Using the Directives Process to Track EMS Requirements Department of Energy EMS Training Workshop...

Using the Directives Process to Track EMS Requirements

Department of EnergyEMS Training Workshop

Columbus, OHMarch 7-8, 2005

Daniel L. McCollum, Quality Assurance ManagerNational Energy Technology Laboratory

EMS Training – DLM/ES&H Division/March 7-8, 2005

4.3.2 – Legal and Other Requirements

The organization shall establish and maintain a procedureprocedure to identifyidentify and have accesshave access to legal and other requirementslegal and other requirements to which the organization subscribesorganization subscribes, that are applicableapplicable to the environmental aspects of its activities, products and services.

ISO 14001:1996 Standard


Implementation Philosophy

Use existing process where they work Build separate process if needed Converge the multiple processes later if

possible

What process exists that could be used to maintain the list of legal and other requirements?


History

Worksmart Standards Identified all legal, DOE,

consensus standards which applied to NETL

ISM Converted WS standards to

ISM-related standards EMS

Use of ISM identified standards and their relation to EMS – called the FOCUSED STANDARDS LIST


Focused Standards List

DOE Directives Other DOE Requirements Executive Orders Federal laws/regulations State laws/regulations Local ordinances ES&H References

(consensus) Standards


The Challenge: How to Maintain the FSL?

Bi-weekly regulatory updates OSHA EPA DOE

State/Local/Reference Standards Rely on the program manager who is the subject

matter expert Relationships with local regulators

Directives Process References and requirements are captured in

directives


Directives Process

Four Tiers of documents Tier 1: Policy

Orders Notices

Tier 2: Strategy/Implementation Operating Plans Procedures

Tier 3: Operational Control Standard Operating Procedures

Tier 4: EMS Records Forms Other records

DirectivesProcess


Example

450.1, Environmental Management System

450.1-1, Environmental Media Release Management

450.1-1, Ambient Air Quality Management

450.1-2, Groundwater Quality Management

450.1-3, Surface Water Quality Management

450.1-4, Industrial Wastewater Management

450.1-5, Spill Prevention and Control Management

450.1-9, Waste Handling, Storage and Disposal

450.1-10, Waste Minimization, Pollution Prevention, and Recycling

Program

POLICY

STRATEGY

IMPLEMENTATION


Reference Section

In each directive (order/notice, operating plan, procedure) DOE Directives (orders, policy, manuals, guides) Regulations (state, local, CFR, USC) Consensus standards (ANSI, ASME)

This makes up the universe of our legal and other requirements for all ES&H programs


Groundwater Procedure 3. REFERENCES.

a. DOE Order 225.1, Accident Investigations. b. DOE Order 231.1, Environmental, Safety and Health Reporting. c. DOE Order 414.1, Quality Assurance. d. DOE Order 450.1, Environmental Protection Program. e. NETL Order 450.1, Environmental Management System (EMS). f. NETL Operating Plan 151.1-1, Comprehensive Emergency Management System. g. NETL Operating Plan 450.1-1, Environmental Media and Release Management. h. NETL Operating Plan 450.4-1, Integrated ES&H Management Plan. i. NETL Procedure 151.1-1, Comprehensive Emergency Management System Administration. j. NETL Procedure 421.1-1, R&D Safety Analysis and Review System.


Groundwater Procedurek. Statutory ES&H Standards:

(1) 33 U.S.C. 1251, Federal Water Pollution Control Act, as amended. (2) 42 U.S.C. 300, Safe Drinking Water Act, as amended. (3) 40 Code of Federal Regulations (CFR) 141, National Primary Drinking Water Regulations. (4) 40 CFR 142, National Primary Drinking Water Regulation Implementation. (5) 40 CFR 143, National Secondary Drinking Water Regulations. (6) Pennsylvania Clean Streams Law (35 §§ 691.1-691.801). (7) Pennsylvania Act 610, Water Well Driller License Act. (8) West Virginia Code, Chapter 16, Article 1, Series III, Water Well Design Standards. (9) West Virginia Code, Chapter 20, Article 5A, Water Pollution Control Act. (10) West Virginia Code, Chapter 20, Article 5M, West Virginia Groundwater Protection Act. (11) West Virginia Code, Chapter 22, Article 6, Section 19, Continuance During Life of Well;

Dry and Abandoned Wells. (12) WV Title 33 Code of State Rules, Series 23 (33 CSR 23), Groundwater Protection Standard. (13) WV 46 CSR 12, Requirements Governing Groundwater Standards. (14) WV 47 CSR 55, Groundwater Protection Act Fee Schedule. (15) WV 47 CSR 58, Groundwater Protection Regulations. (16) WV 47 CSR 59, Monitoring Well Regulations. (17) WV 47 CSR 60, Monitoring Well Design Standards.


Groundwater Procedurel. DOE Policy ES&H Standards:

(1) Executive Order 12088, Federal Compliance With Pollution Control Standards, 10/13/78.

m. References: (1) “Groundwater Protection Management Plan at NETL-Pittsburgh” (2) “Groundwater Protection Management Plan at NETL-Morgantown” (3) “Handbook for Analytical Quality Control in Water and Wastewater Laboratories,”

(EPA-600/4-79-019), latest edition, EPA. (4) “Handbook for Sampling and Sample Preservation of Water and Wastewater,”

(EPA-600/4-76-049), latest edition, EPA. (5) “Methods for Chemical Analysis of Water and Wastewater,” U.S. EPA Technology Transfer (1974). (6) “Standard Methods for the Examination of Water and Wastewater,” Sixteenth Edition; APHA, AWWA, WPCF, current edition. (7) “Test Methods for Evaluating Solids Waste - Physical/Chemical Methods,” SW-846, 3rd Edition, U.S. EPA. (8) PADEP Groundwater Monitoring Guidance Manual, current edition.


The Process

Directive is created by

subject matter expert

Directive is approved by

approving authority

Entered into Tracking System

FSL is updated


Tracking SystemNumber Title References

151.1 Comprehensive Emergency Management System

DOE Order 151.1A, Comprehensive Emergency Management System

231.1 Environment, Safety, and Health Reporting

DOE Order 231.1, Environment, Safety, and Health Reporting.DOE Manual 231.1-1, Environment, Safety, and Health Reporting Manual.DOE Manual 231.1-2, Occurrence Reporting and Processing of Operations Information.

440.1 Safety and Health Program DOE Order 440.1, Worker Protection Management for DOE Federal and ContractorEmployees.DOE Policy 450.1, Environment, Safety and Health Policy.DOE Policy 450.5, Line Environment, Safety and Health Oversight.DOE Policy 454.1, Use of Institutional Controls.NETL Order 421.1, Safety Analysis and Review System.NETL Order 450.1, Environmental Management System (EMS).NETL Order 450.4, NETL Integrated Safety Management Program.NETL Operating Plan 440.1-1, Industrial Hygiene and Occupational Medicine Program.NETL Operating Plan 440.1-2, Chemical Hygiene Program.NETL Operating Plan 440.1-3, Construction and Maintenance Safety.NETL Operating Plan 440.1-4, General Workplace Safety Program.NETL Operating Plan 440.1-5, Fire Protection Program.NETL Operating Plan 440.1-6, Indoor Air Quality and Ventilation Operating Plan.NETL Operating Plan 450.4-1, Integrated ES&H Management Plan.DOE F 5484.3, Individual Accident/Incident Report.Statutory ES&H Standards:(1) 29 CFR 1910, Occupational Safety and Health Standards.(2) 29 CFR 1910.119, Subpart H, Process Safety Management of Highly HazardousChemicals.(3) 29 CFR 1926, Safety and Health Regulations for Construction.(4) 29 CFR 1960, Federal Occupational Safety and Health Program.


Example

New Water Quality Standard is issued: 40 CFR XXX

Directive is revised 450.1-2, Groundwater Quality Management

References Section is updated to include new standard

Directive is entered into tracking system FSL is updated

Includes hyperlink to new standard, if available Order hardcopy if hyperlink is not available


Lessons Learned

The FSL meets ISO 14001 requirements Forces the SME to be more judicious in

choosing references Each one must be tracked

Used an existing process to meet a new need One contractor maintains the directives process and

the FSL Virtually no additional cost

FSL is accurate and timely

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