Attachment_A_-_OCCC_ISO-14001-2022_Report.pdf

Prepared For:

Orange County Convention Center

Orlando, Florida

Prepared By:

Douglas Dean, P.E., CHMM, CSP

Matrix Compliance Services, LLC

December 2022

OCCC ISO 14001 SYSTEM

2022 INTERNAL AUDIT REPORT

OCCC ISO 14001 REVIEW Page 1

EXECUTIVE SUMMARY

The ISO 14001 is an international standard for an Environmental Management System (EMS) with the goal of improving environmental performance through such OCCC approaches as efficient use of resources, reduction of waste and providing environmentally friendly cleaning solutions and operations.

This achievement is substantial given a number of organizational changes in recent years, a reflection of

OCCC’s desire to continue in the EMS’s benefits to the environment, the surrounding community and the organization.

Maintaining its EMS is also a substantial accomplishment given the major economic challenges due to

COVID-19. In addition to its EMS, OCCC in 2020 achieved accreditation from the Global Biorisk Advisory

Council (GBAC). This means the facility has established and maintained a cleaning, disinfection, and infectious disease prevention program to minimize risks associated with infectious agents like the virus that causes COVID-19. Having this GBAC accreditation, OCCC has seen opportunities to host new clients, taking advantage of the opportunities presented in these challenging times. OCCC has been responsive to Client’s demands for safe, sanitized areas and created safe “bubbles” that satisfy Client expectations.

The efforts to manage the risks from COVID-19 are applicable to specific Environmental Services duties occurring within the EMS fenceline. For example, OCCC has acquired UV disinfection equipment used by

Environmental Services employees to disinfect areas potentially affected by the virus and has changed out certain cleaning chemicals to ensure that all of the sanitizing products used are EPA-approved.

Matrix Compliance Services, LLC (Matrix) contracted with OCCC to examine the EMS and other activities and compare them to the ISO 14001 standard, identifying any deficiencies and recommendations for change. In 2022, the approach used by Matrix to accomplish this objective was to use a checklist format consisting of questions to address each specific element. Evidence to support the EMS conformance was obtained during a videoconference with participants with OCCC: Pam Cavanaugh, Paul Suedmeyer and

Katerina Chagoya, PhD.

Katerina, OCCC’s Sustainability Coordinator who has been appointed the Environmental Management

Representative (EMR) for OCCC, was particularly helpful during this internal audit. Katerina received the checklist provided by Matrix and gathered the audit evidence to show conformity with the ISO standard and the existing EMS procedures. This information was reviewed and discussed with the audit participants during the conference call held on December 5, 2022.

A significant part of the discussion involved the expansion of the EMS fenceline to include Facility

Operations. In this auditors opinion, this would be a positive move because: 1) the EMS procedures would bring greater internal accountability to the Facility Operations performance by introducing a more formal corrective action process; 2) the EMS will document and highlight the environmental benefits achieved by Facilities Operations activities, such as filter changes after dog shows to improve indoor air quality; 3) expansion of the fenceline will lead to a more robust EMS and demonstrate greater commitment.

OCCC ISO 14001 REVIEW Page 2

The overall finding was that OCCC is in substantive conformance with ISO 14001 and its own standard operating procedures. There was no EMS nonconformance, as was the case in 2021. When coupled with OCCC’s other achievements such as the LEED Gold Recertification and projects such as the solar project, OCCC’s commitment to sustainability is obvious.

In addition, the auditor found no recommendations for improvement to correct an observation of potential deficiency. A summary of audit findings is in Table 1. The auditor wishes to acknowledge the cooperation of all OCCC audit participants that allowed the information review to be very efficient.

OCCC ISO 14001 REVIEW Page 3

Table 1. Audit Findings

ELEMENT NUMBER AND DESCRIPTION

AUDIT RESULTS

No. of Majors / No. of Minors

A, N, or X*

4.1 Understanding the Context 0/0 A

4.2 Understanding Needs/Expectations 0/0 A

4.3 Determining the EMS Scope 0/0 A

4.4 Environmental Management System 0/0 A

5.1 Leadership and Commitment 0/0 A

5.2 Policy 0/0 A

5.3 Organizational Roles and Authorities 0/0 A

PLANNING

6.1.1 General 0/0 A

6.1.2 Significant Aspects 0/0 A

6.1.3 Compliance Obligations 0/0 A

6.1.4 Risks associated with Threats/Opportunities 0/0 A

6.2.1 Environmental Objectives 0/0 A

6.2.2 Planning Actions to Achieve Objectives 0/0 A

SUPPORT

7.1 Resources 0/0 A

7.2 Competence 0/0 A

7.3 Awareness 0/0 N

7.4 Communication 0/0 A

7.5 Documented Information 0/0 A

OPERATION

8.1 Operational Planning and Control 0/0 A

8.2 Emergency Preparedness and Response 0/0 A

PERFORMANCE MONITORING

9.1 Monitoring and Measurement 0/0 A

9.1.1 General 0/0 A

9.1.2 Evaluation of Compliance 0/0 A

9.2 Internal Audit 0/0 A

9.3 Management Review 0/0 A

IMPROVEMENT

10.1 General 0/0 A

10.2 Nonconformity and Corrective Action 0/0 A

10.3 Continuous Improvement 0/0 A

TOTAL 0/0 A

Legend:

A = Acceptable: Interviews and objective evidence indicates that the EMS meets all the requirements of that section of the standard.

N = Not Acceptable: The auditor has made the judgment that, based on the number and type of nonconformances, the requirements of that the section of the standard are not being met.

X = Not Audited

OCCC ISO 14001 REVIEW Page 4

AUDIT DOCUMENTATION: AUDITOR CHECKLIST

4.0 CONTEXT OF THE ORGANIZATION

4.1 Understanding of the organization and its context 5

4.2 Understanding the needs and expectations of interested parties 6

4.3 Determining the scope of the environmental management system 7

4.4 Environmental Management System 8

5.0 LEADERSHIP

5.1 Leadership and commitment 9

5.2 Policy 10

5.3 Organizational roles, responsibilities and authorities 11

6.0 PLANNING

6.1 Actions to address risks and opportunities 12

6.1.1 General 12

6.1.2 Significant environmental aspects 13

6.1.3 Compliance obligations 14

6.1.4 Risk associated with threats and opportunities 15

6.2 Environmental objectives and planning 16

6.2.1 Environmental objectives 17

6.2.2 Planning actions to achieve environmental objectives 17

7.0 SUPPORT

7.1 Resources 18

7.2 Competence 19

7.3 Awareness 20

7.4 Communication 21

7.4.1 General 21

7.4.2 Internal communication 22

7.4.3 External Communication 22

7.5 Documented Information 23

7.5.1 General 23

7.5.2 Creating and Updating 23

7.5.3 Control of Documented Information 23

8.0 OPERATION

8.1 Operational Planning and Control 24

8.2 Emergency preparedness and Response 25

9.0 PERFORMANCE MONITORING

9.1 Monitoring, measurement, analysis and evaluation 26

9.1.1 General 26

9.1.2 Evaluation of Compliance 27

9.2 Internal Audit 28

9.2.1 General 28

9.2.2 Internal 28

9.3 Management Review 29

10.0 IMPROVEMENT

10.1 General 30

10.2 Nonconformity and corrective action 31

10.3 Continuous Improvement 32

OCCC ISO 14001 REVIEW Page 5

Clause # Requirements Comments

4 CONTEXT OF THE ORGANIZATION

4.1 Understanding of the

organization and its context:

The organization shall determine external and internal issues that are relevant to its purpose and that affect its ability to achieve the intended outcome(s) of its environmental management system. Those issues include environmental conditions capable of affecting or being affected by the organization.

Does the organization have a high-level, conceptual understanding of the internal and external issues that can affect, either positively or negatively, its ability to achieve the intended outcomes of its Environmental Management System (EMS)?

Describe the process used to identify internal and external issues. Reference objective evidence, including examples of these issues.

Organization’s Issues examples:

a. Environmental conditions capable of affecting or being affected by the organization. For example, the impacts on environmental conditions like air quality, water quality, land use, existing contamination, natural resource availability, biodiversity, etc.

b. External: cultural, social, political, regulatory, financial, economic, natural and competitive issues, whether national, regional or local

c. Internal: organization’s activities, products, services, strategic direction and capabilities (people, knowledge, processes, systems)

Observations/Evidence:

The EMS Manual, Section 4.1, describes the general context of the organization. The section was reviewed and approved by Terry DeVitt, Assistant Director and Hector Clemente, Assistant Manager of Building Systems.

Interviews with these two representatives of Top Management in 2021 verified their familiarity with the context in the EMS Manual and their approval; therefore, it appears that Top Management has demonstrated leadership in the high-level description of OCCC’s context.

Under the heading of General Context, Section 4.1 describes organizational context, environmental context, natural disasters and emergency response, heat/cold extremes, economy, guest/customer perception, regulatory environment and capital projects plan. These descriptions were at a high level and were comprehensive from a business perspective. There were references to some of the sustainability initiatives that OCCC has undertaken.

It is noteworthy that a substantial portion of the Capital Plan and time in the Facilities Operations meetings is set aside for sustainability-related initiatives.

Section 4.1 has not changed since the previous audit, and all information is current. Management will approve this section in the 2022 Management Review meeting.

OCCC ISO 14001 REVIEW Page 6

4 CONTEXT OF THE ORGANIZATION

4.2 Understanding the needs and

expectations of interested parties:

The organization shall determine the interested parties that are relevant to the environmental management system. The relevant needs and expectations (i.e. requirements) of these interested parties;

which of these needs and expectations become compliance obligations.

Has the organization adequately determined the interested parties and their requirements relevant to its EMS? Which of these requirements are considered as organization’s compliance obligations?

Describe the process used by the organization to identify the interested parties. Examples of interested parties: customers, communities, contractors, suppliers, regulators, business partners, etc.

The organization has the right to decide which interested party requirements will be considered as “compliance obligations,” as each interested party may also have its own set of requirements, but not all of these will be relevant to the organization’s EMS.

“Compliance obligations” include: All relevant legal requirements; requirements imposed by upper levels in the organization (for example Orange County); or Vendor contractual requirements.

Interested parties are identified in Section 4.2. An “Interested Parties Chart” is included in this section that breaks out interested parties based on the categories of “Internal” and “External”. Within these two categories the interested parties are broken out into the following: interested parties; interests; needs; expectations; risks and opportunities.

This chart was used to identify compliance obligations, which includes legal requirements and contractual obligations with vendors. Interviews with Terry DeVitt and Hector Clemente in 2021 verified their familiarity and approval of this chart. Management leadership is apparent in the review and adoption of this chart used to satisfy

Section 4.2 of the ISO specification.

There were no recent changes to this chart in 2022 since the initial acceptance.

OCCC ISO 14001 REVIEW Page 7

4 CONTEXT OF THE ORGANIZATION

4.3 Determining the scope of the

environmental management system:

The organization shall determine the boundaries and applicability of the environmental management system to establish its scope.

Has the organization determined the boundaries and applicability of the EMS to establish its scope?

Has the organization effectively considered the following prior to determining the scope of the EMS? The extent of organization’s control and influence, context, external and internal issues, compliance obligations, physical and functional boundaries, activities, products and services?

Has the organization made its scope available to all interested parties as documented information?

Evaluate the process by which the scope of the EMS was determined. Review any process or procedure, if present. Lack of a documented process will require more reliance on objective evidence from interviews.

Auditors may need to question if any activities, products and services that would likely have a significant impact on the environment are omitted from the scope of the EMS. The organization’s scope determinations should be reasonable and consistently applied.

OCCC needs to ensure that the organization has made the documented scope available to its interested parties. A statement from the organization that the scope will be provided upon request may be accepted as evidence.

Observations/Evidence:

The current scope or “fenceline” is organizational, i.e., Environmental Services. There is discussion about expanding the fenceline to include other Facilities Operations departments.

There are significant improvements that regularly occur outside the fenceline that can easily be drawn into the

EMS. The challenge does not seem to be environmental performance, rather, it is obtaining buy-in occur in other

Departments to adopt the EMS-specific processes.

OCCC ISO 14001 REVIEW Page 8

4 CONTEXT OF THE ORGANIZATION

4.4 Environmental Management

System:

The organization shall consider the knowledge of its context and interested parties when establishing and maintaining the EMS.

While establishing, implementing, maintaining and continually improving the EMS;

Has the organization implemented an EMS, including all required processes, in accordance with the requirements of ISO 14001?

Has the organization considered the knowledge it gained from its context and its interested parties’ requirements?

ISO14001:2015 includes specific requirements necessary for the adoption of processes when developing, implementing and improving the EMS. This requires an organization to systematically define and manage processes and their interactions so as to achieve the intended results in accordance with both the policy and strategic direction of the organization.

EMS processes may be defined to address supplier, internal or external issues; materials, resources, energy and wastes; activities, products and services; customers and end-users.

A brief description of the system processes could consider the interrelationships between the following EMS components:

• Context→Interested Parties→Compliance Obligations→Policy→EMS Procedures, o Scope→Significant aspects→Operational Procedures→Environmental Performance,

▪ Review of EMS→Recommendations to Improve→Management Review/Support.

The EMS Manual Section 4.4 adequately describes the processes for establishing environmental objectives and the development of operational procedures to achieve these objectives.

Neither the context of the organization nor the interested parties have changed. There have been no changes that have impacted the EMS in 2022.

OCCC ISO 14001 REVIEW Page 9

5 LEADERSHIP

5.1 Leadership and commitment:

Top management shall demonstrate leadership and commitment with respect to the environmental management system.

• Ensuring that policy and objectives are relevant to the strategic direction and the context of the organization.

• Ensuring the integration of the environmental management system requirements into the organization’s business processes.

• Directing and supporting persons to contribute to the effectiveness of the quality management system.

• Supporting other relevant management roles to demonstrate their leadership as it applies to their areas of responsibility.

Is top management demonstrating accountability for the effectiveness of the EMS?

Are the environmental policy and objectives established, and compatible with the strategic direction and the context of the organization? Is top management involvement evident?

Does top management ensure that the EMS requirements are integrated into the organization’s business processes?

Does top management ensure the availability of resources needed for the EMS?

Does top management communicate the importance of effective environmental management and of conforming to the EMS requirements?

Does top management ensure that the EMS achieves its intended outcome(s)?

Does top management direct and support persons to contribute to the effectiveness of the EMS?

Does top management promote continual improvement?

Does top management support other relevant management roles to demonstrate their leadership in their areas of responsibility, when applicable?

Evidence of top management involvement may be found in:

Business strategy plans & meetings; Environmental goals & communications; Information provided on the organization’s website; Annual reports; and, Management meeting minutes.

Management has revised its Policy into an “Environmental Commitment”. Along with the previous commitments, the Policy mentions improving levels of sustainability and environmental stewardship.

Management engagement was verified by examining the weekly meetings of Facility Operations. These meetings, which include Terry DeVitt as executive management, routinely has EMS and Sustainability topics on the agenda.

These meetings are frequently attended by representatives from upper management. The topics covered during these meetings confirmed that the EMS is often discussed under the heading of sustainability. This is documented evidence of Management's leadership in the EMS and other environmental initiatives.

For 2022, several sets of meeting minutes were submitted that show the Facility Operations meetings are ongoing, still attended by management representatives, and still include topics related to sustainability and the ISO 14001

EMS.

OCCC ISO 14001 REVIEW Page 10

5 LEADERSHIP

5.2 Policy:

Top management shall establish, implement and maintain an environmental policy, and make Policy available to interested parties.

Is the policy appropriate to the defined scope, purpose, and context of the organization, including the nature, scale and environmental impacts of its activities, products and services?

Does the policy provide a framework for setting environmental objectives?

Does the policy include a commitment to protection of the environment, covering prevention of pollution and other specific commitments relevant to the context of the organization?

Does the policy include a commitment to fulfill the compliance obligations?

Does the policy include a commitment to Continual improvement of the EMS to enhance environmental performance?

Is the policy maintained as documented information?

Is the policy communicated within the organization, to all persons doing work (directly or indirectly) under the organization's control?

Is the policy made available to interested parties?

ISO14001:2015 now requires that an organization’s environmental policy is appropriate to both its purpose and context. This means that once the organization has determined its context and the relevant requirements of its interested parties, top management must review its environmental policy in light of that information.

Objective evidence must include an interview with top management covering the points a) to e) to ensure thorough understanding and leadership at the highest level. If the top management is not involved; a non-conformance must be issued.

The existing OCCC Policy was updated and signed by top management, thus satisfying the requirement for a Policy in Clause 5.2, Environmental Policy. The Policy includes specific commitments to the Orange County’s

Sustainability Operations and Resiliency Action Plan (SORAP), the OCCC Sustainability Action Plan and the EMS.

OCCC had some changes to our upper management mid- to late-2022. Mr. Ingram has left the OCCC as of

November 2022. In addition, Yulita Osuba has also left upper management. OCCC’s policy containing the new staff members will be signed during the Management Review. However, a replacement for Mr. Ingram has not yet been chosen.

OCCC ISO 14001 REVIEW Page 11

5 LEADERSHIP

5.3 Organizational roles, responsibilities and authorities Top management shall ensure that the responsibilities and authorities for relevant roles are assigned and communicated.

Ensuring that the environmental management system conforms to the requirements of this International Standard and reporting on the performance of the environmental management system, to top management.

In order to facilitate effective environmental management:

Does top management ensure that the roles and their relevant responsibilities and authorities are assigned and communicated within the organization to ensure that:

EMS conforms to the requirements of the ISO14001:2015 standard?

Performance of the EMS, including environmental performance, is reported to top management?

Auditors should note that there is no longer a requirement for appointment of Management Representative (MR), though the duties currently assigned to the EMR under ISO14001:2004 must still be undertaken and can be assigned to different personnel.

Auditor must seek evidence that organization’s personnel have not only been advised of their EMS responsibilities and authorities, but also that they understand these in the context of the overall purpose of the EMS.

Auditors must also seek evidence that top management have assigned responsibility and authority for preserving the integrity of the organization’s EMS during changes.

The existing Manual specifies the roles and responsibilities for implementing and maintaining the EMS. This information was reformatted into a new Section 5.3.

There is amble evidence that Top Management has assigned responsibility and authority for preserving and maintaining the integrity of the EMS during changes. In 2022, Management assigned the role of EMR to Katerina

Chagoya. In January, the new EMR received a 1 hour virtual training from EcoPreserve on the EMR responsibilities.

OCCC has stayed on track, despite significant organizational changes, in making the transition to 14000:2015.

Inspection of Facilities Operations meeting minutes should several references to “requires management decision”, providing evidence that management is properly involved in some of the daily activities that occur in the fenceline.

OCCC ISO 14001 REVIEW Page 12

6 PLANNING

6.1 Actions to address risks and

opportunities

What process has been developed to identify risks and opportunities?

6.1.1 General

The organization shall plan and implement a process to meet the requirements in 6.1. When planning for the environmental management system in 6.1 (i.e.

6.1.2 ‐ 6.1.4), the organization shall consider the issues referred to in 4.1 and the requirements referred to in 4.2.

Is it evident that the organization has considered its context, relevant requirements of their relevant interested parties and their defined scope when planning for the EMS?

Does the organization maintain documented information on its risks and opportunities, and are the processes needed documented to the extent necessary to be sure they are carried out as planned?

Has the organization determined the risks and opportunities that need to be addressed to:

• give assurance that the EMS can achieve its intended outcome(s)?

• prevent, or reduce, undesired effects, including the potential for external environmental conditions to affect the organization?

• achieve continual improvement?

“Risks and opportunities” are defined as: Potential adverse effects (threats) and Potential beneficial effects (opportunities).

Although risks and opportunities have to be determined and addressed, there is no requirement for a formal, documented risk management process. Auditors should seek evidence confirming that an organization has a methodology in place that enables them to effectively identify risks and opportunities with respect to the planning of its EMS.

Objective evidence may be in the form of a risk matrix, risks added to other forms such as an aspect register, corrective/preventive action log and forms, etc. All of the processes of an EMS do not represent the same level of risk in terms of the organization’s ability to meet its objectives. Due to this reason, the consequences of failures or non-conformities in relation to processes, systems, products and/or services will not be the same for all organizations.

Observations/Evidence:

Risks and opportunities are identified in Section 4.2 on the “Interested Parties Chart”. This chart is an accurate reflection of the context of the organization as described in the manual. There have been no recent changes to this chart, but it will be reviewed by Management on an annual basis.

There has been no change to the “Risks and Opportunities” part of the EMS in 2022.

OCCC ISO 14001 REVIEW Page 13

6 PLANNING

6.1 Actions to address risks and

opportunities

6.1.2 Significant environmental

aspects Identified aspects considering a life cycle perspective; have also identified abnormal and potential emergency situations.

The organization shall communicate its significant environmental aspects among the various levels and functions of the organization.

Has the organization identified environmental aspects of the activities, products or services under its control / influence?

Does the organization’s determination of environmental aspects consider a life cycle perspective?

Do the identified aspects take into account change? i.e.

• Planned or new developments and

• New or modified activities, products and services?

Do the identified aspects cover abnormal and potential [foreseeable] emergency situations as well as normal situations?

Does the organization determine its significant environmental aspects (those aspects that have or can have a significant impact on the environment)?

Has the organization communicated its significant environmental aspects among the various levels and functions with the organization?

This is almost the same requirement as in the 2004 edition.

New: Life-cycle Perspective Consideration of environmental aspects and impacts has been broadened. Environmental aspect identification and evaluation process must now consider a life-cycle perspective.

A full-scale life-cycle analysis is not required. However, the organization needs to consider aspects associated with: natural resources uses (water withdrawal); purchased raw materials;

transportation; by-products: air, waste and waste emissions;

transportation of products; end of life – recycling and disposal.

Observations/Evidence:

The existing process for identifying significant aspects continues to be used as before to satisfy the requirements, except that that life cycle perspective and compliance obligations is considered. Consideration is also given to the context and risks/opportunities beyond legal requirements. These can be thought of as “significance criteria” along with impacts to air, water, etc. OCCC has already considered life cycle with its purchases of green products and recycling efforts.

Life cycle considerations includes such things as purchased raw materials (green purchasing) and end-of-life issues such as wastes or recycled materials. Some of these issues such as purchasing of green products and equipment have been met as part of obtaining OCCC’s LEED certification.

In 2022, Environmental services’ significant aspects and the process to identify them was not changed.

OCCC ISO 14001 REVIEW Page 14

6 PLANNING

6.1.3 Compliance obligations:

The organization shall:

• Identify and have access to the compliance obligations related to its environmental aspects;

• Determine how these compliance obligations apply to the organization.

The organization shall maintain documented information of its compliance obligations.

Does the organization determine and have access to the compliance obligations related to its environmental aspects?

Does the organization determine how its compliance obligations apply to the organization?

Does the organization take its compliance obligations into account when establishing, implementing, maintaining and continually improving its environmental management system?

Does the organization maintain documented information of its compliance obligations?

“Legal and other requirements” shifted to “compliance obligations” Note: These compliance obligations can result in risks and opportunities to the organization.

Obligations may arise from: Mandatory requirements: applicable laws and regulations; Voluntary commitments: such as organizational and industry standards, contractual relationships, principles of good governance and community and ethical standards. Documented information could be a list or matrix of compliance obligations.

The enforceable legal requirements continue to be included under this section. The Orange County Environmental

Protection Division (EPD) continues to assist OCCC in meeting these requirements.

In addition, voluntary contractual obligations with vendors is considered a compliance obligation beyond legal requirements. Environmental Services meets with Event Managers before events to cover specific requirements including the requirements for recycling and other environmental objectives. Interviews with managers verified commitment to these contractual obligations as something as important as meeting external legal compliance obligations.

Orange County EPD has let the OCCC know that they are due for an audit before 2024. The latest compliance letter dated November 12, 2021 was submitted as evidence of this statement. However, Aimee Krivan from EPD has come on-site in 2022 to assist with OCCC’s hazardous waste compliance, and the EMR has been working with her regularly to enhance OCCC hazardous waste practices. They have had numerous meetings and email exchanges concerning Hazardous and Universal waste, our generator status, and containment methods. Although hazardous waste issues are largely outside the current fenceline, the EPD representative could easily inspect the

Environmental Services areas for compliance with the two regulatory issues they face: employee right-to-know chemicals used, and protection of stormwater from wastewaters generated by Environmental Services.

Historically, these issues were controlled.

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6 PLANNING

6.1.4 Risk associated with threats

and opportunities:

The organization shall determine the risk associated with threats and opportunities that needs to be addressed to:

• Give assurance that the environmental management system can achieve its intended outcome(s);

• Prevent, or reduce, undesired effects, including the potential for external environmental conditions to affect the organization;

• Achieve continual improvement.

Has the organization planned to:

Take actions to address these?

• Risks and opportunities,

• Significant environmental aspects and,

• Compliance obligations.

Integrate and implement the actions into its EMS processes or other business processes?

Evaluate the effectiveness of these actions?

When planning these actions, does the organization consider its technological options and its financial, operational and business requirements?

The standard requires a planned approach with respect to these actions, with the actions being integrated into the EMS or other business processes.

The actions planned may include: Establishing objectives;

Establishing new or improving existing controls; Establish or expand monitoring methods; Incorporating the action into an EMS process; etc.

This requirement is largely met by existing Objectives and Targets Procedure (renamed to eliminate the word

“Target”) EMS-SOP-3. The OCCC EMS Form used to document objectives has a section entitled “Actions Planned and Taken to Achieve Objective” that should suffice in meeting the 6.1 requirement.

The objectives set by the Core Team for 2022 are (1) Purchase and deploy outdoor waste bins; (2) create a location for recycling hub; 3) create a “dock recycling master” job description; and 4) create a long-term EMS vision-plan.

These objectives were noted as being discussed in the Core Team meetings in June 2022.

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6 PLANNING

6.2 Environmental objectives and

planning to achieve them

6.2.1 Environmental objectives:

Considering the risk associated with threats and opportunities.

Shall be communicated (consideration of the views of interested parties has been removed)

Has the organization established environmental objectives at relevant functions and levels?

Has the organization taken into account below issues when establishing environmental objectives?

• Significant environmental aspects,

• Compliance obligations associated with significant environmental aspects.

Does the organization consider its risks and opportunities when establishing environmental objectives?

Are the organization’s environmental objectives consistent with its environmental policy?

Are the environmental objectives measureable (if practicable)?

Does the organization monitor the environmental objectives?

Are the environmental objectives communicated?

Does the organization update the environmental objectives as appropriate?

Does the organization retain documented information on the environmental objectives?

ISO 14001:2015 is asking for a more robust management of objectives. Auditors need to know how to audit a set of interrelated objectives, ensuring that they are mutually consistent and that they are aligned with the strategic direction of the organization.

The existing process (EMS-SOP-3) used to identify objectives is used to meet the new standard, integrating new information (context, risks/opportunities, etc.) into the decision process.

The tasks for OCCC objectives set for 2022 were all completed. However, OCCC improved, but fell short of the overall waste diversion target. As explained to the OCCC participants, this auditor is not as concerned with the performance but rather the completion of the action plans as stated by the Core Team; since they followed the plan, OCCC is in conformance.

The Core Team has not yet discussed OTs for 2023.

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6 PLANNING

6.2 Environmental objectives and

planning to achieve them

6.2.2 Planning actions to achieve

environmental objectives:

How the results will be evaluated, including indicators for monitoring progress toward achievement of measurable objectives (see 9.1.1).

The organization shall consider how the actions to achieve environmental objectives are integrated into organization’s business processes.

Has the organization determined below information in its planning to achieve its environmental objectives?

• the activities that will be conducted;

• the required resources for those activities;

• the responsibilities of persons;

• the time frame for these activities to be completed;

• How the results will be evaluated?

For those measurable environmental objectives; what indicators will be used for monitoring progress?

Does the organization consider how the actions to achieve environmental objectives can be integrated into the organization’s business processes?

The organization must undertake planning in order to determine how its environmental objectives will be achieved. This planning includes determining the work required in order for the organization to realize its environmental objectives, the resources necessary to undertake this work, who will be responsible for ensuring that the work is done and when the work needs to be completed by.

Planning actions should meet “SMART” criteria to ensure that they can be monitored and measured.

The criteria specified in the new standard is included in the revised Form used to document actions taken to meet objectives (EMS-SOP-3). These criteria are outlined in Clause 6.2.2. This form will be used to document actions taken to achieve 2022-23 objectives as required under 6.2.2.

The form used to document the actions taken to achieve 2022 objectives and targets was used in conformance with the EMS procedure.

OCCC ISO 14001 REVIEW Page 18

7 SUPPORT

7.1 Resources:

The organization shall determine and provide the resources needed for the establishment, implementation, maintenance and continual improvement of the environmental management system.

Has the organization determined and provided the resources needed for the establishment, implementation, maintenance and continual improvement of the EMS?

Auditors should not merely look at the budget to check that some funding has been allocated to the EMS. They must dig deeper, checking if the organization has really identified all types of resources required and that it has taken action to ensure that those resources will be available when needed. Note: Not all resources are tangible.

The Resources needed for objectives are identified in the Objectives Form.

Resources needed to accomplish the EMS requirements are discussed by the Core Team and with Top

Management during the Facility Operations weekly meetings. In addition to improvements, the meetings address deficiencies in performance and the resources needed to repair, correct and maintain the equipment and assets required.

OCCC ISO 14001 REVIEW Page 19

7 SUPPORT

7.2 Competence:

Those assigned roles and responsibilities within the EMS shall be competence to fulfill these assignments.

How does the organization determine the necessary competence of person(s) doing work under its control that affect its environmental performance?

How does the organization ensure that persons doing the job are competent? What is the basis for their competency?

(appropriate education, training, or experience).

How does the organization determine training needs associated with its environmental aspects and it’s EMS?

How does the organization take actions to acquire the necessary competence, and evaluate the effectiveness of the actions taken

(where applicable)?

Has the organization retained appropriate documented information as evidence of competence?

Clause 7.2 is essentially a rewording of the text in the 2004 edition. However, the impact of the change is that competency evidence is now expanded to be necessary for persons that may affect the organization’s environmental performance.

If the people are found not to be competent, the organization is required to take action. The actions taken need to be evaluated for effectiveness in raising competence to the required level.

Section 5.4 of the existing Training Procedure (EMS-SOP-4) appears to address the competency requirements.

Other portions of the SOP address training from an awareness perspective where competency is not as critical.

Competence is achieved within Environmental Services through several employee training courses, including Right-

To-Know training (safety); Personal Protective Equipment; Spill Response; OCCC Environmental Management

System; and, training in specific work instructions for Building Services. Records were available documenting the training for competence.

In accordance with the recommendation from the 2019 audit, it appears that the Core Team (May 23, 2019 minutes) took steps in May 2019 to improve training, better answering the question of “Why” employees need to follow established procedures. This is evidence of the annual review of training as required by the EMS.

There have been no changes to training processes since the previous audit. Previous efforts are ongoing, although the external context has brought challenges in keeping employees with labor shortages prevalent in Orlando.

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7 SUPPORT

7.3 Awareness:

Persons doing work under the organization’s control shall be aware of:

• The environmental policy;

• The significant aspects and related actual or potential impacts associated with their work;

• Their contribution to the effectiveness of the environmental management system, including the benefits of enhanced performance;

• The implications of not conforming with the environmental management system including compliance obligations.

Are the persons doing work under the organization’s control aware of the organization’s environmental policy, any objectives that are relevant to them, how they are contributing to the effectiveness of the EMS and what the implications are of them not conforming to EMS requirements?

Auditors should seek the evidence that the required information has been communicated to relevant personnel (both internal and external). This will require appropriate interviewing to assess if adequate awareness is evident.

The important factor here is the addition of requirement to make people aware both of the organization’s EMS requirements as well as the consequences of non-conformance with the requirements.

All employees, even those outside the fenceline, should know of the OCCC Environmental Commitment Policy.

The nonconformance related to training in 2018 has been corrected as per the corrective action procedure.

Inspection of current training delivered by this department (TIPS) revealed that environmental policy and EMS awareness training is now given to new employees during orientation.

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7 SUPPORT

7.4 Communication

7.4.1 General:

The organization shall plan and implement a process for internal and external communications.

Does the organization plan and implement a process for internal and external communications relevant to the EMS, including on what it will communicate, when it will communicate, with whom it will communicate and how it will communicate?

Are compliance obligations considered in the organization’s communication planning process?

How does the organization ensure that the environmental information (and claims) it communicates is reliable and in line with the EMS?

What is the organization’s response process to relevant communications on its EMS?

Has the organization retained documented information as evidence of its communications, as appropriate?

Organizations need to develop and implement a process (i.e., communication strategy) to determine those EMS-related matters on which it wishes to communicate taking into account:

Compliance obligations; Quality (reliability and consistency) of the communicated information.

Communications may include an organization’s: Compliance to various obligations (agency reports); Milestone achievements.

OCCC has an existing procedure describing communications (EMS-SOP-5). Important things to communicate internally include the Policy, roles and responsibilities, milestone achievements, significant aspects and function-specific controls. External communications might include reports to agencies and the public.

The existing procedure has been updated to the new standard. An Environmental Communications Log has been developed to provide details on the various internal and external meetings used to communicate environmental issues. The log has proved to be very useful in providing evidence of the EMS being implemented within OCCC.

For 2022, the auditor confirmed evidence of internal and external EMS communications:

• Internal: Core Team Meetings, Facilities Operations meeting minutes;

• External: Facility Tours, and Post-Event Sustainability Reports.

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7.4 Communication

7.4.2 Internal communication:

Including changes to the environmental management system, as appropriate.

Ensure its communication process enable any person doing work under the organization's control to contribute to continual improvement.

Is there any process to communicate EMS related information (including updates and changes) to all functions and various levels of the organization?

Are the persons doing work under organization’s control able to contribute to the EMS and its continual improvement?

Internally, organizations have to communicate information relevant to the EMS amongst all levels and functions, including information on any change, as appropriate, and have to establish a mechanism to enable all persons performing work under the organization’s control to contribute to continual improvement.

7.4.3 External Communication:

The organization shall externally communicate info relevant to the environmental management system, as determined by its communication process and required by its compliance obligations.

Has the organization established a process to externally communicate information relevant to the EMS?

Externally, organizations have to communicate as required by their compliance obligations. Additionally, organizations may choose to communicate on other issues, as appropriate.

The existing EMS-SOP-5 has been modified to satisfy the above requirements.

Procedure has been established describing internal and external communications. Observed evidence that the procedure is being implemented (e.g., e-mails, Core Team meetings). The EMR also reported that she is involved in giving presentations at conferences.

The EMR is maintaining external EMS-related communications as referenced in the procedure. External communications occur through social media such as Twitter and Facebook.

One of the goals in 2022 has to do with communications: installing new compactor signage at loading docks to improve segregation of recyclables.

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7 SUPPORT

7.5 Documented Information

7.5.1 General:

Does the organization’s EMS include all documented information required by the ISO 14001:2015 standard, and the information determined by the organization itself as necessary for the effectiveness of the EMS?

The terms ‘documented procedure’ and ‘record’ used in ISO 14001: 2004 have both been replaced by the term ‘documented information’, which is defined as information required to be controlled and maintained by an organization, as well as the medium on which it is contained.

7.5.2 Creating and Updating:

When creating and updating documented information the organization shall ensure appropriate: identification and description (e.g. title, date, author, or reference number); format (e.g. language, software version, graphics) and media (e.g. paper, electronic);

review and approval for suitability and adequacy.

When creating and updating documented information, does the organization ensure that it is appropriately identified and described (e.g. title, date, author, reference number), in an appropriate format (e.g. language, software version, graphics) and on appropriate media (e.g. paper, electronic)?

Is the documented information being reviewed and approved for suitability and adequacy?

7.5.3 Control of Documented

Information:

Documented information required by the environmental management system and by this International Standard shall be controlled to ensure: it is available and suitable for use, where and when it is needed.

Is the above mentioned documented information (please see 7.5.1.) controlled in order to ensure that it is available where needed and that it is suitable for use?

Is it adequately protected against improper use, loss of integrity and loss of confidentiality?

For the control of documented information;

- Does the organization address distribution, access, retrieval and use of documented information?

- Is there a process for control of changes (version control), storage and preservation (including preservation of legibility), retention and disposition of documented information?

Observations/Evidence:

The processes used under the former 2004 standard are used to conform to the new standard as well. The format specified in OCCC’s document control procedure is being used. The controlled copy is that shown on the OCCC intranet. “Documentation” now includes both procedures and records. OCCC has retained the use of the term

“records”.

There has been no change in the keeping of records since the previous audit. The EMS Manual is continually kept current and revisions are still being logged. EcoPreserve is still assisting the OCCC with record keeping.

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8 OPERATION

8.1 Operational Planning and

Control:

The organization shall plan, implement and control the processes needed to meet environmental management system requirements, and to implement the actions determined in 6.1 and 6.2 consistent with a life cycle perspective.

Requirements are considered in the design process for the development, delivery, use and end‐of‐life treatment of its products and services.

In order to meet requirements of EMS and to address the issues determined in 6.1 and 6.2;

Does the organization plan, implement and control any processes?

Any criteria are established for the processes?

In accordance with the above criteria, are controls implemented on the processes, to prevent deviation from the environmental policy, environmental objectives and compliance obligations?

Does the organization control planned changes and review the consequences of unintended changes, taking action to mitigate any adverse effects, as necessary?

Has the organization ensured that outsourced processes are controlled or influenced?

Are the type and degree of control or influence to be applied to these processes are defined within the EMS?

To make the control processes consistent with a life cycle perspective, has the organization:

• determined environmental requirements for the procurement of products and services, as appropriate?

• established controls to ensure that environmental requirements are considered in the design process for the development, delivery, use and end-of-life treatment of its products and services, as appropriate?

• communicated relevant environmental requirement(s) to external providers, including contractors?

• considered the need to provide information about potential significant environmental impacts during the delivery of the products or services and during use and end-of-life treatment of the product?

Does the organization maintain documented information to the extent necessary to have confidence that the processes have been carried out as planned?

Controls can include engineering controls, procedures, documented…