The Purpose Is Also to Establish and Maintain Documented Environmental Objectives and Targets

TITLE: Environmental Aspect Document ID: EMS-4.3.1 Identification

Issue Date: 07/07/09 Page 1 of 4

Approval: Revision Date:

Purpose

The purpose of this procedure is to identify the environmental aspects of our activities, services and products in order to determine those which may have a significant impact on the environment.

The purpose is also to establish and maintain documented environmental objectives and targets for our significant environmental aspects and to establish and maintain programs for achieving objectives and targets developed for significant environmental aspects.

This procedure applies to all of our activities, services and products and covers the environmental aspects of activities, services and products that our company can control or over which it can be expected to have an influence.

This procedure applies to environmental objectives and targets set by the organization and the development of EMPs to meet those objectives and targets.

Definitions

CFT- Cross Functional Team

EMP - Environmental Management Programs

EMR – Environmental Management System Representative

Environmental Aspect - Elements of the organizations activities, products or services that can interact with the environment.

Environmental Impact - Any change to the environment, whether adverse or beneficial, wholly or partially resulting from the organization’s activities, services and products.

D:\Docs\2018-04-21\0c2266591ef6647654fbc0d41bb4d329.doc TITLE: Environmental Aspect Document ID: EMS-4.3.1 Identification

Environmental Objective – Overall environmental goal, arising from the environmental policy, that the organization sets itself to achieve, and which is quantified where practicable.

Environmental Target – Detailed performance requirement, quantified where practicable, applicable to the organization or parts thereof, that arise from the environmental objectives and that needs to be set and met to achieve those objectives.

Top Management – Environmental Steering Committee

Procedure

The EMR or designee assembles information describing the activities, processes or services of the organization. This information may include process flow diagrams, lists of raw materials, raw material usage information and other information. This information will be used by the CFT to identify the environmental aspects of the organization.

The CFT is assembled by the EMR to review the activities, processes and services information assembled by the EMR. The CFT then lists environmental aspects and sets priorities for further analysis as needed. The CFT prepares a record of its review on Aspects List.

The CFT then reviews the list of aspects and determines which are significant by evaluating each aspect against the following five criteria:

Regulatory - Is the aspect subject to a local, state/provincial, Federal regulation or corporate guideline, policy or procedure?

Unplanned Release - Could a significant environmental impact result from an unplanned release?

Other Interested Parties – Have other interested parties expressed views regarding an environmental aspect?

Economic Considerations - Does the aspect have a significant economic impact on the organization?

Scale, Duration - Are there other significant environmental impacts from the aspect due to its scale (amount generated or emitted) or duration (how long will the aspect continue to have an impact on the environment)?

A decision by a majority of the CFT members that an aspect is covered under any of these criteria results in the aspect status being identified as significant.

The EMR or designee enters the results of CFT review on Aspects List.

The EMR or designee establishes preliminary objectives and targets for each significant aspect or group of aspects (see Aspect List). The EMR or designee will consider legal and other requirements, its significant environmental aspects, technological options and its financial, operational and business requirements, and views of interested parties when establishing objectives and targets.

Objective, Targets and EMPS The EMR or designee will also prepare a proposed list of objectives and targets (see Objectives and Targets List) The Objective and Targets list is reviewed and approved by top management during management review. Project plans (Environmental Management Programs) are prepared for each objective and target. These are also presented to top management during management review meetings.

Keeping the Aspect List Up-to-Date

New projects including new construction planned at our facility will be presented to the EMR by the project manager for identification of new or modified environmental aspects. The EMR will review the information and ensure that new environmental aspects are listed on the Environmental Aspect Form (E01-Form 1). Annually, in May, the EMR will assemble the CFT to review and revise the significant aspect list.

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