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Independent EMS Assessment
Standard Criteria | Small Business Criteria | Independent Assessment | Annual Performance Reporting | Site Visits
Summary of Criterion
Options for an Independent Party
Assessment
Options for Selecting an Assessment
Protocol
Qualifications for Performance Track
Site Visit Leaders
Summary of Criterion. Every three years, all members of the Performance Track Program must have an independent assessment of their environmental management system (EMS). New applicants must have had an independent assessment within two years of the date applications are due. The assessment must confirm that a functioning EMS that conforms to the Performance Track EMS criteria has been in place for at least one full plan-do-check-act cycle.
Facilities may correct minor non-conformances identified during the assessment without requiring a follow-up assessment. However, if an assessment finds major non-conformances, 1 facilities must undergo a follow-up independent assessment to confirm that such major non-conformances have been corrected and that the conformant EMS has progressed through a full plan-do-check-act cycle before being considered acceptable under this criterion.
This criterion is designed to ensure the quality of EMSs at Performance Track member facilities. For purposes of this criterion, an independent party is one that is neither directly employed by the applying facility; nor has the party played a substantive role in developing the facility’s EMS. The independent assessment must be conducted using the Performance Track Independent Assessment Protocol (PDF, 188KB, 21 pp About PDF) or another protocol that covers all of the provisions of the Performance Track Independent Assessment Protocol, such as an ISO 14001-based protocol amended to cover the additional Performance Track EMS criteria. 2
Options for an Independent Party Assessment. Facilities may select from a number of options for an independent assessment of their EMS. If unsure of the independent party’s qualifications, facilities should consult with their EPA Regional Performance Track Coordinator before conducting their assessment. A facility may choose from the following options:
-
An EMS assessment conducted in conjunction with participation in an EPA or State EMS/performance-based program and led by an individual meeting the qualifications of a Performance Track Site Visit Leader. Note that a Performance Track site visit is not a comprehensive EMS audit and does not qualify as an independent assessment of a facility’s EMS;
- An assessment conducted by one of the following
so long as the lead auditor is not directly employed
by the facility
and did not play a substantive role in
developing the EMS for the facility:
(a)an individual certified as an EMS lead auditor by the Registrar Accreditation Board Quality Society of Australasia International (RABQSA) or the Board of Environmental, Health, and Safety Auditor Certifications (BEAC). This includes ISO 14001 certification audits; however, per footnote 2, the ISO 14001 audit must incorporate the Performance Track EMS criteria;
(b)an individual who has demonstrated the qualifications of a Performance Track Site Visit Leader, except those qualifications related to i) the Performance Track site visit training course, ii) Performance Track site visits, and iii) current EPA or state employment;
(c)a corporate audit team whose audit team leader meets the requirements of (2)(a) or (b);
(d)a trade association EMS audit program whose audit team leader meets the requirements of (2)(a) or (b); or
(e)mentors that participate in the Performance Track mentoring program and who meet the requirements of (2)(a) or (b);
- An assessment of a Federal facility EMS conducted
according to the
Environmental Management Systems Agency
Self-Declaration Protocol for Appropriate Federal
Facilities,whose audit team leader meets the
requirements of (2)(a) or (b); or
- An assessment conducted by other entities, which will be considered on a case-by-case basis in consultation with EPA/states. EPA may conduct EMS assessments on a very limited basis for facilities that do not otherwise have the opportunity to select from one of the preceding options.
Options for Selecting an Assessment Protocol. Facilities may choose either to use: a) the Performance Track Independent Assessment Protocol (PDF, 188KB, 21 pp About PDF); b) their own protocol so long as it incorporates all elements of the Performance Track protocol; or c) a state protocol that is consistent with the Performance Track protocol. If possible, facilities should consult with EPA or their state in advance to discuss the acceptability of their own protocols.
Qualifications for Performance Track Site Visit Leaders
Individuals wishing to serve as a Site Visit Leader for a Performance Track site visit must meet the qualifications listed below.
| Background Requirements for Performance Track Site Visit Leaders | |
|---|---|
| Education | High school diploma |
| Training | 40-hour RABQMS Accredited ISO 14001 (EMS) Lead Auditor Training, passing score on course examination, and |
| Performance Track Site Visit Training | |
| Work and Audit Experience |
Work experience: in environmental
management, environmental science and technology,
environmental regulation, or related field as
follows:
|
| Audit experience: 20 work-day equivalents of environmental auditing, 3 which includes a minimum of four EMS audits 4 | |
| Participation in at least two Performance Track site visits as part of a site visit team. These two audits can be part of the minimum four EMS audits required above. | |
| Current Employment | To qualify as a Site Visit Leader, the individual must currently work at EPA, a state environmental agency, or be a duly authorized agent of EPA or the State. |