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Independent EMS Assessment
Standard Criteria | Small Business Criteria | Independent Assessment | Annual Performance Reporting | Site Visits
Summary of Criteria
Definition of an Independent Assessment
Differences Between Performance Track EMS Criteria and ISO 14001
Corrections of Non-Conformances Identified by the Independent Assessment
Options for an Independent
Assessment
Options for Selecting an Assessment
Protocol
Qualifications for Independent Assessment Team Members
Lead Auditor Certification
Assessment Scope, Duration, and Team Size
Summary of Criteria. The Performance Track EMS Independent Assessment criteria are designed to ensure the quality of the environmental management system (EMS) at a Performance Track member facility. All members of the Performance Track Program must have an independent assessment of their EMS every 3 years. For new applicants to the program, they must have had an independent assessment within 2 years of the application due date for the round in which they are applying. This requirement will be deemed to be met for organizations under an ISO 14001:2004 surveillance contract. Members should not exceed 3 years between assessments. The assessment must confirm that a functioning EMS, that is in conformance with the Performance Track EMS criteria, has been in place for at least one full PLAN-DO-CHECK-ACT cycle.
Definition of an Independent Assessment. For purposes of these criteria, an independent assessment is one performed by an independent party. An independent party is someone who is neither directly employed by the applying/member facility nor has played a substantive role in developing the facility's EMS. The independent assessment shall be conducted using an acceptable protocol (see below) that covers all the elements of the Performance Track EMS criteria as set out in the Performance Track Program Guide.
Differences between Performance Track EMS Criteria and ISO 14001. The Performance Track EMS criteria contain several important differences from ISO 14001. These include:
- Sharing of information regarding environmental performance with the public.
- Continual improvement in environmental performance (in addition to continual improvement of the system).
- Pollution prevention as defined by the EPA hierarchy with source reduction as the first preference.
- Measurable objectives and targets to meet the facility's Performance Track goals.
- Defined procedures, including a formal audit program, to achieve and maintain compliance.
- Prompt corrective action of any legal or EMS non-conformance.
- Communication about the facility's environmental performance throughout the organization.
- Documented management review of performance against objectives and targets.
Correction of Non-Conformances Identified in the Independent Assessment. Facilities may correct minor non-conformances identified during the independent assessment without requiring a follow-up assessment. However, if an assessment finds major non-conformances,* then the facility is required to undergo a follow-up independent assessment to confirm that all major non-conformances have been corrected. If a major EMS element was determined to be non-functional and/or not in-place during the independent assessment, then the EMS must go through a full PLAN-DO-CHECK-ACT cycle and be re-assessed before being considered acceptable under these criteria.
* Major non-conformances include, but are not limited to, the non-functioning or absence of specific EMS elements such as: a) comprehensive aspects identification process; b) compliance or EMS audit program; c) EMS organizational responsibilities; or d) performance measurement and continuous improvement programs. Major non-conformances can also result due to the presence of multiple minor non-conformances to the same element.
Options for an Independent Assessment. Facilities have a number of options for an independent assessment of their EMS. A facility may choose from the following:
- A comprehensive EMS audit conducted in conjunction with participation in a State EMS/performance-based program and whose audit team members meet the requirements of the Qualifications for Independent Assessment Team Members below; or
- An assessment conducted by one of the following (a – c) 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:
- an audit led by an individual certified as an EMS lead auditor by RABQSA or the Board of Environmental, Health & Safety Auditor Certifications (BEAC). This includes ISO 14001:2004 certification audits; however, the ISO 14001:2004 audit must incorporate the Performance Track EMS criteria as discussed above;
- a corporate audit whose audit team members meet the requirements of (2)(a) or the Qualifications for Independent Assessment Team Members below;
- an audit conducted under an established trade association EMS audit program (e.g., the Responsible Care audit program) whose audit team members meet the requirements of (2)(a) or the Qualifications for Independent Assessment Team Members below; or
- An assessment of a Federal facility EMS conducted according to the Environmental Management Systems Agency Self-Declaration Protocol for Appropriate Federal Facilities (PDF) (3 pp, 369K) whose audit team members meet the requirements of (2)(a) or the Qualifications for Independent Assessment Team Members below; or
- An assessment conducted by other entities, to be considered on a case-by-case basis in consultation with their EPA Regional Performance Track Coordinator.
Options for Selecting an Assessment Protocol. ISO 14001:2004 and RC 14001:2005/2008 certified facilities need only ensure that their registrar incorporates the additional Performance Track EMS criteria into their audit planning and protocol. ANSI-RAB, now the ANSI-ASQ National Accreditation Board (ANAB), issued Heads Up, Issue 9 (PDF) (1 p, 80K, About PDF) to all of its accredited registrars on February 5, 2003 to address this issue. It makes clear that registrars must consider voluntary programs, such as Performance Track, in their registration audits.
Non-ISO 14001:2004 or RC 14001:2005/2008 certified facilities may choose any EMS auditing protocol as long as it addresses the EMS criteria in the Performance Track Program Guide. Facilities should consult with their EPA Regional Performance Track Coordinator in advance to discuss the acceptability of their own protocols.
EPA is also making available two other EMS protocols as a resource for facilities. The first was developed by EPA for external assessments of its own facilities and the second was developed by the Texas Commission on Environmental Quality (TCEQ) for use in its Clean Texas program.
- EPA External EMS Review Protocol (PDF) (47 pp, 361K, About PDF)
- TCEQ Interim Audit Protocols (PDF) (29 pp, 318K, About PDF)
Facilities can adapt these protocols for their own use if they wish; however, as with any protocol they propose to use, they should supplement them as necessary to ensure that all of the Performance Track EMS criteria are covered.
Qualifications for Independent Assessment Team Members
Individuals wishing to serve as auditors for the purpose of a Performance Track EMS Independent assessment must meet the qualifications listed in the table below. If a facility is unsure of a proposed auditor's qualifications, it should consult with its EPA Regional Performance Track Coordinator for guidance. The selection of the auditors should be based on the ISO 19011:2002 Guidelines for quality and/or environmental management systems auditing.
Qualification Category |
Lead Auditor |
Audit Team Members |
|---|---|---|
Education |
Bachelor's degree |
Bachelor's degree |
Training |
40-hour RABQSA Accredited ISO 14001:2004 EMS Lead Auditor Course or IPC (formerly IATCA) EMS Lead Auditor courses; must receive passing grade on course examination. |
40-hour RABQSA Accredited ISO 14001:2004 EMS Lead Auditor Course or IPC (formerly IATCA) EMS Lead Auditor courses; must receive passing grade on course examination. |
Work Experience |
Five years of work experience in environmental management, environmental science and technology, environmental regulation, or related field. |
Three years of work experience in environmental management, environmental science and technology, environmental regulation, or related field. |
Auditing Experience |
Auditing experience required is thirty-five audit days1 acting in the role of lead auditor planning, conducting, and reporting on full EMS audits.2 A maximum of ten days of off-site audit activity is allowed in these thirty-five days. Included in the thirty-five audit days, an applicant must demonstrate at least seven complete environmental management system audits as a solo auditor, as a member of an audit team or as an audit team leader. At least three of the complete audits and a total of at least fifteen audit days must be performed as an audit team leader managing a team of at least one other auditor. |
Auditing experience required is twenty audit days2 acting in the role of co-auditor participating in environmental audits.3 A maximum of six days of off-site audit activity is allowed in these twenty days. Included in the twenty audit days, an applicant must demonstrate at least four complete environmental management system audits as a member of an audit team. |
Source: Adapted from PCD19 – RABQSA Competence Qualifications of EMS Auditors
1. An audit day as defined by the ANAB is a minimum of 8 hours. Additional hours above 8 over multiple days may not be used to make additional audit days.
2. EMS audit experience can include ISO 14001:2004 audits, RC 14001:2005/2008 audits, and other EMS audits using a an audit protocol consistent with the EMS requirements in the Performance Track Program Guide.
3.
Audit experience can include regulatory, compliance assistance, pollution prevention, or EMS audits.
EPA recommends that the Lead Auditor complete the Performance Track EMS Independent Assessment Certification (PDF) (1p, 76K, About PDF). This certification will state that the Lead Auditor meets the requirements for education, training, and experience above and that the assessment covered all of the Performance Track EMS Criteria. The Performance Track member should retain this certification in its EMS records.
Assessment Scope, Duration, and Team Size
The independent assessment must include all of the Performance Track EMS criteria in addition to whatever other EMS criteria to which the organization subscribes. The following tables provide recommended guidelines on determining the duration of the assessment and the size of the audit team. When calculating the number of man-days for the independent assessment, Table 2 should be used. Table 3 provides guidance on the complexity of the facility audited. EPA recommends the use of at least two auditors, whenever practicable, to ensure an effective audit. If the independent assessment will be performed by an accredited registrar for issuance of the ISO 14001 or RC 14001 certificate, then the registrar's procedures for determining audit days may be used.
If a facility is unsure of the requirements for independent assessment of their EMS, it should consult with their EPA Regional Performance Track Coordinator for guidance.
Number of Employees |
High Complexity |
Medium Complexity |
Low Complexity |
Limited Complexity |
|---|---|---|---|---|
1-10 11-30 31-100 101-500 5001-2000 |
4 ± 1 7 ± 2 11 ± 3 16 ± 5 23 ± 7 |
3 ± 1 6 ± 2 8 ± 3 12 ± 3 18 ± 5 |
3 ± 1 4 ± 1 6 ± 2 9 ± 3 13 ± 4 |
3 ± 1 3 ± 1 4 ± 1 6 ± 2 8 ± 2 |
Source: IAF Guidance on the Application of ISO/IEC Guide 66, Issue 3, November 1, 2003.
Complexity Category |
Business Sector |
|---|---|
High |
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Medium |
|
Low |
|
Limited |
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Special Cases |
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