Summary of an Environmental, Health & Safety Management System (EHSMS) in the Recycli

I wanted to create a post to help make recyclers aware of the components associated with a certified environmental, health and safety management system (EHSMS). It may be time consuming to first implement, but from the summary that you will see below, it is not a complicated system. In another post I’ll discuss the benefits of an EHSMS and how everyone should give it strong consideration.
There are many environmental, health and safety standards that you could chose to be certified to. In the recycling industry, the most common certifications are ISO 14001 (environmental standard), OHSAS 18001 (health and safety standard), RIOS (combined Quality + EHS standard), Responsible Recycling (R2) and e-Stewards. A certified EHSMS is a prerequisite for R2 and e-Stewards, which have additional downstream and data security requirements.
In my experience, RIOS (Recycling Industry Operating Standard) has two great benefits: it’s a combined standard that contains quality components, and it is one of the easier standards to implement. For this reason, I would recommend RIOS for recyclers that have limited resources that can be used for the implementation and maintenance of a QEHSMS. When picking a standard to be certified to, an important decision point is your customer’s requirements and end goal (for example e-Stewards does not recognize RIOS as a prerequisite).
For the purpose of understanding what a QEHSMS entails, I will provide a brief summary of the requirements of RIOS. To learn more about RIOS you can start at their official site: http://www.certifymerecycling.org/.

1.1 Scope and Application

• The QEHSMS must be written.
  
• Define what is within or outside the control of your QEHSMS.
  
• Create a process map showing how the QEHSMS elements interact with your process.

1.2.1 Management Structure
- Who is responsible for your QEHSMS?
1.2.2 Resources and Facilities
- Are your employees, machinery and workspace in line with your QEHS?
1.2.3 Document and Record Keeping Controls
- Most current procedures and forms are available to your employees
- Records are stored and readily retrievable
2.0 Policy
- The top document that should provide guidance to the QEHS decisions and actions the company engages in.
3.1.1 Important Environmental Aspects and Health & Safety Risks
- List the potential environmental impacts that could occur due to your processes/products
- List the health and safety risks that could occur due to your processes/products
- Rank the EHS impacts/risks based on potential size of impact and frequency
3.1.2 Legal, Product, and Other Relevant Requirements
- Identify and have access to legal, product and customer requirements.
3.2 Improvement Planning
- Create QEHS goals based off of significant EHS risks. Make them measurable and assign responsibility in achieving them.
4.1 Training
- Employees understand their roles and responsibilities associated with the QEHSMS.
- Employees are aware of EHS risks and controls associated with their jobs.
4.2 Communication
- Internal communication including employees understand the status of the QEHSMS.
- Customer communication including tracking requirements, customer feedback and complaints.
- Purchasing and QEHS requirements communicated to suppliers and contractors
- Receiving, documenting and responding to QEHS communications from external interested parties.
4.3 Operational Controls
- Establish processes and written procedures to ensure that activities are performed in a controlled manner (especially significant EHS risks).
- Downstream customers are qualified to receive product (in sync with your QEHS policy and goals).
- Qualify suppliers and ensure raw materials from suppliers meet requirements.
- Contractors adhere to QEHS requirements
4.4 Emergency Preparedness
- Create a plan to mitigate and respond to EHS incidents, accidents and emergency situations. Routinely test the plan for adequacy.
5.1 Monitoring and Measurement
- Monitor QEHS performance, achievement of goals, and product conformity.
- Supplier qualification and verification of raw materials
- Compliance to EHS legal and other requirements
- Maintenance and calibration of monitoring equipment
5.2 Nonconformance and Preventative Action
- Investigate cause, ensure action to address nonconformance, prevent repetition and review effectiveness of corrective action.
- Product that does not conform to requirements is identified and controlled to prevent unintended use.
5.3 EHS Management System Audits
- Periodically evaluate the QEHS Management System performance to RIOS
5.4 Management Review
- Senior management reviews the QEH&S management system to ensure its adequacy and effectiveness.

As stated prior, this is a summary of RIOS and does not list all of the details for being in compliance to RIOS. Please contact me if you have questions on the benefits of an EHS Management System, questions about EHS standards or tips on being in compliance. Note that my schedule is up and down so be patient if I do not respond quickly. I plan for my next article to be focused on the benefits of an EHS Management System and the benefits of certification.

Be Safe,

Russell Ballard
Seed to Sequoia EHS Consulting