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ISO 14001:2004 Environmental Management Systems Lead Auditor CourseInstructor Guide

STUDENT EXERCISES (Instructor Guide)

This document contains all the Exercises provided to students behind the Exercise Tab of
the Student Manual. However, comments specific to instructors are included in this
document in gray shaded boxes (like this one). Answers to the Exercises are also provided
in this document in gray shaded boxes. If answers are not provided for an Exercise, it is
because there is no right answer for the questions or tasks; in these and all other cases,
instructors should rely on their experiences as auditors to respond to student work.

This Tab contains the Student Exercises. The exercises were designed to provide students with an
opportunity to practice their third-party auditing skills. Some of the exercises are individual
exercises; others involve teamwork. Each exercise describes the purpose, directions, the allotted
time for completion, and the number of points that will count toward the continual evaluation.

Keep in mind; there may be more than one correct answer for an exercise. Try to identify the
strongest or most direct answer in each case, and be prepared to consider, defend, or rebuke
alternate answers raised during class discussions.

The case study concerns a fictitious organization, Automotive Electronics Group (AEG). This
organization developed an Environmental Management System and has sought registration to ISO
14001:2004. The AEG Environmental Manual and the organizations accompanying procedures
are located behind the Case Study Tab of the Student Manual and should be referenced to
complete the exercises involving the case study.

For purposes of this course, the 1st day of the audit to be planned for and conducted will be
June 5, 2007. All supporting dates in the Case Study documents and records will be
consistent with those recorded on them.

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ISO 14001:2004 Environmental Management Systems Lead Auditor CourseInstructor Guide

Contents

Exercise 1: Prerequisite Review.................................................................................3


Exercise 2: Reviewing Environmental Policy Statement............................................7
Exercise 3: Aspects, Impacts, Objectives, and Targets...........................................10
Exercise 4: Application of ISO 14001:2004.............................................................12
Exercise 5: Regulations............................................................................................18
Exercise 6: Creating an Audit Plan (for Stage 2 audit)............................................21
Exercise 7: Creating an Audit Checklist...................................................................24
Exercise 8: Conducting an Opening Meeting..........................................................26
Exercise 9: Auditing Scenarios................................................................................29
Exercise 10: Auditing the AEG Case Study...............................................................45
Exercise 11: Writing Nonconformity Statements........................................................53
Exercise 12: Conducting the Closing Meeting and Preparing the.............................57
Exercise 13: Reviewing Corrective Actions and Audit Follow Up..............................60
Exercise 14: Completing the Sample Exam...............................................................61

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ISO 14001:2004 Environmental Management Systems Lead Auditor CourseInstructor Guide

EXERCISE 1: PREREQUISITE REVIEW

Students should have this exercise completed when they enter class. Take 30 minutes to
review the chart, having students provide responses. Try to gauge their understanding of
the requirements and take note of areas in which they can try to improve throughout the
course.

This prerequisite exercise is designed to encourage students to review the ISO 14001:2004
standard before attending the ISO 14001:2004 Environmental Management System Lead Auditor
course. This exercise will be graded on the first day of the course and will count toward the overall
continual evaluation of students. 1

Students must bring this completed exercise and the accompanying copy of
ISO 14001:2004 to the course.

Time

30 minutes total

Continual Evaluation

5 points total

Directions

Review the ISO 14001:2004 standard

Answer the following questions and be prepared to submit this sheet to the instructor at the
appropriate time.

1
Students who successfully pass the EMS Lead Auditor course receive Certificates of Successful Completion. To
pass the course, students must achieve a 70% or higher on both the written exam and the continual evaluation. The
continual evaluation consists of the cumulative score of all course exercises, including this prerequisite exercise.

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1. What are the seven elements of the DO section of ISO 14001:2004?

4.4.1 Roles, Responsibilities, and Authorities

4.4.2 Competence, Training, and Awareness

4.4.3 Communication

4.4.4 Documentation

4.4.5 Control of documents

4.4.6 Operational control

4.4.7 Emergency preparedness and response

2. List 4 records specifically required by ISO 14001:2004 and provide the relevant clause.

4.5.1 Records of calibration and maintenance

4.5.2.1 Records of legal compliance evaluation

4.5.2.2 Records of other requirements compliance evaluation

4.6 Records of management review

3. According to ISO 14001:2004 who is required to have the environmental policy communicated to
them?

4.2f Persons working for or on behalf of the organization

4. As stated in ISO 14001:2004 what is the difference between a document and a record? What
is a relevant clause?

4.4.5 Records are a special type of document and shall be controlled in accordance with
the requirements given in 4.5.4.

The response may also be a reference clause 3.4 and 3.20

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5. What is evaluated for compliance according to ISO 14001:2004?

4.5.2.1 Compliance to legal requirements

4.5.2.2 Compliance to other requirements

6. According to ISO 14001:2004 what must audit procedures address?

4.5.5 the responsibilities and requirements for planning and conducting audits, reporting
results and retaining associated records, the determination of audit criteria, scope,
frequency and methods.

7. What does Clause 4.2 of ISO 14001:2004 correspond to in ISO 9001:2000?

Annex B, Table B1

5.1 Management commitment

5.3 Quality policy

8.5.1 Continual improvement

8. What are the Normative References for ISO 14001:2004?

There are none

9. What is required to be monitored and measured according to ISO 14001:2004?

4.5.1the key characteristics of its operations that can have a significant environmental
impact.

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ISO 14001:2004 Environmental Management Systems Lead Auditor CourseInstructor Guide

10. What are four inputs into the management review process and what is the relevant clause of
ISO 14001:2004?

4.6
a) results of internal audits and evaluations of compliance with
legal requirements and with other requirements to which the
organization subscribes

b) communication(s) from external interested parties, including complaints

c) the environmental performance of the organization

d) the extent to which objectives and targets have been met

e) status of corrective and preventive actions

f) follow-up actions from previous management reviews

g) changing circumstances, including developments in legal and other requirements related


to its environmental aspects

h) recommendations for improvement.

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EXERCISE 2: REVIEWING ENVIRONMENTAL POLICY STATEMENT

The instructor should have the students divide into small groups and review the
environmental policy for AEG. Have them compare the policy against the requirements of
clause 4.2 to determine if it meets the requirements of the standard.

Purpose

To audit for the required elements in an environmental policy as part of Stage 1 Document
Review Audit.

Time

20 minutes for team preparation


10 minutes for class discussion
30 minutes total

Continual Evaluation

5 points total

Directions

In your teams, read the environmental policy statement provided below for AEG from the
Case Study, and review it against the requirements contained in clause 4.2 of ISO14001:2004.

What does clause 4.2 require?

Where does the policy meet or fail to meet the requirements of clause 4.2?

Select a spokesperson from your group to make a report back to the class.

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AEG Environmental Policy Statement from Case Study

4.2.1 POLICY
AEG will be a global leader in environmental management. This is consistent with AEGs business
interests, ethics and Shared Values. We commit to improvement of our environmental performance.
We will measure progress and communicate results. Compliance with this policy is the
responsibility of every employee. Specifically, we commit to the following:
4.2.1.1 Sustainable Development
We will strive to conserve resources and reduce environmental effects and risks that may be
associated with our activities.

4.2.1.2 Employees and Others


We will ensure that our employees have the awareness, skills and knowledge to carry out this
policy and will encourage respect for the environment.

4.2.1.3 Compliance
We will meet all environmental laws and AEG environmental requirements, including our own
environmental management standards.

4.2.1.4 Business Integration


We will integrate environmental considerations into our business activities. .

4.2.1.5 Customers
We will work with our customers to help them address their environmental management and
improvement needs.

4.2.1.6 Suppliers and Contractors


We will work with our suppliers and contractors to enhance their own environmental performance.

4.2.1.7 Community and Government


We will participate in community and government environmental protection initiatives.

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Were Requirements Met in the


Requirements of 4.2
Organizations Policy?

Is appropriate to the nature,


Cant tell without more information on
scale, and environmental impacts of its
company, but all indications are yes.
activities, products, and services

4.2.1 Sentence #3, a commitment


Includes a commitment to continual
to improvement but not continual
improvement and prevention of
4.2.1.1 weak indication
pollution
reduce environmental effect

Includes a commitment to
4.2.1.3 Statement does not include
comply with applicable legal
applicable, it states all.
requirements and with out other
No reference to other except for
requirements to which the organization
AEG or to aspects
subscribes with relate to its aspects

Provides the framework for


4.2.1 Sentence #4, weak framework
setting and reviewing environmental
for objectives measure progress
objectives and targets

Is documented, implemented, and Cant tell without more information on


maintained company, but all indications are yes.

Is communicated to all persons working


Cannot tell at this time
for or on behalf of the organization

Is available to the public Cannot tell a this time

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ISO 14001:2004 Environmental Management Systems Lead Auditor CourseInstructor Guide

EXERCISE 3: ASPECTS, IMPACTS, OBJECTIVES, AND TARGETS

Have students break into small groups and review the AEG documents in the Case Study.
After reviewing their procedure for identifying aspects and impacts, have them determine if
the procedure meets the requirements of 14001, clause 4.3.1. Also have them review the
objective and target table in the case study and determine if it meets the requirements of
clause 4.3.3.

Purpose

To provide practice in auditing an organizations identified environmental aspects, impacts,


objectives, and targets as part of the Stage 1 Document Review Audit.

Time

30 minutes for team review


15 minutes for class discussion
45 minutes total

Continual Evaluation

5 points total

Directions

Read the introduction to the case study for Auto Electronics Group (AEG) behind the Case Study
Tab in the Student Manual.

Review AEGs procedure for Identification of Aspects and Impacts Procedure (ESH-002) and the
Objective and Target Table.

In your teams, review the procedure to identify aspects and impacts,


ESH-002, and determine if it meets the requirements of ISO 14001:2004, clause 4.3.1.

Also in your teams, review the table in which AEG identifies its objectives and targets
and determine if it meets the requirements for objectives and targets in ISO 14001:2004,
clause 4.3.3.

Select a spokesperson from your group to make a report back to the class on your findings.

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Exercise Workspace

Evaluating the aspects and impacts in comparison to the identification procedure, ESH-002,
AEG states they will keep up to date a register of impacts, but there is not one present in the
documentation. Aspects are listed in the Objectives and Targets Table, but are not clearly
logged with their associated impacts.

The Objectives and Targets Table in the case study meets the requirements of clause 4.3.3
of ISO 14001:2004. It documents objectives and targets, they are measurable, and they take
legal and other requirements into account.

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EXERCISE 4: APPLICATION OF ISO 14001:2004

This exercise will help students apply ISO 14001 to audit situations. This exercise is
intended to encourage students to think like an auditor. Students may identify more than
one answer for each question. However, suggested answers are provided below. Have
students perform all the scenarios and then compare the responses. Use a Round Robin
and discussion approach for this exercise.

Purpose

To give you practice applying the ISO 14001:2004 standard to audit scenarios.

Time

30 minutes for individual review


30 minutes for class discussion
60 minutes total

Continual Evaluation

5 points total

Directions

As individual auditors read the scenarios on the following pages.

For each scenario, cite the applicable clause(s) of ISO 14001:2004. If more than one applies, note
the strongest, most direct clause/sub-clause.

Determine for each scenario whether or not the requirements of ISO 14001:2004 have
been met.

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Scenario 1:

When asked how roles and responsibilities were defined, the Human Resources Manager said that
this was done through job descriptions. After reviewing the job descriptions, an auditor noted that
there were three levels of Water Treatment Operators: Operator I, II and III. The difference between
them was the years of service with the company. There was no mention of EMS responsibilities in
the job descriptions other than that the operators were to follow documented procedures where
they exist. Except for a small number of Managers and support personnel, everyone in the
organization was an operator. Through an active Empowerment Program, the operators were
responsible for all aspects of operations.

Applicable clause(s): 4.4.1 Resources, roles, responsibility and authority

Requirements met? No. At this point, it appears that managements expectations of the
employees, as they relate to the EMS, are not clear.

Scenario 2:

When reviewing the companys environmental policy statement, an auditor sees that one part of it
reads, To promote a company which understands and is comfortable with our environmental
performance and protects and supports our continued operations and expansion. When asked
how the company had made the policy statement available to the public, the Environmental
Manager replied that it was on a plaque on the wall in the main lobby. When asked what decisions
had been made regarding external communication of aspects she replied that they were uneasy
committing to full disclosure of all aspects but that they were generally receptive to community
inquiry. She said As a matter of fact, just
last week we hosted a tour by the third-grade science class from the local
grade school.

Applicable clause(s): 4.2 (g) Environmental Policy

Requirements met? All indications are yes, but further questioning would be in order.
Is the lobby is wide open and unlocked to the public? Has the
organization documented their decision on communicating their
significant environmental aspects?

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Scenario 3:

When asked how the company identified its environmental aspects, the Plant Manager said, At our
annual planning retreat the management team spends a couple of hours brainstorming a list of
ways that we affect the environment. Then we short-list the top five aspects, based on our
understanding of the severity of the possible impacts. We make these five the aspects around
which we will set targets and objectives for the year.

Applicable clause(s): 4.3.1 Environmental Aspects

Requirements met? More questions would be in order. Have they ensured their aspects
are taken into account in their operating procedures? Is there a
procedure for determining significant aspects? Does the
procedure say anything about a retreat process?

Scenario 4:

After being asked how he knew if he was in compliance with the applicable environmental laws
associated with the operations, the Department Manager replied, I follow the procedures that
include any regulatory requirements.

Applicable clause(s): 4.5.2 Evaluation of Compliance and


4.3.2 Legal and Other Requirements

Requirements met? Not yet. Questions to ask: How has the organization ensured
international, national, local, and company requirements are
audited? Is an auditor asking the right person the right questions?
Has the Department Manager been trained to the procedures he
references above? Is there a compliance audit report of which the
Department Manager may not be aware?

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Scenario 5:

While reviewing a log of external communications, an auditor noticed that there were regular
complaints from the operators of a retirement facility next door. The residents were disturbed by the
noise caused when the solid waste compactor turned on periodically, sometimes at night. On
checking the minutes of the last management review in which objectives and targets were
discussed, it was found that this issue had come up in previous reviews and the management team
had agreed that something should be done. The Plant Engineer had researched options and
reported that the best solution was to install an additional bin for holding waste before compacting
to accommodate the waste from the late shifts. This would cost approximately $90,000. On hearing
the cost estimate the management team shelved the plan until the next budget cycle. No
communication had been made to the operators of the retirement home.

Applicable clause(s): 4.4.3 (b) Communication

Requirements met? No. The procedure for responding to complaints needs to be


reviewed.

Scenario 6:

Upon visiting the wastewater treatment facility the auditor notices a binder labeled Permits and
sees a wastewater permit inside. The auditor then asks one of the technicians what his
understanding of the permit limitations are. The technician replies, I dont remember them exactly.
Thats why we have them in a book. You have the book you tell me.

Applicable clause(s): 4.3.2 Legal and other requirements and


4.4.2 Competence, training and awareness

Requirements met? Not yet. The auditor should be flexible and approach the question
from a different angle. It may be possible (although not likely) that
the operator doesnt need to know the permit limitations, but
maybe a manager does. Possibly, the operator may know and is
just not cooperating.

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Scenario 7:

In the receiving area, drains leading off the property are observed. Standard Operating Procedures
for the Receiving Department do not contain any actions that are to be taken with respect to the
drains in the case of a spill.

Applicable clause(s): 4.4.7 Emergency preparedness and response

Requirements met? No. The organization is required to maintain a procedure to


identify potential emergency situations or potential accidents that
could impact the environment. They do not have a spill plan for the
drains in these areas.

Scenario 8:

The Quality Manager was showing an auditor the new computer network that allowed the
organization to put all its procedural documents on-line. In the past, Document Control maintained
and used a spreadsheet on the network showing the current revision of each document so that
anyone could verify the current revision of his or her paper document. Now the documents
themselves were in the database. When people need a document they bring it up on-line. When
asked how one could tell what the current revision is, the QM replied, That the beauty of it only
the current documents are in the database. If its there, its current.

Later while checking back-up procedures, an auditor asked the Network Administrator about user
IDs. All employees have a user ID. Of course, for security reasons, we dont assign user IDs until
a person is appointed to a permanent position.

Applicable clause(s): 4.4.5 Control of Documents

Requirements met? Not sure yet. It is not yet clear that the documentation includes the
dates of revision. Questions to ask: How does the organization
ensure that temporary employees receive the
latest procedures? Does the online system actually work?

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ISO 14001:2004 Environmental Management Systems Lead Auditor CourseInstructor Guide

Scenario 9:

An auditor noted that the procedure for Emergency Response referenced the Hazardous Materials
Management Plan (HMMP) is contained in the environmental, safety, and health programs.

While reviewing the HMMP in the ESH programs, an auditor notices that the program is audited
using the Quality Management System Procedure. When asked if the audit findings were
incorporated into the EMS, the Quality Manager replied, No, that is part of the Quality System and
the two are kept separate.

Applicable clause(s): 4.5.5 Internal Audit

Requirements met? Not sure yet. Check the QMS internal audit procedure and/or audit
results. Integration of the EMS and QMS audit processes should be
encouraged where possible, as illustrated by
ISO 19011

Scenario 10:

When asking the Environmental Manager who is responsible for accessing and identifying
applicable environmental regulations to demonstrate how she would find out about the most current
CAA information, she replied I get that type of information from the corporate lawyer on a need to
know basis.

An auditor went on to question the corporate lawyer on how regulatory information was transferred
to other areas of the plant and to those responsible for meeting compliance requirements. The
lawyer said, I keep track of all permits, and it is not necessary for process management to know
this level of detail.

Applicable clause(s): 4.5.2 Evaluation of Compliance


4.3.2 Legal and Other Requirements

Requirements met? No. The auditor should determine what the procedure for
identifying and accessing legal and other requirements says. The
auditor might use an example of recent legal change and see how
the Environmental Manager was made aware of the change. Was
the Environmental Manager made aware of the change in a method
other than that described in the procedure?

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ISO 14001:2004 Environmental Management Systems Lead Auditor CourseInstructor Guide

EXERCISE 5: REGULATIONS

This exercise is to ensure active learning from the students and help them apply their
knowledge of regulatory vehicles and interpret regulatory information. The exercise asks
students to determine the meeting of a regulatory requirement by reviewing the operational
control designed to meet it in the AEG case study. They will need to go into the reference
section and quickly familiarize themselves with the piece of legislation.

Instructors should make the point that information about ISO 17021:2006 is included in
Module 8 of the Tab Text in the Student Manual. They should also draw the clear distinction
that while environmental technical competence is important for an EMS audit, EMS third-
party auditors do NOT conduct compliance audits. The instructor may also show students
some regulatory websites (e.g. EPA) by actually connecting to the web if possible.

After the students have had a chance to conduct a review for the first 30 minutes the
instructor should lead the class in a discussion for the final
30 minutes.

The instructor will need to grade each student for his or her level of participation in the
exercise and during the class discussion. There is no need for the instructor to grade each
students individual answers to the scenarios. Students can receive a maximum of 5 total
points for their participation, and the grade must be recorded on the Marking Matrix.

Purpose

To give you practice with reviewing a regulation applicable to an organization and the document
designed to meet it.

Time

30 minutes team review


30 minutes class discussion
60 minutes total

Continual Evaluation

5 points total

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Directions

Review the material provided behind the Reference Tab for 40CFR Part 112 OIL
POLLUTION PREVENTION.

Answer the following:


What is the evidence of the applicability of this regulation to an environmental aspect
of AEG?

What AEG document is intended to meet the requirement of this regulation?

Identify 8 things in the AEG document that provide evidence of meeting the
regulatory requirement.

(Note: Remember, you are not looking at compliance to the law, you are looking for
conformance to a requirement of an Operational Control and conformance to 4.4.6)

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Exercise Workspace

Inventories in Spill Plan provide evidence of oil in storage greater than 1320 gallons and
AEG is located on the Arnold River and West River.

AEG Livonia Site Spill Plan, SP-100, Issue 3, 06-30-04

1. Documented spill plan


2. Layout and facility diagram
3. Types of oils described on the inventory sheets
4. Emergency contact numbers provided
5. Training requirements (8.0)
6. Inspections and Testing (9.0)
7. Response planning
8. Spill sources identified (6.0)

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EXERCISE 6: CREATING AN AUDIT PLAN (FOR STAGE 2 AUDIT)

In this exercise, students will write an audit plan using ISO 19011:2002 and the AEG Case
Study.

For our purposes we will consider exercises #2, #3 & #5 as being the Stage 1 or Document
Review portion of the registration audit. Regardless of any identified deviation the decision
has been made to go forward with the Stage 2 portion of the audit

Try to offer as much critique on the plans for the students benefit as possible. Take 15
minutes to discuss the basics of writing a successful audit plan and offer a critique of the
classs audit plans as a whole.

Purpose

To provide practice in creating an audit plan based on ISO 19011:2002.

Time

30 minutes individual work


15 minutes small group work
15 minutes class discussion
60 minutes total

Continual Evaluation

5 points total

Directions

Review the AEG case study.

Determine the necessary number of audit days for your team to perform the Stage 2 Registration
Audit for the AEG Livonia site using the tool provided behind the Reference Tab. Note: For
purposes of this class the Stage 1 Document Review took 2 audit days

Using the guidelines from ISO 19011:2002, clause 6.4.1, create an audit plan for the Stage 2
Registration Audit at the AEG Livonia site.

Review your plan with your team. Choose one to present to the class.

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Sample Audit Schedule/Plan

Client: ABC Company Report Number: 123456

Management Standard: Team Leader: TL

ISO 14001:2004 Team Members:

Opening Meeting Date/Time: MM/DD/YYYY


Client Representative:
800AM
Management Rep
Closing Meeting Date/Time: MM/DD/YYYY

1200PM

Audit Objectives: Stage 2 Implementation to: We


maintain
ISO 14001:2004 requirements strict

Audit Scope:
EMS, organizational policies and procedures
governing the manufacture,
confidentiality concerning all information gained from undertaking its business
(A copy of the assessor confidentiality statement is available on request). This audit is to be
conducted in English.

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ISO 14001:2004 Environmental Management Systems Lead Auditor CourseInstructor Guide

Date Time Assessor Process/Area


Day 1 8:00 TL Opening Meeting
8:30 TL External area review
9:30 TL Stage 1 Nonconformance Clear-down
EMS Policy; Aspects ; Objectives and Targets
Environmental Programs; Monitoring &
Measuring
12:00 Working Lunch
1:00 TL Legal & Other requirements; Evaluation of
Compliance
Emergency Preparedness & Response
5:00 TL Daily Out brief
Day 2 8:00 TL Training; Internal Audit; Corrective/Preventive
Actions
10:30 TL
Air Management ; Water Management
12:00 Working Lunch

1:00 TL
Waste Management (Solid, Hazardous,

Recycling)

Energy Management; Chemical Management


2:30 TL
Manufacturing/Warehousing Operations
Plant Maintenance
5:00 Daily Out brief

Day 3 8:30 TL Top management / Management Review


10:00 Audit trail follow-up /Report Preparation

12:00 TL Closing Meeting

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ISO 14001:2004 Environmental Management Systems Lead Auditor CourseInstructor Guide

EXERCISE 7: CREATING AN AUDIT CHECKLIST

In this exercise, students will use the audit plans they created in Exercise 6 to create
checklists for the AEG audit. The instructor will assign each student a department, process
or function of AEG or an ISO 14001:2004 clause they were assigned to audit from the audit
plans that were prepared.

Students will then prepare a checklist based on their assigned department, process,
function, or clause. The tutor will then select a member of each team present their checklist
to the entire class while other class members critique the work. At the end all checklists will
be turned in to the tutor for evaluation.

There is no specific solution provided for this exercise. Instructors should use their
knowledge of ISO 19011:2002 and auditing techniques to evaluation students checklists.

Purpose

To give you practice developing audit checklists.

Time

40 minutes individual work


20 minutes class discussion
60 minutes total

Continual Evaluation

5 points total

Directions

Using the audit plans from the previous exercise develop a checklist that would enable you to
conduct an effective audit.

The instructor will assign each student a department, process or function of AEG or an
ISO 14001:2004 clause they were assigned to audit from the audit plans that were prepared within
their team.

Students will then prepare a checklist based on their assigned department, process, function,
or clause.

The tutor will then select a member of each team to present their checklist to the entire class while
other class members critique the work.

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All checklist will be turned in to the tutor for evaluation and comment at the end of the exercise

Tip: Structure the checklist around the following:

What is the requirement?


What will you look at to assess conformance with the requirement?
What evidence will you look for to prove conformance?
What sample size should you use?

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EXERCISE 8: CONDUCTING AN OPENING MEETING

No specific answers are provided for this Exercise; however, guidance is provided for the
instructor on the subsequent pages. For this exercise, the instructor and students should
be ready to role-play.

Purpose

To give you practice conducting an opening meeting for an environmental audit.

Time

15 minutes small group preparation


45 minutes small group presentations
15 minutes class discussion
75 minutes total

Continual Evaluation

5 points

Directions

This is a team exercise. Each team will need to select an Audit Team
Leader. Using your audit plan from Exercise 6, develop an agenda for an opening meeting.

An opening meeting presentation will be made to company management about the upcoming audit
to ISO 14001:2004. Each group will have the opportunity to present their audit plans, and each
team member will be required to explain the auditor assignments. In other words, each auditor
must explain his or her assigned departments, assigned processes, and the scheduled time
periods in which they will conduct the audit. Additionally, each auditor must explain what will be
expected of the auditees during their phases of the audit.

During the opening meeting, the instructor and students who are not participating will serve as the
management team for AEG. When not presenting, students should make notes on the effective
aspects of the other groups' presentations. Students should also note how the other groups could
improve their performances. The student critiques will serve as the basis for a 15-minute class
discussion and debrief after all the presentations are complete.

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While playing the role of AEG management during the opening meeting, the instructor may
wish to ask questions of the students or make key statements to expose them to situations
that commonly occur during an opening meeting. Possible questions or statements include:

"Due to a lot of internal audit results and subsequent problems found, could we ask for
that department/process to be removed from the audit plan? The time gained could be
spent in other departments."
"Due to a lack of storage room, some of our records may not be available. In fact, weve
shipped most of our records offsite to a storage facility. Sometimes it can take a few
days to retrieve the records from the storage facility because we have to free up
someone's time here to go find the records over there. If you need a record and its
offsite, we will be happy to mail a copy over to your office within a few days, if that's ok.
We would prefer not to waste anytime during the audit by digging through the storage
facility."
"We understand you have a lot of ground to cover during the audit, so we've taken the
liberty of providing samples of records for you in each department. We've also asked all
of our best employees to be available for interviewing to ensure you get the information
you need."
"I'm sorry, but the managers from our Inspection and Testing Department and the
Production Department will not be available for you to interview. They scheduled their
vacations before the audit was scheduled."
"We've made reservations for us to eat at a fine restaurant in town, so we may need to
increase the time allotted for lunch on the schedule if that's ok with you."
"Would you like to start the audit with a plant tour? We expect it to only take about 90
minutes."
"Would you like to view our company video to get a better sense for our operations and
how we meet customer expectations?"
"I'm sure you will find things to be in top shape. In fact, our ISO 9001:2000 auditors
always cut the audit short in the past because they've been so impressed with our
operations. We would be happy to show you previous audit results so you won't need to
spend so much time in each department."
"Our guides won't be available during the night shift, so can you remove that from the
audit plan?"

Instructors may pose other questions or use other statements, as long as they meet the
courses learning objectives. As this is the first time some students will have come in
contact with a role-play scenario, the Managers for AEG should bear this in mind.

Note: If your class size is such that you require four teams, consider having two teams
present to the other two teams to save time. Wait until the two auditee teams are ready
for the meeting before changing their assignments (for full benefit of the preparation). Then
give each group of "auditees" different questions or statements outlined above to ensure
the role-play is effective.
As outlined in clause 6.5.1 of ISO 19011:2002, possible opening meeting topics may include:

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Introductions/roles/attendance
Sampling/disclaimer
Communication channels
Objectives/scope/criteria
Logistics/guides
Conditions for audit terminations
Documentation status
Audit methods
Possible outcomes
Audit Plan confirmation
Appeal system
Closing/interim meetings
Assignments
Acknowledgements
Classifications of findings
Language of the audit
Confidentiality
Clarifications
Audit progress
Restrictions
Thanks

At the end of the exercise, the opening meeting role play should be evaluated on a scale of
1-5 and scores for each student entered into the Marking Matrix.

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EXERCISE 9: AUDITING SCENARIOS

The instructor will assign each student 1 to 4 of the scenarios on the following pages.
Students will then read their assigned scenarios and determine if there is enough
information to issue a nonconformity. After the students have finished analyzing their
scenarios and writing the appropriate information in the space provided below the scenario
in the student manual, have each student present their assigned audit scenarios to the class
with their NC statement and their ideas for further questioning. Try to assign each student
with at least one scenario that results in a nonconformity and one that does not.

The Tutor should challenge the findings of the students for adequacy or existence of
evidence and appropriateness of requirement. Test their tenacity and get them away from
the I think to I know this is a nonconformance.

The purpose of this exercise is to expose students to as many different audit scenarios as
possible. Each scenario aims at a specific topic or situation auditor might face, for example,
one scenario encroaches on integration and how to discuss environmental issues with your
quality management interviewee. Additionally, there are scenarios that allow an auditor to
deal with obstinate interviewees. Other scenarios enable the instructor to illustrate the
distinction between ensuring the auditee is complying with environmental law, and auditing
the auditee for compliance, keeping in mind the fact that EMS auditors do NOT conduct
compliance audits.

Purpose

To give you practice conducting audit interviews, preparing questions, and following audit trails.

Time

15 minutes individual work


60 minutes class discussion
75 minutes total

Continual Evaluation

5 points total

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Directions

The instructor will assign you one to four of the following scenarios.

Read the scenario(s) assigned to you and determine if there is enough information to issue a
nonconformity. If you can show there is a nonconformity provide the most applicable clause of ISO
14001 and the evidence. If you do not believe there is a nonconformity then state the following and
be sure to include (develop an audit trail):

Actions you would take next and whom you would interview
Questions you would ask and how you would ask them (Prepare about 3 to 5 questions)
Applicable element(s) of the ISO 14001 standard for the scenario
Objective evidence you would look at and look for to assess conformance to
the requirement(s)

Be prepared to discuss your scenario(s) and recommendations with the class.

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Auditing Scenarios:

1. Youre interviewing an employee who is responsible for operating one of the scrubbers. You
notice he records air emission monitoring information on a log sheet as required by his
operating procedure. You examine the log sheet and notice that it doesnt have any limits. You
ask the employee if he knows the limits and he responds, I just read the gauge and record the
results on the log sheet per my procedure. I guess someone else worries about the limits.

Nonconformity: Not yet

Applicable Clause: N/A

The auditor needs to determine if this particular air emission monitoring is tied to a
significant impact. If so, clause 4.5.1 requires a procedure(s) to monitor and measure the
key characteristic(s) of the operation that can result in the significant impact as such, the
auditor needs to look for a procedure. The organization must record information to:

Track performance,
Track operational controls, and
Track conformance with objectives and targets.

Also, if this air emission is tied to a significant impact, clause 4.4.6 requires that there are
adequate operational controls in place to ensure that this air emission doesnt go out-of-
control. Sometimes this means that the organization needs documented procedures that
stipulate operating criteria including, limits or thresholds. As such, an auditor needs to
review the documented procedure that the operator is using to determine if the limits are
defined. The operator may also be telling the truth.

If the procedures define the limits, but the operator just doesnt know them than there may
be an issue pertaining to 4.4.2 awareness.

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2. You ask a marketing specialist in the Marketing and Sales department about the EMS policy at
AEG. She replies, Our department doesnt pollute, Im not sure if that stuff really applies to us.
Further conversation with the employee reveals that she joined AEG three weeks ago.

Nonconformity: Not yet

Applicable Clause: N/A

The auditor needs to determine what sort of orientation training new-hires receive. How is
the environmental policy communicated to new employees (4.2.f) and how are new
employees made aware of importance of conforming to the environmental policy,
procedures and requirements of the companys EMS (4.4.2)?

3. Youre watching a waste treatment operator take pH measurements at one of the outfalls adjacent
to a river near the AEG manufacturing facility. The operator has the latest procedure with him and
appears to be doing everything according to the procedure. You notice that the procedure
requires three measurements and the results are to be recorded on form FM-009. The form that
the operator is using only has two columns for measurement data. As such, the operator pencils
in another column and records the third measurement.

Nonconformity: Not yet

Applicable Clause: 4.4.5

The auditor needs to determine:

1. Is there a more recent version of the form that has three columns?
2. If so, how is it made available to operators?
3. If, for example, the form is available online, does the operator have access to it (i.e., Does
the employee have access to a computer? Does the employee know how to access the
computer? Does the employee know how to access the form on the computer?)

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4. While reviewing specific environmental training curriculum in the Training


department, you notice that the training package for scrubber operations contains change
request forms from the ESH department notifying the Training department about regulatory
changes that need to be incorporated into the training curriculum.

Nonconformity: Not yet

Applicable Clause: N/A

The auditor needs to determine when the change request forms were submitted and their
effective dates. Also need to determine the process/procedure for controlling changes to
training curriculum. The organization may have defined how and when changes are to be
incorporated. Need to see if the organization if following its own process/procedure. If
these changes have exceeded their effective dates, there may be a nonconformity against
clause 4.4.5 (c). This type of nonconformity leads to downstream problems, including
possible nonconformities relating to:

4.4.2 Training, awareness and competence


4.4.6 Operational controls
4.2(c) Commitment to comply with legal and other requirements

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5. Youre interviewing a supervisor in the wafer area about a new etching process that has been
incorporated to increase production rate while also reducing environmental waste by 12%.
While stepping through the process, you notice that page two of the applicable work
instruction contains a few handwritten redline changes with the same initial by each of the
changes. When asked, the supervisor says that those are his initials and that he made the
changes to enhance (fine-tune) the process.

Nonconformity: Not yet

Applicable Clause: N/A

The auditor needs to determine if this new etching process has been proofed and finalized
(base-lined). If the process is still being proofed, what is the redline process and who is
authorized to redline? If the new etching process has been proofed and finalized, what is
the process for making and controlling changes to the work instruction? Is the supervisor
authorized to make these changes? If not, this may be a nonconformity against 4.4.5 (b).
Note: This may be a major nonconformity if it can be proven that unauthorized redline
changes are normal occurrences or if there are actual or potential environmental non-
compliances as a result of these unauthorized changes.

6. While interviewing the Quality Assurance manager about the EMS corrective and preventive
action process at AEG, you notice that the database used to track nonconformities only contains
EMS audit results. When asked about this, the Quality Assurance manager replied, I
developed the database to track quality-related nonconformities. When ISO 14001 was
implemented at AEG, the environmental folks wanted to use the same database. I agreed to
input their findings into my database so we wouldnt have to maintain two separate systems.
The only nonconformities Ive received from them so far are their audit results.

Nonconformity: Not yet

Applicable Clause: N/A

The auditor needs to find out how and where other (non-audit) environmental
nonconformities are tracked review the organizations procedure/process for handling and
investigating nonconformities. If it is determined that there is no process for handling and
investigating other nonconformities, there would be a nonconformity against 4.5.2.

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7. While interviewing a hazardous waste handler, you ask her what ISO 14001 means to her, and
she states, Im so focused on making sure that I follow my procedures that Im not really sure
about ISO 14001. Weve had several compliance problems in the past and management is
really driving 100% compliance at ALL times or else. We really dont have time for all the
other extras around here. I cant afford to lose my job as a result of a compliance issue.

Nonconformity: Not yet

Applicable Clause: Possibly 4.4.2

A truly successful and sustainable EMS relies on employee awareness and involvement.
Understanding the EMS requirements will allow employees and the company to achieve
compliance. Clause 4.4.2 was established to help organizations achieve this. The
organization could have implemented an EMS and never mentioned ISO 14001 in any
training. More research is required.

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8. While walking through the hazardous waste storage area, you notice a few 55-gallon drums are
not properly sealed and each of them contained waste product. You also noticed what
appeared to be waste oil or solvent on the top lid of some of these drums and the ground
around some of these drums was soiled. You remember that air emissions was considered to
be a significant aspect at AEG. You go to the ESH department to find out who performs
compliance evaluations and the ESH representative states, Our department does all of the
compliance evaluations and reviews and the Q.A. department takes care of the EMS audits.

Nonconformity: Not yet

Applicable Clause: N/A

The auditor needs to find out if the compliance evaluations include a review of the
hazardous waste storage area specifically the legal requirements associated with
handling, storing and maintaining drums to prevent air emissions and spills (4.5.2 & 4.3.2).
If the compliance reviews include the hazardous waste storage area, when was the last
evaluation? Was this adverse condition discovered during the last compliance evaluation?
If so, what was done to correct and prevent this condition? If nothing was done to correct
this condition, there would be a major nonconformity against 4.5.3 for not taking
appropriate corrective action. If something was done, but the corrective action was not
effective, there may be a minor nonconformity against 4.5.3 for not taking action to
mitigate the impact. Also, since this condition is tied to a significant aspect, the auditor
needs to determine what operational controls have been put in place to control the handling,
storage and maintenance of drums (4.4.6). Also, if operational controls have been
established, the auditor needs to determine if employees are aware of these controls and
have received the appropriate training (4.4.2) and if they have access to these controls, if
required (4.4.5).

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9. While reviewing the process for identifying aspects, you notice the ESH department has created
a list of aspects and associated impacts for the activities at the Livonia facility. However, the list
does not include products or services provided by the Livonia facility.

Nonconformity: Yes

Applicable Clause: 4.3.1

Clause 4.3.1 requires that an organization have a procedure(s) for identifying aspects
associated with its products, services and activities. The auditor needs to review this
procedure(s) for the Livonia facility. If the Livonia facility has a procedure(s) for identifying
aspects, the auditor needs to determine if it includes products and services. If it doesnt,
there would be a nonconformity against 4.3.1. If it does, then the organization didnt follow
its own procedure(s). Note: The type and quantity of products and services may help an
auditor decide between major and minor.

10. The Livonia facility identified significant aspects associated with scrubber operations. While
reviewing their scrubber procedures, you notice a specific requirement to check the manometer
on the side of the scrubber once a day to ensure adequate filter operations. You examine the
manometer and notice there is no evidence of calibration.

Nonconformity: Not yet

Applicable Clause: N/A

Although there is no evidence of calibration on the manometer, the auditor needs to


determine if the manometer has been calibrated. Need to look for calibration records. If the
manometer has not been calibrated, this would be a nonconformity against 4.5.1. If the
manometer has been calibrated, the auditor needs to review the organizations calibration
procedures to determine if the manometer requires some sort of calibration identification. If
so, there would be a nonconformity against their own calibration procedure.

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11. While reviewing management review records, you notice the last management review was
conducted two weeks ago. The record shows that internal and external audit results were
presented during the review, which included two Notices-of-Violation issued by the state
environmental protection agency and 86 internal audit findings.

Nonconformity: Not yet

Applicable Clause: N/A

The auditor needs to determine the management review intervals and look for evidence that
the management reviews are conducted per their specified interval (4.6). Also, need to
review the records for at least the last two management reviews to determine what
information is being presented to top management during the management reviews. Top
management needs more than audit results to determine if the EMS continues to be suitable,
adequate and effective. Remember: The quantity of audit nonconformities is not an
accurate indicator of the adequacy, suitability and effectiveness of an EMS. Additionally
there may be an issue if CA/PA under 4.5.3 is not being taken for the NOVs.

12. One of the objectives and targets at the Livonia facility is to, reduce air emissions from
scrubber operations by 20% by the end of the year. You ask the Environmental Management
Representative (EMR) to review the environmental management program (EMP) put in place to
achieve this objective and target. The EMR attempts to show you the online version of the EMP
but cant access it because the server is temporarily out of service. The EMR states that this
sort of thing occasionally occurs, but he printed a copy of the EMP last night just in case
something like this happened.

Nonconformity: Not yet

Applicable Clause: N/A

Discretion must be used in these cases. Clause 4.4.5 requires that documents be available
at all locations where essential operations are being performed. A common rule of thumb is
to move on as long as the online documents can be accessed and reviewed before the end
of the audit. Need to review the organizations document control procedure to determine
what is required during these situations. The auditor may want to probe a bit to determine
how often this occurs and why this may be a resource issue (i.e., inadequate server
capacity, software discrepancies, etc.) 4.4.1

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13. While reviewing the internal audit procedure with the Director of Quality, you notice there is a
requirement to create the annual schedule and audit plan during January of each year. You ask
about the criteria used to determine what is to be audited each year and the Director replies,
Weve decided to integrate the quality and environmental management system audits. So, now
we include EMS every time we do a QMS audit.

Nonconformity: Not yet

Applicable Clause: N/A

Clause 4.5.5 requires that audit program and schedules be based on the environmental
importance of the activity concerned and the results of previous audits. Although its a
good idea to integrate EMS and QMS audits as much as possible, its important to consider
these criteria to ensure the proper allocation of resources to the audit process. The auditor
needs to determine if this criteria was used or did the Director just make a blanket decision
to EMS audits during QMS audits. If EMS audits are conducted only during QMS audits,
theres a risk that certain areas or processes are not audited.

14. You ask the environmental engineer who is responsible for environmental compliance
evaluations at the Livonia facility. She replies, We normally dont do formal compliance
evaluations. Thats something the Corporate ESH group does when they come down.

Nonconformity: Not yet

Applicable Clause: N/A

The auditor needs to review the organizations documented procedure for conducting
compliance evaluations to determine if it specifies Corporate ESH to conduct these
evaluations. If there is no documented procedure, there is a nonconformity against 4.5.2.
Also, need to determine what is reviewed and how often. Need to determine if the Corporate
ESH group evaluates compliance to legal requirements associated with the organizations
environmental aspects.

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15. The Livonia facility has identified spills in the hazardous storage area as one of several
significant aspects. You ask the supervisor of the hazardous storage area about operational
controls pertaining to this significant aspect and the supervisor replies, I just follow the
procedures that have been created by my predecessors predecessor.

Nonconformity: Not yet

Applicable Clause: Possibly 4.4.2

The auditor needs to sample a few activities in the hazardous waste storage area to
determine if the associated operational controls are current and adequate (4.4.6). Also, if
some of these operational controls are documented, the auditor should ask to review the
organizations document control procedure to determine if the operational control procedure
is periodically reviewed, revised (as necessary) and approved by authorized personnel
(4.4.5). The supervisor needs to know his role and responsibilities in conformance with
procedures (i.e., its not good enough to know about the existence of procedures also
understand why its important to conform with the procedures (4.4.2 (c) and (d))

16. While interviewing the H.R. and ESH Director, you ask to see how the Livonia facility
documents relevant inquiries from external parties. The director shows you the communication
log used to document incoming calls from external parties. While reviewing the log, you
remember that you called the Livonia facility two weeks prior to your visit and asked about the
air emission hazards associated with their wafer manufacturing operations.

Nonconformity: Not yet

Applicable Clause: N/A

The auditor needs to ask about the inquiry he presented two weeks ago. Who received it?
Is it documented? Who worked or is working on it? Who responded or is preparing the
response? If these questions cannot be answered, this would be a nonconformity against
4.4.3 (b).

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17. While reviewing the environmental records retention schedule, you notice that calibration
records for devices used to monitor and measure key environmental characteristics are to be
kept for two years in the Q.A. office. You also notice that the Livonia facility has a policy to
archive environmental records at an offsite storage facility if the records are to be kept for
longer than two years.

Nonconformity: No

Applicable Clause: N/A

The auditor needs to review the organizations records control procedure. Also, need to test
the records retrieval process to determine if records can be readily retrieved. Ask for a
sample of records to test the retrieval process and to assess the condition of the records
are they received in a timely manner and is there evidence that they are properly stored and
maintained? If time permits, the auditor may choose to visit the offsite facility.

Note: An auditor must use discretion when assessing timely retrieval. Retrieval time is
typically defined in an organizations records control procedure. If the retrieval time is not
clearly defined, the auditors rule of thumb is to allow for receipt of a record before the end
of the audit.

18. While interviewing a forklift operator in the hazardous waste storage area, you ask him about
the environmental policy and about his roles and responsibilities to achieve conformance with
the policy and associated procedures. He explains what he does as a forklift operator and the
type of training he has received to do his job. You ask him about specific activities that may
impact the environment and what would happen to the environment if he didnt follow his
procedures. He replies, Im not sure what would happen to the environment, but I know the
internal auditors would probably have a field day with me if I didnt have my procedures stapled
to my forehead.

Nonconformity: Yes

Applicable Clause: 4.4.2 (d)

Clause 4.4.2 (d) requires that the forklift operator understand the potential consequences of
departure from his procedures. Also, the auditor may explore the operators knowledge of
emergency procedures in the event of a spill.

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19. While in the shipping and receiving area, you notice there are several 5-gallon containers of
hazardous chemicals on pallets that have just been received. The employees in the area
appear to be properly handling the chemicals and are being cautious. You ask one of the
operators what they would do in the event of an accidental spill with one or more of the 5-gallon
containers and she replies, I would try not to let my boss know about it by cleaning it up as
soon as possible. We have kitty litter, brooms and shovels in that closet over there to clean up
any mess. My boss runs a tight ship.

Nonconformity: Not yet

Applicable Clause: N/A

Obviously, the employee is worried about retribution and the auditor must respect this by
not revealing names. The auditor needs to assess the employees knowledge of the clean
up process to determine if it conforms to the organizations emergency response
procedures (4.4.2 (c) and 4.4.7). If the clean up process conforms to the applicable
procedures, the auditor needs to determine how and when (if necessary) emergency
procedures are supposed to be reviewed and revised after an accident or emergency (4.4.7).

20. The boiler room at AEG Livonia has been undergoing substantial renovations for fifteen months.
As a result of these renovations, bulk chemical storage has been displaced. Drums and other
containment vessels have been placed around equipment and in aisles. There is no secondary
containment for the chemicals and no inventory management is taking place. The Plant
Manager defends the situation saying it is only temporary. Renovations are expected to
continue for another six months.

Nonconformity: Yes

Applicable Clause: 4.3.1

Change or modification has not initiated aspects identification process, therefore potential
significant aspect has not been evaluated or identified [4.4.6(a) is secondary element for
nonconformance].

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21. An Internal Audit at AEG identified a puddle with an oil sheen outside the facility which
appeared to have originated from an air compressor blow-down pipe. Corrective Action to this
nonconformance was documented as follows:

A walk around the outside of the facility was added to the weekly housekeeping
inspection.
The environmental effect of releasing oil from the facility was added to the agenda at the
weekly shift meeting and employees were reminded that it is everyone's responsibility to
watch for and report leaks or spills.
Condensation from the compressor is now piped through an oil water separator prior to
discharge.
The discharge is tested every quarter to ensure oil water separator effectiveness.

The nonconformance was closed.

Nonconformity: Yes

Applicable Clause: 4.5.3

Corrective action does not include spill clean up (mitigation).

22. Upon inspection of old site plans for AEG Livonia, the auditor discovers that there was an
underground storage tank in an area that has since been paved over and made into a parking
lot. There is currently no visual evidence of the tank and there are no records of its removal.
No one interviewed has any knowledge of the situation.

Nonconformity: Not yet

Applicable Clause: Possibly 4.3.1 or 4.3.2

Missed a potential significant aspect or regulatory requirement related to USTs.

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23. During the audit of AEG Livonia, while interviewing an operator, the auditor noticed that an
out of date version of the emergency spill plan was found at his work station. The operator
explained that he was given the plan during his initial training session and has kept it for
reference.

Nonconformity: Not yet

Applicable Clause: Possibly 4.4.5 (d)

Obsolete document not removed or suitably identified.


Also need to see if the plan is referenced for use in an emergency .
Does operator have access to current plan?

24. During a documentation review, the auditor reviewed the structure and responsibilities of the
organization. She noted that the EHS Manager was identified as the management
representative. However, during the audit the auditor realized that the EHS Manager had
delegated all responsibilities regarding the EMS to a recently designated EHS Coordinator and
does not participate in the EMS.

Nonconformity: Yes

Applicable Clause: 4.4.1

Roles and responsibilities not clearly defined and documented.

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ISO 14001:2004 Environmental Management Systems Lead Auditor CourseInstructor Guide

EXERCISE 10: AUDITING THE AEG CASE STUDY

For this exercise, the instructor and students should be ready to role-play. The role-play is
central to the success of this course and must take place. Instructors and students must
improvise and think on their feet to ensure the success of this exercise.

In this exercise, each student will role-play a mini-interview as the auditor. On the following
pages are 10 interview scenarios for a third-party audit at AEG Livonia. Each student should
be assigned as the auditor for at least one scenario if possible (you should be able to role-
play all 10 scenarios in the allotted time). Instructors are encouraged to develop their own
characters if they wish to add to the course.

For this exercise, you should find a packet of scenario preparation handouts that have been
printed and mailed with the Student Manuals. To conduct the role-play, you will need to pull
out these handouts (a master copy is located behind the Exercises Tab of the Instructor
Manual).

You will also need to assign students to the roles of the auditees. For example, Scenario 1:
The Management Review Process has two auditees, so you will need to choose two
students to play these roles. Give the handouts to the auditees 65 minutes before the role-
playing the scenarios to prepare and ask questions (you may adjust the amount of
preparation time as needed).

The student role-playing the auditor should not see the handouts for that specific scenario.
The only information the auditors should see regarding their scenarios is provided in the
directions for this exercise in their Student Manual. The handouts give the auditees specific
instructions on which documents they will need to use from the Case Study throughout the
audit, as well as directions on how to act and, in some cases, what to say. If the other
students act like real auditees, the learning experience will be significantly better for the
student acting as the auditor.

The instructor may act as the auditee for the first scenario to warm the students up. Each
audit scenario should last approximately 25 minutes. Give the students ten minutes in
between role-plays to prepare.

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The instructor may wish to position one table in the front of the class for the auditor and
auditees to sit at, so the entire class can watch the role-play. Extra name tents should be
provided along with the handouts. If the instructor wishes, they may write the names of all
the auditees on the name tents and place them on the front table so everyone can see the
names and titles of the characters while the audits are taking place.

The participants in the AEG case study are:

George Aspen President


Mark Profit Plant Manager
Bill Jones Facilities Manager
Hugh Trent Quality Director
Bob Blood Electroplating Supervisor
Sally Johnson Environmental Management Representative
Earl Campbell Oiler
Meg Ransom ESH/Safety Coordinator
Bubba Material Handler
Susie Smartt Training Manager

All the role-plays have nonconformances that are likely to be uncovered during the
scenarios. However, if they are not uncovered during the scenario, the instructor may
debrief the class on any nonconformances that were missed by the auditor. The instructor
should wait until after the scenario is complete before giving any nonconformances away.
On the following pages, potential nonconformances that may be identified during the
scenarios are described (the nonconformance descriptions are not included in the student
manuals). Students are likely to identify additional nonconformities depending on how the
role-plays are executed.

While the role-plays are occurring, ask the students to pay attention to all elements of
auditor behavior, as described in ISO 19011:2002. Students not participating in the audit
should take thorough notes, especially on any nonconformances they identify.

After each role-play is complete, the instructor should lead a discussion about any
nonconformities that were detected for about 30 minutes. Write these nonconformities on a
whiteboard/flipchart in the classroom so students will have notes to use in subsequent
exercises.

After all the audits are complete, the instructor should lead a discussion about the audits as
a whole and how to audit effectively. You may begin this discussion by asking the students
to vocalize what tactics taken by the auditors during the role-plays were particularly well
done or effective.

Any strongly negative feedback on a specific students performances during the role-play
should be given to the student privately and in a professional and diplomatic manner. You
should encourage the students to have fun during the role-play and become engaged in the
characters they are asked to assume.

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NOTE: DEPENDING ON THE PATH THE AUDITS TAKES FOR EACH SCENARIO, STUDENTS
MAY FIND ADDITIONAL NONCONFORMITIES NOT DESCRIBED IN THE INSTRUCTOR
MANUAL. INSTRUCTORS MUST BE WILLING TO ADAPT TO AND PAY ATTENTION TO THE
PATH EACH SCENARIO TAKES AS IT IS ROLE-PLAYED.

Purpose

To simulate an audit situation using interview techniques, role-plays, and the AEG case study.

Time

60 minutes preparation for both auditees and auditors


180 minutes for role-plays for each of the 10 scenarios
(roughly 20 minutes per role-play)
60 minutes for class discussion debriefs for each of the 10 scenarios
300 minutes total

Continual Evaluation

10 points for participation as auditor in the role-play


10 points for participation as auditee in the role-play
10 points for participation in class discussion debriefs for each of the 10 scenarios
30 points total

Directions

For this exercise, you will rely on the AEG Corporation case study material provided behind the
Case Study Tab of the Student Manual. Ten scenarios have been developed to help you perform a
simulated audit of AEG. Students in the course will serve as both the auditees and auditors for
each scenario.

Before the scenarios begin, you will be given 60 minutes to prepare for your roles as auditor and/or
auditee. Read through all the materials behind the Case Study Tab of the Student Manual and
make note of any nonconformities that you identify in the documents. When serving as the auditor,
you may wish to ask the auditee about any of the nonconformities
you identify.

When it is not your turn to act as auditor or auditee, you should take thorough notes on any
nonconformances they can identify. Listen carefully to the auditors interview questions and the
responses from the auditees. After each audit scenario, the instructor will take 10 minutes to lead a
class discussion on the nonconformities (or lack of nonconformities) observed during the audit
scenario. Take close notes during these discussions, as the identified nonconformities will be used
in Exercise 11.

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Note: Nonconformities found in Exercise 10 will be used in upcoming exercises, so make sure you
take excellent notes!

Directions for Auditees

The instructor will assign you and other students in the class to play the roles of the following AEG
employees:

George Aspen President


Mark Profit Plant Manager
Bill Jones Facilities Manager
Hugh Trent Quality Director
Bob Blood Electroplating Supervisor
Sally Johnson Environmental Management Representative
Earl Campbell Oiler
Meg Ransom ESH/Safety Coordinator
Bubba Material Handler
Susie Smartt Training Manager

For different scenarios, the instructor may assign different students to role-play the same AEG
employee. To help you "get into character," the instructor will hand out scenario preparation sheets
that will help you assume the different roles for each of the auditees. In some scenarios, you may
need to provide specific documents to the auditor; the scenario preparation sheets will tell you
which documents to show the auditor from the AEG case study. Dont be afraid to immerse yourself
in your role as an auditee!

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Directions for Auditors

The instructor will also assign the roles of the various auditors for each
scenario. Depending on class size, you may be asked to serve as the auditor more than once.

Auditors will need to plan the questions they will ask the auditees (developing a checklist may
help), but you should also be alert while auditing in case you come across any potential audit trails.
You should be prepared for auditees to avoid answering some of your questions when he/she is in
character. Just as in real audit situations, the auditee may not be cooperative. Remember: this is
supposed to simulate a real audit, and in real audits the auditor cannot prepare for every
contingency or situation that can occur. You should ask, when necessary, to see specific AEG
documents, procedures, and records. If the auditee cannot provide you with the necessary
documents, this may be a further audit trail for you to examine. In other words, prepare thoroughly
within the given time, but you will still need to think on your feet!

Scenario Preparation for Auditors

The following ten scenarios are all based on the Auto Electronics Group Case Study materials.
The instructor and/or students will take the role of the auditee and the student will take the role of
the auditor for the scenario to which they were assigned. Students will interview the auditee based
on the area under review.

Scenario 1: Auditing the Management Review Process

Auditee: Plant Manager


Auditee: President

Preparation Documents: Management Review Procedure (MP-001)


Management Review Minutes (dated 6/28/2004)
EMS Performance Metrics

Potential Nonconformance: Management is not on target with NRG reduction, Metrics are
out of date. Meeting minutes do not clearly show what they are doing about the
nonconformities to get back on track.

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Scenario 2: Auditing the Aspect and Impact Identification Process

Auditee: Facilities Manager

Preparation Documents: Aspect & Impact Identification Procedure


(ESH-002)
AEG Objective and Targets Table
Environmental Management Programs

Potential Nonconformance: Metal stamping and Electroplating operations are not on the
table. Several items from the site map are not on the table. As an observation, students
may find the aspect and impact identification process is not well done.

Scenario 3: Auditing the Corrective Action Process

Auditee: Quality Manager

Preparation Documents: Corrective Action Procedure (ESH-010)


Copies of the nonconformities written in
Stage 1audit

Potential Nonconformance: The preventive action for NCR #2 is not adequate. AEG should
in fact take a comprehensive view of its operations to determine if other processes with
adverse impacts are on the table.

Scenario 4: Auditing the Operational Control Process

Auditee: Electroplating Supervisor

Preparation Documents: AEG Spill Plan (SP-100)


Aspect & Impact Identification Procedure
(ESH-002)

Potential Nonconformance: There are objectives and targets in Electroplating but the
Supervisor is not aware of them, nor is he aware of any operational controls to support their
initiatives.

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Scenario 5: Auditing the Compliance Audit Process

Auditee: Environmental Management Representative

Preparation Documents: Environmental Audit Procedure (ESH-005)


Internal Audit Report
Management Review Minutes (dated 6/28/2004)
CFC Management Policy (ESH-006)
Open Burning Policy (ESH-008)
PCB Management Policy (ESH-009)
Asbestos Management Policy (ESH-011)
Thompson Environmental Engineering Email
Air-Conditioning System Service Report

Potential Nonconformance: The Corrective and Preventive Action and permit exceedance
problems are major issues. This nonconformance for permit exceedance could also be
raised against External Communication.

Scenario 6: Auditing Legal Requirements

Auditee: Environmental Management Representative

Preparation Documents: AEG Spill Plan (SP-100)


Objectives and Targets Table
EMS Performance Metrics
Thompson Environmental Engineering Email

Potential Nonconformance: Copies of the Air Permit, the NPDES Permit, and the Stormwater
Discharge Permit cannot be provided to the auditor. A further audit trails may be to discuss
this with Thompson Environmental. The auditor should actively request to speak to
Thompson Environmental representatives.

Scenario 7: Auditing the Environmental Management Program for Achieving Objectives and
Targets

Auditee: Oiler in the metal stamping department

Preparation Documents: AEG Spill Plan (SP-100)


Aspect & Impact Identification Procedure
(ESH-002)
Objectives and Targets Table
EMS Performance Metrics

Potential Nonconformance: There are targets for oil reclamation increase and total use to be
reduced. However, there is a lack of awareness or training for the Oiler of these targets.
Also, the manager responsible for Stamping does not have familiarity with the EMP that

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directly impacts
her department.

Scenario 8: Auditing the Emergency Response Procedure

Auditee: ESH/Safety Coordinator

Preparation Documents: Emergency Response Procedure (ESH-003)

Potential Nonconformance: A minor nonconformity could be issued due to the lack of an


incident report.

Scenario 9: Auditing the Chemical Control Process

Auditee: Material Handler

Preparation Documents: Site Map


Spill Plan (SP-100)
Transportation of Dangerous Goods Policy (ESH-007)
Management of Non-Hazardous Waste Policy
(ESH-004)

Potential Nonconformance: The potential for deviation from procedures could be a minor
nonconformity.

Scenario 10: Auditing the Training and Awareness Process

Auditee: Training Manager

Preparation Documents: Training Needs Analysis Procedure (TR-002)


Training Needs Email
Email to supervisors and foreman
Training Record Log

Potential Nonconformance: A minor nonconformity could be raised since temporary and


other employees have not received awareness training. The organization is required to
conduct awareness training for the masses. At a Stage 2 audit they have not conducted
training and if the workers are very unaware at the time of the audit, this must be raised as a
nonconformity.

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EXERCISE 11: WRITING NONCONFORMITY STATEMENTS

No specific answers are provided for this Exercise, as the answers may vary for each group
depending on the outcome of the role-plays.

After students have spent 45 minutes preparing their nonconformity reports in their groups,
give each group roughly 10 minutes each to explain their nonconformity reports to the class.
When not presenting, the other groups should critique the presenting groups reports.
Encourage the groups to constructively evaluate each others work as you serve as the
conversation moderator and facilitator.

If you have left over time after all the presentations, you may fill out additional
nonconformity reports as a class based on observed nonconformities in the AEG case study
that were not already written up by the groups.

NOTE: See Case Study for examples of completed NCRs.

Purpose

To give you practice writing nonconformity statements.

Time

45 minutes team preparation


30 minutes team presentation
75 minutes total

Continual Evaluation

5 points total

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Directions

This is a group exercise based on the case study audit. Students should break up into groups of
three. The instructor will assign each group one of the nonconformities observed during the audit
role-play in Exercise 10, Auditing the AEG Case Study. After discussing the observed
nonconformity, the groups must prepare and write a nonconformity report (NCR).

The NCR should be written on forms provided and in a manner consistent with the methods taught
(Nonconformity report forms are found after the exercise directions below). After 30 minutes of
preparation time, the team will select a NCR for presentation to the entire class.

After each presentation, the instructor will lead a class discussion on the effectiveness of the
NCRs.

Note: The results of this exercise make up part of the Exercise 12, Closing Meeting and Audit
Report. Each student may be required to deliver (present) one or more nonconformity statements
from the case study during the closing report meeting.

Nonconformity reports will be reviewed by the class and instructor against the following criteria:

Correctly identifying a nonconformity


Describing clearly the nature of the nonconformity
Inclusion of pertinent objective evidence
Citing of applicable quality requirement(s)

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Exercise Workspace

Nonconformance Report #EMS-NCR,


Issue 1

AUDIT NONCONFORMITY REPORT

Organization: ___________________________ Incident Number: ______

Area under Review: __________________ ISO 14001:2004 Clause Number: ________

Category: MAJOR MINOR


Requirement:

Nonconformity/Evidence:

Auditor: ________________ Auditee: ________________

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Exercise Workspace

Nonconformance Report #EMS-NCR,


Issue 1

AUDIT NONCONFORMITY REPORT

Organization: ___________________________ Incident Number: ______

Area under Review: ______________ISO 14001:2004 Clause Number: ______

Category: MAJOR MINOR


Requirement:

Nonconformity/Evidence:

Auditor: ________________ Auditee: ________________

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EXERCISE 12: CONDUCTING THE CLOSING MEETING AND PREPARING THE


AUDIT REPORT

No specific answers are provided for this Exercise, as the answers may vary for each group
depending on the outcome of the role-plays.

After students have spent 60 minutes preparing their final audit reports in their groups, give
each group roughly 10 minutes each to conduct a closing meeting. You may need to tailor
the time each group spends on the closing meeting to ensure each group receives an equal
time. All of the closing meetings combined should not exceed 45 minutes.

You will play the role of top management during the closing meetings. You may also ask
other students to sit in as additional auditees during the meetings.

After each closing meeting, take a few minutes to discuss with the class the strengths and
weaknesses of the reports and the meeting. Encourage the groups to constructively
evaluate each others work as you serve as the conversation moderator and facilitator.

If you have left over time after all the presentations, reiterate the importance of an effective
closing meeting.

Purpose

To gain an understanding of the audit reporting and closing meeting processes.

Time

60 minutes preparation
45 minutes for closing meeting presentations
15 minutes class discussion and debrief
120 minutes total

Continual Evaluation

5 points

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Directions

Each team is to prepare an audit summary report and present it during a closing meeting to
management of AEG (played by the instructor). The written summary report will be presented to
AEG top management during a closing meeting (the instructor will serve as the AEG top
management representative during the role-play).

The report must address all the relevant topics covered in the course slides for audit reporting, as
well as meet the requirements of clause 6.6.1, ISO 19011:2002. It may be completed on the form
provided with additional pages for detail or explanation as needed (the audit report form is located
in this section after the exercise directions below).

The audit team leader is responsible for planning, conducting, and controlling the meeting, which
should meet the requirements of clause 6.5.7, ISO 19011:2002. Contributions of each team
member should be decided as part of meeting planning. Each team member is to present (at least)
one nonconformity and come to an understanding with the auditee management on the issue and
corrective action responsibility. The team leader is to sum up and conclude the meeting.

Note: the duration of each closing meeting may need to be determined by the number of groups
and students in the class.

Remember, the purpose of an audit is to verify conformity with requirements; do not neglect to
include this in the report, as well as the nonconformities. Make sure the audit summary report
and presentation include the nonconformity you worked on in Exercise 11 as well as other
nonconformities observed during the role-plays.

The student and the team will be reviewed against the following criteria:

Content and accuracy of the written audit summary report


Contribution of each member to the preparation work
For the team leader, a clear, logical presentation of the audit summary, effective dealing
with manager concerns and a summation/closure
For team members, a NCR presented clearly, logically, and effectively dealing with
manager concerns, and reaching an understanding on corrective action
responsibility/timing
For all members, effectively supporting the team efforts during the meeting

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Exercise Workspace

AUDIT SUMMARY REPORT

Report Number: ___________ Date: ___________

Process(es) Audited: ______________________________________________________________

Date of Audit: _________

Scope of Audit: __________________________________________________________________

Audit Objective: __________________________________________________________________

Audit Criteria (standard/procedure/project etc): _________________________________________

Auditor(s): ______________________________________________________________________

Summary of findings:

__________________________________________________________________________________________
__________________________________________________________________________________________
__________________________________________________________________________________________
__________________________________________________________________________________________
__________________________________________________________________________________________
__________________________________________________________________________________________
__________________________________________________________________________________________
__________________________________________________________________________________________
__________________________________________________________________________________________
__________________________________________________________________________________________
__________________________________________________________________________________________

NCR Reference Numbers:


__________________________________________________________________________________________
__________________________________________________________________________________________

Report Prepared by: ____________________________ Date: ___________

Report Approved by: ____________________________ Date: ___________


Company Representative

Distribution: _____________________________

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EXERCISE 13: REVIEWING CORRECTIVE ACTIONS AND AUDIT FOLLOW UP

Have the students split up into their teams. Have each team take the role of the auditee for a
moment. Have them create a corrective action plan for one of the nonconformities identified
in the audit report from Exercise 12.

Once the students have developed a corrective action plan, have them quickly present their
plan to another team. Then each team will evaluate the effectiveness of the corrective action
plan presented to them, and develop an audit trail for the next visit to check the
implementation of the plan.

Purpose

To help you gain an understanding of the corrective action and audit follow-up processes.

Time

45 minutes group corrective action plan preparation


30 minutes group evaluation corrective action of plan
75 minutes total

Continual Evaluation

5 points

Directions

Break into teams and act as the auditee for the beginning of this exercise. Based on the audit plan
developed in Exercise 12 and the NCs from the AEG case study, develop a corrective action plan
for one of the nonconformities.

You will then present your plan to another group, and you will have a plan presented to you. As a
team of auditors, determine if the corrective action plan presented to you would be effective when
implemented.

Also, develop an audit trail you would use during a follow-up visit to determine if the corrective
action plan was effectively implemented.

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EXERCISE 14: COMPLETING THE SAMPLE EXAM

The instructor should preface the sample exam with all the same directions as the real 2
hour exam. Two hours will be allotted for students to complete the sample exam. Then lead
the students in a review of the exam.

Purpose

To give you practice taking the EMS Lead Auditor Exam.

Time

120 minutes for exam completion


60 minutes class discussion and debrief
180 minutes total

Continual Evaluation

5 points for completion


5 points for class discussion
10 points total

Directions

Complete the sample exam on the following pages.


Solutions then will be covered in class.

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