal requirements
Other EMS requirements
Views of interested parties
Financial, operational and business goals
Not applicable No When setting up the objectives and
targets, they should consider the
significant aspect, legal requirement,
EMS requirements, view of interested
parties, and financial operation
business goals.
4.3.3 5 Are the objectives and targets consistent with the
environmental policy, including a commitment to
prevention of pollution
Not applicable Objectives and target should consistent
with the policy and reflect the spirit of
the environment policy.
4.3.3 A 6 Are objectives specific Not applicable
Objectives and targets should be
SMART, specific, measurable,
achievable, realistic, timely.
GAP ANALYSIS 1S0 14001 2011-2012
Prepared by Baiq Dian Zoelaeha
Are the targets measurable where practicable No
7 Do objectives and targets take preventive measures into
account where appropriate
There is no a systematic system in establishing objectives
and targets and a monitoring system to check progress
towards achieving these objectives and target
NO Objectives and targets should take
preventive measures into account
where appropriate
4.3.4 1 II. PLANNING ACTIVITIES
4. Environmental management programme
4.3.4.b 2 Is there program to achieve objectives and targets There are no specific programs to achieve objectives and
targets, in particular for waste, energy and water
conservation. However, the practices in the site reflect
some program intended to recycling waste and to conserve
water.
Partly There should be a formal and detailed
environmental management program
or action plan with the time frame to
achieve each objective and target. This
program should be regularly reviewed
and revised where necessary
4.3.4.A 3 Does the program define the means (detailed program
steps) and time frame by which objectives and targets
are to be achieved
Not clearly defined Partly Same as above
4.3.4.A 4 Has responsibility for achieving Objectives and Targets
been designated at each relevant function & level in the
company
Not clearly defined NO The environmental management
program should assign responsibilities
fro achieving the objectives and targets.
4.3.4.A 5 Has Environmental Management been applied to
programme(s) relating to projects covering:
a) new developments?
b) new or modified activities?
c) new or modified products?
d) new or modified services?
Not clearly defined No Environmental management should be
applied to program relating to projects
covering:
New development
New or modified activities
New or modified product
New of modified services
4.3.4.A 6 Does the programme for current and new activities,
products and services consider the following stages?
Planning
Design
Production
Marketing
disposal
The company should consider these
stage in establishing the environmental
management program
4.3.4.A 7 Does the programme for products consider the following
stages?
Design
Materials
No Not It is recommending to consider these
stage
GAP ANALYSIS 1S0 14001 2011-2012
Prepared by Baiq Dian Zoelaeha
Production
Processes
use and disposed
4.3.4.A 8 Does the programme for installation or significant
process modifications address the following stages?
Planning
Design
Construction
Commissioning
Operation
decommissioning
no no
III. IMPLEMENTATION AND
OPERATIONAL ISSUES
1. Structure and responsibilities
4.4.1 1 Have roles, responsibilities and authorities for
effective environmental management been:
Defined?
Documented?
Communicated?
The new organization structure show the line of roles,
responsibilities, and authorities for environmental
management. In each sub department and division,
document control and communication system has been
defined at all level. Communication system uses the
intranet, share point and weekly meeting.
Yes To implement environmental
management system, it is necessary to
have specific project team to design the
EMS, to plan and monitor the
implementation of EMS
4.4.1 2 Has the management provided the following resources
for EMS implementation and control?
human resources
specialized skills
technology
financial resources
The team will assembled from existing human resources
available within the environmental department and
possible representative from each department. The team
member should have
Partly The company should establish a
procedure to ensure all these resources
are sufficient, and utilized and managed
in systematic and effective way.
4.4.1.a.b 3
Has the company appointed specific management
representative(s) to:
ensure EMS is established, implemented and
maintained?
report performance of EMS to top management for
review and EMS improvement?
Management representative will be appointed once the
EMS project is agreed and the initial environmental review
and gap analysis is done
Not yet Management representative is of
responsible a clearly strategy of change,
coordinate schedule meeting and the
implementation of the project team
and bridge between project team and
steering committee.
4.4.1.A 5 Have environmental responsibilities been defined in
departments other than just the environmental
department?
The environmental responsibilities mainly still lies within
environmental department. The environmental
department conducts environmental inspection and
monitoring across departments. However, other
departments are urged to adopt environmentally sound
practices within their activities.
Partly Increasing the awareness of
environmental management to all
employees should be apriority of the
EMS project. This can be done through
campaign, communication and training.
GAP ANALYSIS 1S0 14001 2011-2012
Prepared by Baiq Dian Zoelaeha
4.4.1.A 6 Does top management ensure that appropriate resources
are provided to ensure the EMS is implemented and
maintained?
Not applicable, because the company has not had EMS yet NO The EMS should be documented,
periodically reviewed and revised
where necessary, and authorized by the
General Manager to ensure that
appropriate resources are provided for
implementing and maintaining the EMS
III. IMPLEMENTATION AND OPERATION
ISSUES
2. Training, Awareness and Competence
4.4.2 1 Has the company identified training needs Training need information usually come from the sub
department manager and proposed to HR department. If
appropriate and match with the development process f
the employee, employee can take the training
Yes/partly Methodology used is bottom up,
employee give detailed training they
need and HR process and funded.
4.4.2 2 Has the company appropriately trained those personnel
whose work may have a significant impact on the
environment?
The staff in the environmental department, in particular
those at supervisor level has gained several training
including first level mining supervision training, waste
management training, and other, however the training
documentation is not really defined.
Yes/partly As part of EMS implementation, training
on awareness, documentation and
monitoring aspect of EMS is crucial. The
trainings are intended to employees
whose role and responsible related to
EMS requirements.
4.4.2 3 Are there procedures to ensure employees at each level
& function are aware of:
importance of conformance with the
environmental policy and procedure?
importance of conformance with the requirements
of the EMS?
the significant environmental impacts, actual or
potential, of their work?
the environmental benefits of improved personal
performance?
their roles and responsibilities in achieving
conformance with the environmental policy and
procedures?
their roles and responsibilities in achieving
conformance with the requirements of the EMS
including emergency preparedness and response
requirements?
the potential consequences of departure from
specified operating procedures?
Standard operation procedures have become the guideline
when conducting activities. Currently, within
environmental department, there are more than 30 SOP
which divided into three categories, baseline monitoring,
rehabilitation and biodiversity and environmental
monitoring and inspection. SOPs was design and prepared
by environmental department based on template and
reference agreed by the manager
Yes/partly SOPs should be prepared base on the
activities concerned in the ISO 14001.
At least there are 14 must have SOPs in
the ISO 14001 and from the initial
review, the company can get the
comparison.
4.4.2 4 Are those who perform tasks that can cause significant
impacts competent to do so, based on appropriate
education, training and/or experience?
The information on other department condition is not
available right now since the IER is only focus to the
environment department
No
Information
The implementation of EMS should
cover process, product and services of
the company, and other department
also shall take part in this process.
4.4.2 5 Has the company determined whether contractors The company currently working with several contractors to Partly The company can start to be selective
GAP ANALYSIS 1S0 14001 2011-2012
Prepared by Baiq Dian Zoelaeha
working on their behalf can show that their employees
have the requisite training?
do activities in different department, for example mining,
drilling, sample analysis, construction. Most of the
contractor is local and national contractor; however, so far
there is no information whether they are ISO 14001 or ISO
9001 certified contractor.
to contractor that ISO certified
contractor and be used as one of the
requirement.
III. IMPLEMENTATION AND
OPERATIONAL ISSUES
3. Communications
4.4.3.a 1 Does the company have a method for internal
communications about its significant aspects and EMS,
between the various levels and functions?
Within environmental department, there is internet share
point where the main management level can share
information, weekly meeting for core team in Jakarta and
site, bi-weekly reporting. While for external, the GM
environment department has regular meeting with other
top management. For all part of company, communication
department can be asked to published information on the
weekly newsletter and also magazine.
Yes/partly Communication method should be
documented as for internal
communications as well as record all
correspondences
4.4.3.a 2 Does the company have a method for receiving,
documenting and responding to relevant communication
from external interested parties about its significant
aspects and EMS
Yes, all document or communication from external usually
received by intended recipient then if necessary the
document or information will be uploaded by document
controller
Yes/partly As part of document control, all
communication or document need to
be recorded.
4.4.3.a 3 Has the company decided whether to communicate its
significant aspects externally?
Release of information should go through standard
operation procedure of communication to external parties.
GM responsible for disseminate information if necessary to
team, and all information release from communication
department
Yes/partly To communicate the significant
environmental aspect, the company
should establish a procedure to explain
the method.
4.4.3.a 4 Has there been any dialogue with external interested
parties, other than the regulators?
In regard of environmental performance, the environment
department maintain dialogue with other department,
while externally, environment department maintain
dialogue with government and stakeholders.
Yes/partly
4.4.3.a 5 Has there been any dialogue with public authorities
regarding emergency planning and other relevant issues?
The company keeps correspondences to public authorities
such as village head, bupati.
Yes/partly
III. IMPLEMENTATION AND
OPERATIONAL ISSUES
4/5. EMS Documentation and Document Control
4.4.4.a 1 Is there information in paper or electronic form to
describe the core elements of the management system
and their interactions?
So far EMS is not documented yet, either in paper or
electronic form
No EMS shall be documented both in paper
and electronic.
GAP ANALYSIS 1S0 14001 2011-2012
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4.4.4.a 2 Does this information provide direction to relevant
documentation?
Not applicable No EMS documentation system should
provide direction to relevant
documentation
4.4.5 3 Is there a method to control all documents such that :
they can be located?
they are periodically reviewed, revised as necessary
and approved for adequacy by authorized
personnel?
current versions of all relevant documents are
available at appropriate operational locations?
obsolete documents are removed promptly and
their disposal ensured?
obsolete documents retained for reference are
suitably identified?
So far all documents within environmental department is
stored in the share point at site and share point in Jakarta.
Document control is part of each supervisor
responsibilities. Any changes of document, the supervisor
will give notice. Moreover, the tool box meeting every
morning ensures that all employees get informed regarding
the SOPs or any related issues.
Partly In the future, as part of EMS, it is
important to define a document control
system to control, EMS documentation
to ensure compliance with ISO 14001
standard requirements.
4.4.5 4 Is the documentation:
legible?
dated (with dates of revision)?
readily identifiable?
maintained in an orderly manner?
retained for a specific time?
The documentation in the share point is only available to
those who have access to share point, however, if there is
document need to be informed to all employees,
supervisor printed and put the document shelf.
Partly EMS procedure is to ensure that the
EMS documentation is legible, dated,
readily identifiable, maintained in
orderly manner, retained for specific
time.
4.4.5 5 Is there a method detailing who is responsible for
creation and modification of the various types of
documentation?
So far, there is no specific procedure to determine whose
roles and responsibilities for creation and modification of
various types, however supervisor responsible to establish
and ask for supervision and approval from the upper level.
Partly The responsibility for document
creation and modification should be
defined.
III. IMPLEMENTATION AND
OPERATIONAL ISSUES
6. Operational Control
4.4.6 1 Has the company identified those operations and
activities that are associated with the identified
significant environmental aspects in line with its policy
objectives and targets?
Yes partly, the company, in particular the environmental
department has identified environmental aspect impacts
based on activities, for example n, and environmental
inspection. However, it needs to see in other department,
whether other department also have standard operation
procedures based on the identified aspect and impacts
Partly EMS required documented, accessible
and implemented standard operation
procedures and control which based on
the identified environmental aspect and
impacts
2 Has the company planned these activities, including
maintenance, in order to ensure that they are carried out
under specified conditions by:
establishing and maintaining documented
procedures to cover situations where their absence
could lead to deviations from the environmental
policy and the objectives and targets?
stipulating operation criteria in the procedures?
establishing and maintaining procedures related to
Yes, the environmental department has some formal SOP
and work instruction sheet (maintenance schedule,
sampling schedule, and notice board) for internal use.
Detailed operation criteria and responsibilities are
moderately defined.
Partly EMS required well documented
operation control procedures to control
activities and operations related to
significant environmental aspects and
consider communicating these
procedures and requirements to
supplier and contractors. .
GAP ANALYSIS 1S0 14001 2011-2012
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the identifiable significant environmental aspects of
goods and services used by the company and
communicating relevant procedures and
requirements to suppliers and contractors?
III. IMPLEMENTATION AND
OPERATIONAL ISSUES
7. Emergency Preparedness and Response
4.4.7 1 Has the company established and maintained a method
to:
identify potential for accidents and emergencies?
respond to accidents and emergency situations?
prevent and mitigate the environmental impacts
that may be associated with them?
Yes. The environmental department has established
procedure operation when the environmental incident or
accidental take place, for example, oil spill, soil erosion , or
riots
Yes As part of the operation control, EMS
requires established and maintained
procedures in identifying potential for
accident, and respond to emergency
situation and mitigate the
environmental impact that may be
associated with them. Moreover, these
programmes should be tested and
revised periodically where necessary,
and communicate about it to all
employees.
2 Has the company reviewed and revised, where
necessary, its emergency preparedness and response
procedures, in particular, after the occurrence of
accidents or emergency situations?
In regards of emergency preparedness and response, the
OHS department also has significant roles and
responsibility. The fire system, lighting and power system
also has been monitored regularly. The maintenance and
preventive activities are done by the EMC department,
while emergencies related safety are organized by OHS
department. For example, during the pre construction
process, the frequency of traffic incident increase,
therefore the OHS department reviews the speed limit
regulation on the road.
Yes The company should establish,
maintain, and test (where practicable)
procedures to identify potential for and
to respond to accidents and
emergencies situations and for
preventing and mitigating the
environmental impacts that may be
associated with them
3 Has the company periodically tested such procedures
where practicable?
The company test the emergencies system such as during
fire, riots and evacuation
Yes All these procedures should be
periodically tested where practicable
IV. CHECKING AND CORRECTIVE ACTION
1. Monitoring and Measurement
1 Has the company established and maintained
documented procedures to monitor and measure on a
regular basis the key characteristics of its operations and
activities that can have a significant impact on the
environment?
Review of records and document system in the
environmental department shows that the department has
conducted regular monitoring and measurement on
resources usage, waste management record, baseline
environmental monitoring. Formal documented monitoring
and measurement procedures are absents.
Partly The company should establish and
maintain procedures to monitor and
measure, on regular basis, the key
characteristic of its operation and
activities that can have a significant
impact on the environment. Monitoring
equipement is calibrated according to
schedule and records are maintained.
Implementing a procedure to
GAP ANALYSIS 1S0 14001 2011-2012
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periodically evaluate compliance with
relevant environmental regulation and
legislations
2 Does this include the recording of information to track
performance, relevant operational controls and
conformance with the companys objectives and targets?
Some records are kept in hardcopy and softcopy, however,
as stated before the relation between the operational
control and conformance with the objectives and are
absent.
No The company should establish and
maintain documented procedures to
record information to tract
performance, relevant operational
control and conformance with the
objectives and targets
3 Do they calibrate and maintain monitoring equipment? The calibration of equipment is done regularly, in particular
for baseline environmental management.
Yes
4 Do they retain records of this process according to their
procedures?
Records are kept in the hard copy or soft copy file,
however, it is to be reorganize and coordinated so it is
accessible to others
Yes
5 Has the company established and maintained a
documented procedure for periodically evaluating,
compliance with relevant environmental legislation and
regulations?
One of the environmental impact assessment report
requirements is to provide quarterly environmental
monitoring and management plan to the Government, and
part of legislation and regulation comply, the company
welcome any site inspection by government authorities.
However, so far there is no formal documented procedure
to evaluate legal compliance periodically.
Partly The company should establish and
maintain a documented procedure for
periodically evaluating compliance with
relevant environmental legislation and
regulations.
IV. CHECKING AND CORRECTIVE ACTION
2. Non-conformance and Corrective and Preventive
Action
4.5.2 1 Has the company established and maintained methods
for defining responsibility and authority:
for handling and investigating
nonconformance?
for taking action to mitigate any impacts
caused?
for initiating and completing
Yes, when nonconformances occur, the site environmental
department manager normally reviews the issues and
assigned the superintendent and supervisor to inspect the
incident. Mitigation effort and corrective action then is
undertaken.
Yes The company should establish a
documented procedures for stating the
method and defining the responsibility
and authority:
for handling and investigation non
conformance
for taking action to mitigate any
impact caused
for initiating and completing
corrective and preventive action.
2 Has the corrective or preventive action taken to
eliminate the causes of actual and potential
nonconformance been appropriate to the magnitude of
problems and commensurate with the environmental
impact encountered?
Yes. In the environment inspection record shows the
corrective actions to response any environmental incident.
The inspection is carried out regularly and when the
incident occurs, the superintendent is informed to check it.
The superintended will base on their experience and
consult external parties where necessary to implement
appropriate actions to mitigate any abnormal
performance.
Yes
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3 Has the company implemented and recorded any
changes in the documented procedures resulting from
corrective and preventive action?
The department usually record the action in the
environmental inspection and corrective actions logbooks
Yes
4.5.2.A 4 In establishing and maintaining procedures for
investigating and correcting non-conformance, has the
company included these basic elements :
identified the cause of the non-conformance?
identified and implement the necessary actions?
implemented or modified controls necessary to
avoid repetition of the non conformance?
recorded any changes in written procedures
resulting from the corrective action?
Yes, as shown in the environmental inspection and
monitoring report, identification of cause of non
conformance, actions required and review are undertaken.
Yes EMS required all these basic elements
to be consider while establishing and
maintaining procedures for
investigating and correcting non
conformance
IV. CHECKING AND CORRECTIVE ACTION
3. Records
4.5.3 1 Has the company established and maintained methods
for the identification, maintenance and disposition of
environmental records?
Review on records and document, both hard copy and soft
copy shows that the department keeps records relevant to
resources usage and reuse, equipment. However, it still
need improvement in term of regularity and maintenance.
Yes EMS require establishment of
procedure for identification,
maintenance and disposition of
environmental records.
4.5.3 2 Do these records include
training records?
results of audits?
results of reviews?
Training records biweekly meeting and weekly meeting
reports are store in the share point and maintain the
updating regularly.
Yes EMS require the organization to identify
and keep all records that arise from the
implementation of the EMS
4.5.3 3 Are these environmental records:
Legible?
Identifiable?
traceable to the activity, product or service
Involved?
Yes, however the organization of the share point need to
be controlled by assigned employee
Yes Documents and procedures should
provide direction to relevant
environmental records which should be
dated., with title shown on the first
page.
4.5.3 4 Are the environmental records stored and maintained in
such a way that they are readily retrievable and
protected against damage, deterioration or loss?
Environmental record are stored in the softcopy and
hardcopy forms, each supervisor know the system
Yes The department should state the
responsibility of keeping environmental
records on EMS documents and
procedures.
4.5.3 5 Are retention times established and recorded? Every document is dated, however there is no information
on the retention time fro the document to be kept
NA The department should record the
retention times of environmental
records on EMS documents and
procedures
4.5.3 6 Are these records sufficiently maintained, as appropriate
to the system and to the company, to demonstrate
conformance to the requirements of ISO 14001
Standard?
Partly, systematic record on the implementation of EMS
procedures in order to conform to the requirements of ISO
14001 Standard are absen
No Record from implementation of EMS
should be identified and kept.
4.5.3 Do methods for identification, maintenance and
disposition of records focus on those records needed for
No formal method for identification, maintenance and
disposition of environmental records
No
GAP ANALYSIS 1S0 14001 2011-2012
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the implementation and operation of the environmental
management system?
4.5.3.A 7 Do they record the extent to which planned objectives
and targets have been met?
Analyses on existing records and compare the result with
the previous analysis. The results, which indicate
environmental performance, will be discussed in the
department meeting
Partly The department should define the
responsibility in environmental
management program for recording the
progress towards achieving the
c=objectives and targets
8 Do they keep the following environmental records?
a) information on applicable environmental laws
or other requirements;
b) complaint records;
c) training records;
d) product process information;
e) product information;
f) inspection, maintenance and calibration
records;
g) pertinent contractor and supplier information;
h) incident reports;
i) information on emergency preparedness and
response;
j) records of significant environmental aspects;
k) audits results;
l) management reviews.
The department keeps records except:
Pertinent contractor and supplier information
Record on significant environmental aspects
Audit results
Management reviews
Partly
IV. CHECKING AND CORRECTIVE ACTION
4. EMS Internal Audits
4.5.4 1 Has the company established and maintained (a)
programme(s) and methods for periodic Environmental
management system audits?
Not entirely. An environmental audit was conducted by the
representative of ERAMET, however this was carried out in
general with special attention to OHS department. Audit
was conducted in 2009
No The department should establish and
maintain a procedures for defining a
program for periodic EMS audits
4.5.4 2 Have they determined whether the environmental
management system:
conforms to planned arrangements for
environmental management including the
requirements of ISO 14001 Standard?
has been properly implemented and maintained?
Not applicable No The department should establish an
audit program and carry out regular
audits to ensure that the EMS:
conforms to planned arrangement
for environmental management
including the requirements for the
ISO 14001
has been properly implemented
and maintained.
4.5.4 3 Have they provided information on the results of audits
to management?
Not Applicable EMS audits results are discussed in
management review meeting
4.5.4 4 Is the programme based on the :
environmental importance of the activity
Not applicable No The company should consider all these
in establishing EMS audit program
GAP ANALYSIS 1S0 14001 2011-2012
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concerned?
results of previous audits?
4.5.4.A 5 Does the audit procedure cover:
the audit scope, i.e. the activities and areas to be
considered?
frequency?
methodology, i.e. how the audit will be conducted?
responsibilities associated with managing and
conducting audits?
requirements for conducting audits, i.e. auditor
competence?
requirements for reporting and communicating
the audit findings?
Not applicable NO Audit procedures should cover these
elements
6 Was the audit carried out
impartially?
objectively?
Not applicable No The company should arrange EMS
auditors properly to ensure audit are
performed impartially and objectively
V. MANAGEMENT REVIEW
4.6 1 Has the companys top management, at intervals it has
determined, reviewed the environmental
management system, to ensure its continuing :
suitability?
adequacy?
effectiveness?
The company top management have formal meeting for
review of general performance but not for EMS. Meeting
minute are kept
No The company should establish a
procedure to review EMS regularly,
based on EMS audits result, comment
from interested parties. The
management review provides a good
chance to see whether the
environmental policy is relevant to the
company activities and operation
4.6 2 Does the management review process ensure that the
necessary information is collected to allow management
to carry out this evaluation?
Not applicable No EMS required a procedures to ensure
that necessary information is collected
to allow management to carry out the
review
4.6 &
A.4.6
3 Has the review (observations, conclusions and
recommendations) been recorded/documented for
necessary action?
Not applicable No EMS required procedures to ensure to
ensure that the results of management
review are documented
4 Did the management review address the possible need
for changes to policy, objectives and other elements of
the EMS, in the light of environmental management
system audit results? the extent to which objectives and
targets have been met?
changing circumstances?
concerns amongst interested parties?
the commitment to continual improvement?
Not applicable A procedure to ensure that all these
elements are considered in the
management review process
5 Was the review of the policy, objectives and procedures
carried out by the level of management that defined
Not applicable No The management review should be
attended by top management, in
GAP ANALYSIS 1S0 14001 2011-2012
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them? particular the environmental general
manager and managers.