Energy Management System Standards Reply

For those of you who are still eagerly awaiting the release of  the ISO 50001 energy management system standard (due to be released early next year), there is a British Standard, BS EN 16001, that can be used now.  This British energy management system standard has been a key priority for European delegates contributing to the development of the ISO standard in the much slower international standards setting arena.  These delegates are working closely with ISO to make sure there will be no disincentive for the early adopters of EN 16001 when ISO 50001 is released.  The use of this standard is also providing some information to those writing the ISO 50001 standard. 

The aim of this European standard is to help organizations establish the systems and processes necessary to improve energy performance and make reductions in both cost and emissions of greenhouse gases.  Launched in July 2009, this standard effectively presents a business with a roadmap of the various steps to be taken to ensure it is viewed as being serious about energy management.  The promotion of the standard notes that the combination of energy reduction and risk management is more financially advantageous than merely buying additional carbon credits or offsets to lower the carbon emissions that are reported to the public. 

The standard helps businesses ask the right questions of themselves and adjust their internal processes and decision-making accordingly.  These businesses use the plan-do-check-act (PDCA) framework to establish objectives and processes, implement some changes, monitor their results and finally act again to deliver incremental improvements in performance over time.  Some companies in the UK are required to certify to this standard because of the “Carbon Reduction Commitment Energy Efficiency Scheme” that was launched in April 2010 to support attempts to reduce the greenhouse gas emissions in accordance with the Climate Change Act of 2008.  There are similar requirements in the European Union.

To keep up to the demand in the United States, the US Department of Energy is making draft copies of ISO 50001 available to certain technical assistance providers to use for their own energy conservation programs.  However, no climate change legislation has been enacted in the United States.  A company can purchase a draft of ISO 50001 and use it while the final standard is being subject to its final international ballot.  You do not need to be involved in these Department of Energy projects to do so.

It is important to note that the “aspects” determination in ISO 14001 was designed for looking at all resources:  water, energy and materials.  Energy is very important to all companies and their stakeholders.  Unless you find that you need to certify to an energy management standard, you may be better off looking at both the BS EN 16001 and the draft ISO 50001 and using the information to strengthen your existing ISO 14001 program.

ISO 26000:2010 (Social Responsibility Guidance) Released 1

The ISO 26000:2010 social responsibility guidelines have been finalized and published.  It is now possible to add social responsibility “core subjects” from this new standard to an ISO 14001:2004 or ISO 9001:2008 program.  This would create an integrated sustainability management standard.  ISO 26000:2010 cannot be used alone as a sustainability management system.

CAPACCIO likes this standard since it clearly articulates a wide range of social responsibility issues that sustainable companies need to watch closely; e.g., community involvement, human rights, labor issues, and consumer/customer issues.  Incorporating conformance to social issues within a management system will help coordinate those who manage the environmental responsibilities with those that manage the social responsibilities.

A recent survey found that 86% of employees are not engaged by their employers on sustainability even though the same amount – 86% – said that their organization promotes employee sustainability.  It is possible to engage employees more effectively using a management system rather than relying on only on training and awareness.  A properly implemented management system can make sustainability part of what every employee does every day by including it in the work instructions and every aspect of their involvement with the organization.  CAPACCIO is already seeing this make a difference with our clients that are integrating their sustainability efforts directly with their sustainability efforts.  The new ISO 26000:2010 standard will make this effort easier and more effective.

CAPACCIO is preparing a “white paper” on how to use ISO 26000:2010 with your management systems.  Please reserve a copy by contacting Bob Pojasek at rpojasek@capaccio.com or calling him – 508-970-0033 Ext. 137.

Massachusetts Contingency Plan – Requirements for Chemical Releases to the Air Reply

As we are more than half-way through 2010, it is a good time to review requirements relating to chemical releases to the air from the Massachusetts Department of Environmental Protection (MassDEP) Massachusetts Contingency Plan (MCP) perspective.  As opposed to releases to soil or water, reporting of releases to air is often unclear or overlooked.  This is typically because, due to the nature of an air release, the highest priority becomes coordinating and conducting the necessary rapid remedial response. 

Most chemical releases to the air require MassDEP notification as soon as possible, but not more than 2 hours after obtaining knowledge that the release or threat of release meets one or more of the following:

  • A sudden, continuous or intermittent release or a threat of release to the environment of a hazardous material when:
    • the quantity of the release is or is likely to be equal to or greater than the applicable Reportable Quantity, and
    • it is likely that the release occurred within any period of 24 consecutive hours or less
  • A threat of release to the environment of a hazardous material when:
    • a release or threat of release of a hazardous material, in any quantity or concentration, that poses or could pose an Imminent Hazard
  • A release to the environment which results in the presence of hazardous material vapors within buildings, structures, or underground utility conduits at a concentration equal to or greater than 10% of the Lower Explosive Limit
  • A release to the environment of reactive or explosive hazardous material which threatens human health or safety
  • A release to a roadway that endangers public safety
  • A release to the environment that poses a significant risk to human health when present for even a short period of time
  • A release to the environment which produces readily apparent effects to human health, including respiratory distress or dermal irritation.

The MCP does allow for a delay in notification if one of the following extenuating circumstances can be established by a preponderance of evidence in which case notification must be made as soon as possible:

  • A lack of reasonably-available communication equipment at the site of the release or threat of release
  • A need to take actions prior to notification in order to mitigate or prevent an Imminent Hazard and/or threat to public safety, and/or
  • physical injury to the person responsible for notifying caused by or associated with the release or threat of release, when the injury reasonably prevents that person from notifying

In recent years, the MassDEP has been placing a priority on issuing penalties for violations for failure to notify in a timely manner.  The MassDEP does have a provision for retracting a release notification within 60 days if it is determined that the released amount is below the applicable MassDEP Reportable Quantity.  Therefore, in order to avoid a violation, it is better to report a release of unknown quantity than delay notification until the released quantity is confirmed.

For more information please call Dawn Horter (508) 970-0033 ext. 118 or email dhorter@capaccio.com.

Separating Energy Management from Environmental Management 1

Voting on a draft Energy Management System (ISO/DIS 5001) came to an end on August 26, 2010. The project committee (ISO/PC 242) will seek to resolve comments and issue the final standard by mid-2011. Companies will be able to seek certification to this standard or use it to self-declare their energy management system. It is interesting to note that this energy management system will NOT be part of the widely used ISO 14000 (EMS) series. The separation of this management system standard was supported by ANSI and Georgia Tech. They teamed up in the past to write ANSI MSE 2000 – the predecessor to ISO 50001. More…