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Re: EMS question

At 11:06 AM 6/7/99 -0500, you wrote:
>I think that Mark has hit a key point.  About 10 years ago, I was selected
>jointly by a plant and a community group to conduct a pollution
>prevention -- waste minimization audit of a large, old refinery that was
>undergoing extensive modernization.  As the neutral, third party, my job was
>to call it like I saw it.  I had carte blanche from both the company and the
>group, in terms of what I saw, who I got to question, and what I reported as
>a result.  
>Ralph E. Cooper, Ph.D., J.D.

I have  been involved in more than 50 cases involving similar scenarios -
many with Settlement Agreements from citizens suits.  Some of the companies
were pushing their "self assessments" under the Pollution Prevention Code
of Responsible Care.  They had given themselves high grades.  The
inspection using the backup CMA information gave them lower scores.  They
reacted negatively to the review until you could show them how the
conclusions were reached.  In every case they made the changes.
Checklists, scoring sheets, and ISO 14001 documentation-keeping routines
become just that - ROUTINES.  P2 programs need to be alive, not routine.
ISO 14001 need continuous improvement and "the prevention of pollution."
Most developers of ISO 14001 restrict being alive to the "soon to be dead"
policy statement.  As P2 providers, we need to see that it is addressed by
every person in the company every day.  ISO 9000 was recently modified to
strengthen the continuous improvement requirements.  I understand that the
TC for ISS 14001 will vote down a similar change at their meeting in Seoul,
Korea.  This would be a shame.  This indicates why third party credibility
is needed even when an ISO certification team is involved.


Dr. Robert B. Pojasek 
Pojasek & Associates 
P.O. Box 1333 
E. Arlington, MA 02474-0071
(781) 641-2422 
(617) 788-0288 (FAX)