Despite Its Y2K Origin, ISO 14001 Paid Big Dividends

y2kIn preparing for Y2K, consider environmental impacts. By combining the ISO 14001 internal auditing with corrective and preventive action program elements, management review, and other supporting elements, potential Y2K problems can be effectively managed.

Have you considered the environmental consequences of not being Y2K compliant? The EPA is advising companies to take this concern very seriously. The ISO 14001 Environmental Management System (EMS) Standard is a good way to manage all types of changes that could potentially impact the environment, including abnormal operations resulting from Year 2000 (Y2K) problems. Organizations using ISO 14001 should consider potential Y2K environmental issues in identifying and evaluating environmental aspects and impacts, and setting appropriate objectives and targets.

The Standard also requires that corrective and preventive action is taken to eliminate the causes of actual and potential nonconformance. This includes potential nonconformance caused by Y2K problems. By combining the ISO 14001 internal auditing and corrective and preventive action program elements, along with management review and other supporting elements, potential Y2K problems can be effectively managed.

What is EPA’s Y2K Enforcement Policy?

The EPA announced a Y2K Enforcement Policy late last year designed to encourage prompt testing of equipment to ensure compliance with environmental laws. Under this policy, penalties that may apply as a result of Y2K testing will be waived provided that all policy criteria are met including prompt notification to EPA. This policy will apply to all test-related violations disclosed to EPA by February 1, 2000; http://www.epa.gov/year2000.flnalpol.htm.

With the above exception, violations after January 1, 2000, will be subject to the Agency’s full enforcement response and penalty policies. You should be aware, however, that EPA recognizes good faith efforts. These are described in EPA’s Audit Policy originally entitled “Incentives for Self-Policing: Discovery, Correction, and Prevention of Violations,” (60FR66706 December 22, 1995) and Small Business Policy entitled “Policy on Compliance Incentives for Small Business” (6lFR27954 June 3,1996).

Most states also have similar incentives for good faith efforts, which can be verified with your local state environmental enforcement office or web site. These policies offer major penalty concessions, but require self-disclosure and other requirements that must be met. To date, EPA’s Audit Policy has been successfully used by hundreds of facilities. Penalties have been waived in many cases or substantially reduced. Don’t wait until an incident happens to start planning what you should do. Manage this process with your ISO 14001 EMS.

Some Y2K Problems

There are dozens of Y2K articles appearing almost daily in the print and broadcast media as the countdown towards the year 2000 approaches. There are several unique issues to be aware of. First, the year 2000 triggers three main events, and not just one. It is the start of a new century, a new millennium, and a leap year. Second, there are more than a dozen different dates that could potentially have unintended Y2K consequences if not corrected. As the new millennium begins, many noncompliant systems are anticipated to default back to the start of the twentieth century or 1/4/80, the date that noncompliant DOS clocks will reset themselves (the original DOS release date).

Generally speaking, any type of hardware or software using date-sensitive programming, databases, files or references may be vulnerable to a Y2K glitch. Many concerns have been especially raised over embedded systems since they are so widely used in mechanical and communications functions. Billions of these “invisible” microchips are in use with estimated failures ranging as high as 2%.

Potential Environmental Impacts

Any Y2K non-compliant activities, products, and services could potentially result in adverse environmental impacts. Examples include: the release of harmful air contaminants resulting from the failure of air pollution control devices; the degradation of waterways due to failure of waste treatment plants; increases in waste disposal of raw materials and products due to failure of inventory control systems; equipment failure due to the disruption of critical preventive maintenance programs; and permit violations due to the failure of sampling, reporting, testing, or calibration requirements.

The EPA is particularly concerned with large municipal waste treatment plants that are typically highly automated and have many remote controlled pumping stations. System failures could possibly cause serious health-threatening backups or overflows, or even the disruption of industrial waste treatment services. Businesses could be forced to temporarily close.

Y2K Environmental Liabilities

There are numerous business issues related to environmental concerns that should be carefully considered by every organization.

Insurance companies may not cover claims for damages or business disruption resulting from Y2K problems since these problems are largely viewed as being foreseeable and not unanticipated. Insurance policies should be verified as to specific Y2K coverage especially related to “sudden and accidental” and “environmental impairment” liability.

Environmental equipment warranties, guarantees, and lease contracts raise complex legal liability issues regarding potential Y2K problems. Machinery and equipment may contain components from multiple manufacturers, some of which may not be Y2K compliant. In some cases, software used for programmable logic controllers, for example, can be pre-programmed by the manufacturer, a vendor, a consultant, or the end user–all of which may introduce Y2K flaws.

It is widely recommended that all purchased equipment and services specify that all deliverables be Y2K compliant. Certifications from key suppliers (raw materials, energy, communications, office equipment, financial services, waste contractors, etc.) should be obtained to protect your business from any major disruptions or liability from environmental impacts or safety hazards.

Being Y2K compliant is not easily defined. The meaning generally centers on the ability to accurately process date-sensitive material between the twentieth and twenty-first centuries, although it should not be construed too narrowly. Both legal and technical personnel should appropriately review the specific wording of certification or warranty statements. Sample warranty statements are available on various web sites including the U.S. Government Interagency Committee on Year 2000 Conversion: http://www.year2000.gsa.gov/mks/yr2000/y2kfnl.htm; http://www.year2000.com/archive/warranty/html.

Using ISO 14001

Using your management review process, establish a clear Y2K readiness objective with targets at each relevant function and level in the organization. Assemble a Y2K steering committee or team that has clearly defined responsibilities, accountability and authority. Be sure to include representatives with direct operating and maintenance responsibilities.

Provide the necessary training using internal or external resources to ensure that each team member understands how to investigate and identify potential Y2K problems. Prioritize critical business functions and systems, including those that could have potential significant environmental impacts.

Assemble a detailed inventory (make, model, serial number, dates, etc.) for all suspect equipment and activities including all critical suppliers of raw materials and services. Include all pollution control equipment and emergency response equipment such as first aid, spill, security and fire protection systems.

Contact suppliers to verify Y2K compliance of all suspect items. Many suppliers have information readily available on web sites. Some examples are:

Foxboro at http://www.foxboro.com; Honeywell at http://www.honeywell.com/year2000/iac; Microsoft at http://www.microsoft.com.ezproxy.torontopubliclibrary.ca/year2000; IBM at ibm.com/ibm/year2000/; and Vendors at http://www.vendor2000.com.

Develop and implement a work plan to test, repair, or replace all suspect items. Define target dates for completing each task and retest each system to ensure it will function properly. Don’t forget to notify EPA if testing environmental controls.

Review emergency response and preparedness procedures, and identify ways to prevent and mitigate any environmental releases, safety hazards, or permit violations that may be caused by Y2K problems. This could include back-up power, water, communications, and emergency services as well as modified production schedules. Appoint a person(s) responsible for internal and external communications.

Check insurance coverage, supplier contracts, equipment leases, and warranties, sales contracts, and regulatory permits to ensure that they cover Y2K compliance and any associated environmental or other liability issues.

Select parameters to monitor and measure progress on your Y2K readiness program. Periodically review results with management and take any appropriate corrective actions to keep the program on schedule.

Don’t Forget Your PC

Making your personal computer Y2K compliant may be as simple as clicking on the date/time icon in the windows control panel and changing the year to 2000. Chances are, however, that it won’t be that simple. A good approach would be to first check with the manufacturer of your computer and software. Fortunately, there are a number of inexpensive multi-utility programs readily available at computer stores that can easily detect and repair many Y2K problems.

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