Hazardous and Radioactive Waste Treatment Technologies Handbook - Chapter 9 docx

© 2001 by CRC Press LLC9.1 The Integration of Mixed Waste Treatment into an Environmental and Quality Management System This section discusses the role of modern methods in mixed wast

© 2001 by CRC Press LLC

Chapter Nine System Integration and

Deployment

© 2001 by CRC Press LLC

9.1

The Integration of

Mixed Waste Treatment

into an Environmental and

Quality Management System

This section discusses the role of modern methods in mixed waste treatment (MWT) technology as part

of a systematic approach of integrating this technology into an environmental management system (EMS)

or a quality management system (QMS), with environmentally sustainable development (ESD) — orenvironmental sustainability — as a performance goal A brief background on the two major internationalstandards (ISO 9001:1994 and ISO 14001:1996) as templates for quality and environmental managementsystems is provided

Because MWT technology is a broad area, the emphasis in this section is on the planning aspects andmajor questions a professional should consider when deliberating the successful integration of MWTtechnology into an EMS and QMS Planning aspects should encompass key areas such as human healthtoxicology, human health risk assessment, and ecotoxicology The principles of this section can also beused for any type of waste, mixed as well as non-mixed

This section will help prepare the reader so he/she can choose the best MWT technology for a particularneed, thereby attaining or approaching environmental sustainability Texts and references listed at theend of the section provide further detail about the QMS, EMS, and ESD

What Is Environmental Sustainability and its Relationship to MWT?

Environmental sustainability and sustainable development are terms sometimes used interchangeably.Without splitting hairs, one might say that sustainable development leads to environmental sustainability

To explain more precisely what these concepts mean, and how crucial they are for MWT technology, ashort history of their evolution is beneficial

In 1987, the United Nations (U.N.) World Commission on Environment and Development land Commission) coined “sustainable development” in its report entitled “Our Common Future.” Thisreport, which emphasized the need to balance environmental protection and economic growth, definedsustainable development as “development that meets the needs of the present without compromising the

(Brundt-ability of future generations to meet their needs.” This perhaps is the earliest modern use of the termand the simplest definition.

In 1991, the International Chamber of Commerce (ICC) created the Business Charter for SustainableDevelopment The ICC Charter is composed of 16 principles for environmental management that fostersustainable development The principles in this document include some of the basic elements of envi-ronmental management systems still in use today

In 1992, the U.N Conference on Environment and Development (UNCED) was held in Rio de Janeiro,Brazil The conference, also known as the Rio Summit or Earth Summit, resulted in two importantdocuments: “Agenda 21” and the “Rio Declaration.” “Agenda 21” is a comprehensive guidance documentfor sustainable development, and the Rio Declaration provides a set of 27 principles for achievingsustainable development

The progress of the “Agenda 21” initiatives was evaluated in a follow-up summit in June of 1997 Thegoals of this follow-up summit were to assess progress, share best practices, evaluate gaps in financialand economic terms, and build better infrastructure toward “Agenda 21” sustainable development objec-tives The summit results indicated:

1 An increase in global warming from greenhouse gases such as carbon dioxide

2 A growing presence of toxic chemicals in the environment

3 A growing scarcity of freshwater and a loss of productive farmland

4 Growing marine pollution and a loss of viable fisheries

5 Continued destruction of forests

Also in 1997, at a global warming convention in Kyoto, Japan, consensus was reached on cutting back

on greenhouse gases to various degrees in various regions of the world, and timetables to achieve thesecutbacks were set At the time this section was written, the U.S Congress had not ratified the Kyotoagreement and was not expected to do so But its impact has been felt in many U.S industrial sectors,and voluntary compliance with carbon dioxide reduction levels has gained momentum Carbon dioxideproduction — and the growing need to reduce it — affects MWT technology decisions now and willcontinue to do so in the future

In May 1999, the U.S President’s Council on Sustainable Development released “Towards a SustainableAmerica: Advancing Prosperity, Opportunity, and a Healthy Environment for the 21st Century — FinalReport of the President’s Council on Sustainable Development.” This report concluded that movingenvironmental management into the 21st century required:

• A broader understanding of the nature, source, and linkage of environmental problems andrecasting of potential solutions

• A system that is goal-, performance-, and information-driven; is attuned to natural ecologicalcycles; incorporates the values of community and place; is sensitive to variations in the businesssector and changes in the economy; and increases outside participation in decisions that affectthe environment and neighboring communities

• Continued refinement of traditional environmental management tools, while encouraging opment of new tools and collaborative strategies

devel-The President’s Council outlined many goals defining environmental sustainability; the four mostimportant relating to MWT are listed below:

Goal 1: Health and the Environment Ensure that every person enjoys the benefits of clean air,clean water, and a healthy environment at home, work, and play

Goal 2: Economic Prosperity Sustain a healthy U.S economy that grows sufficiently to createmeaningful jobs, reduce poverty, and provide the opportunity for a high quality of life for all in

an increasingly competitive world

Goal 3: Equity Ensure that all Americans are afforded justice and have the opportunity to achieveeconomic, environmental, and social well-being

Goal 4: Conservation of Nature Use, conserve, protect, and restore natural resources, land, air,water, and biodiversity in ways that help ensure long-term social, economic, and environmentalbenefits for ourselves and future generations.

The first three goals outline what has been called the three Es of sustainable development: environment,economics, and equity The last goal addresses the broad definition of environmental sustainability thatcan be summarized as “leaving the earth in at least as good a condition for future generations as wasreceived by ours.”

These national and international initiatives on sustainable development have marked the dawn of anew age in environmental protection The initiatives directly impact MWT as the last link in a technicalsystem chain (or system) leading to the environment The growing societal expectation in the past decade,which will likely continue in the 21st century, is for the public and private sectors to operate sustainably.Technically, this forces two modes of operation: either a closed-loop system with no impact on theenvironment — of which MWT will be one facet of that cycle — or an open system that involves MWT

as the last link to the environment

For open systems, defined as a system in which the material at the end of the treatment process will

be released to the environment, the mixed waste treatment chosen must have scientific assurance (throughrisk assessment and other means) that the environmental products released will be reincorporatedrenewably into the environment, be economically feasible, and equitable for the community In short, if

an MWT system is not closed, the MWT technology model used will have to limit disposal within theassimilative capacity of the air, water, and soil Examples of these technologies are described elsewhere

in this Handbook

The term “system” was highlighted above (in italics) to underscore the importance of its ability todemonstrate accountability and verification of MWT technology in relation to environmental perfor-mance and sustainable development For the remainder of this section, the ISO standards for quality(ISO 9001:1994, Specification for a Quality Management System (SQMS)) and environmental (ISO14001:1996, Specifications for an Environmental Management Standard (SEMS)) will be used as tem-plates for integrated quality and environmental management These standards, the most globally accepted

of their kind, outline the concepts common to all good quality and environmental management systems.What Are ISO and ISO 9001 and ISO 14001?

The International Organization for Standardization (ISO), founded in 1946, is responsible for the opment of the ISO 14000 series of international quality and environmental management standards ISO,based in Geneva, Switzerland, has developed international voluntary consensus standards for manufac-turing, communication, trade, and management systems Its mission is to promote international trade

devel-by harmonizing international standards and developing new ones when there is a need More than 100countries have national standards bodies that are members of ISO, although only a few are votingmembers (called participating, or P, members) with the power to vote on ISO standards

The American National Standards Institute (ANSI) is the U.S representative to ISO, voting on ISOstandard matters on behalf of the United States ANSI was formed in 1918 to develop U.S consensusstandards and to coordinate this nation’s involvement in international standards ANSI consists ofrepresentatives from industry, government, consumer organizations, professional societies, labor, andother groups and represents a wide berth of American stakeholders All voting within ISO is on a one-country, one-vote basis; the size of a nation’s market, geographical area, or population is not a factor.ANSI is the only private-sector, nongovernmental voting member within the ISO and reflects the UnitedStates’ dedication to private-sector control of voluntary standards related to trade and other matters.ISO produces specification standards, which have certain elements that must be implemented asrequirements if one is to conform to the standard Through an internal or external auditing process,parties demonstrate conformance to a specification through a registrar or other recognized standardsbody The ISO also produces guidelines, which are not requirements and may not be audited; however,

these guidelines provide users with internationally agreed-to definitions, interpretations of elements of

a standard, and helpful advice with implementation

Development of ISO 9000 Quality Management Standards

The ISO 9000 series of international quality management standards was published in 1987 after nearly

a decade of back-and-forth negotiation These standards were created to promote consistent qualitypractices and to facilitate international trade The ISO 9000 series has been adopted by more than 80countries and is used as a benchmark for quality management by industry and government bodiesworldwide In some cases, ISO 9000 registration has become a prerequisite for doing business, bothdomestically and internationally In North America alone, more than 25,000 companies are registered toISO 9000 — and the number is growing

The QMS framework can serve as a foundation for environmental management systems and for theirintegration In essence, an EMS is the application of QMS principles to the management of environmentalaffairs ISO 14001 was drafted with language to provide consistency between standards, and althoughISO 9000 and ISO 14001 have different focuses, they share many similar requirements

The three specification documents for the ISO 9000 series are ISO 9001, ISO 9002, and ISO 9003 Thekey differences between ISO 9000 and ISO 14001 is that ISO 14001 requires planning steps to identifyenvironmental aspects and significant environmental impacts that become the basis of an organization’sobjectives and targets For ISO 14001, an organization is responsible for setting its own environmentalobjectives and targets; for ISO 9000, quality objectives are contractual agreements between an organiza-tion and its customer(s)

Development of the ISO 14000 Series Environmental Management Standards and their Relationship to MWT

In June 1991, the ISO formed the Strategic Advisory Group on the Environment (SAGE) SAGE assessedthe need for international environmental management standards and recommended that ISO moveforward with their development In January 1993, the ISO formed Technical Committee 207 (TC 207)and charged it with the development of the ISO 14000 series of standards TC 207 is composed of varioussubcommittees and working groups Representatives from the ISO member countries contribute theirinput to TC 207 through national delegations

In 1996, TC 207 developed the ISO 14001 standard, which specifies requirements for an EMS TheISO 14001 standard is the only one within the ISO 14000 series that is designed to be audited — a true

“specification standard,” as mentioned elsewhere ISO 14001 contains 17 elements that comprise an EMS

In addition to ISO 14001, TC 207 is also developing several guidance documents ISO 14001, ISO

14004 (an EMS guidance document), and three environmental auditing guidelines (ISO 14010, ISO

14011, and ISO 14012) were published in September 1996 At the time this section was written, otherdocuments covering environmental labeling, life-cycle assessment, and environmental performance eval-uation were being developed Published ISO standards must be reviewed and revised every 5 years.ISO 14000 is a series of internationally recognized standards for structuring an organization’s EMSand managing the environmental performance of the system to effect environmental improvement andcost savings The ISO 14000 series includes standards for EMS (14001, 14004), auditing (14010, 14011,14012), labeling (14020, 14021, 14024), environmental performance evaluation (14031), and life-cycleanalysis (14040)

ISO 14001 is the cornerstone document of the ISO 14000 series of standards, and is modeled after thehighly successful ISO 9000 QMS standards It is the document used for registration ISO 14001 requires

3 Implement and operate the program to include defined structure and responsibility, training,communication, documentation, operational control, and emergency preparedness and response

4 Implement checking and corrective action to include monitoring, corrective and preventive action,and auditing

5 Establish management review

MWT technology has a major role in all five of these standard elements, as will be discussed in detaillater in this section Because MWT technology is chosen and implemented primarily for environmentalconcerns, the major elements of the ISO 14001 standard are overviewed and related to quality.Elements of the ISO 14001 Standard

First, an overview is needed of the major elements of ISO 14001:1996, (SEMS) The elements listed herealso have many parallels to ISO 9001:1994 (SQMS) MWT technology will be heavily concerned withthe functioning of an EMS, so this overview sets the stage for comparison

• Environmental policy Develop a statement of the organization’s commitment to the environment

At a minimum, the organization must commit to three things in its policy: compliance withregulations, prevention of pollution, and continual improvement of the management system Thepolicy acts as a framework for planning and action

• Environmental aspects Identify environmental attributes of the organization’s products, activities,and services Determine those that could have significant impact on the environment

• Legal and other requirements Identify and ensure access to relevant laws and regulations (and otherrequirements to which the organization adheres — e.g., responsible care)

• Objectives and targets Establish environmental goals for the organization, in line with its policy,environmental impacts, views of interested parties, and other factors

• Environmental management program Plan actions to achieve environmental objectives and targets

• Structure and responsibility Establish roles and responsibilities, and provide resources to attainenvironmental objectives and targets

• Training, awareness, and competence Ensure that employees are trained and capable of carryingout their environmental responsibilities

• Communication Establish processes for internal and external communications on environmentalmanagement issues

• EMS documentation Maintain information on the EMS and related documents

• Document control Ensure effective management of procedures and other system documents

• Operational control Identify, plan, and manage operations and activities in line with the zation’s environmental policy, objectives, and targets

organi-• Emergency preparedness and response Identify potential emergencies and develop procedures forpreventing and responding to them

• Monitoring and measurement Monitor key activities and track environmental performance

• Nonconformance and corrective and preventive action Identify and correct problems and preventrecurrences

• Records Keep adequate EMS performance records

• EMS audit Periodically verify that the EMS is functioning as intended

• Management review Periodically review the EMS with the goal of continual improvement of themanagement system

In the list above, if the word “quality” were substituted for “environment,” it would closely parallelwhat is required in an ISO 9001 quality management system ISO 9001 and ISO 14001 each encompass

a “say what you will do, do what you will say, and document it” philosophy The standards outline a

process, not a technology-specific course of action This is important for our discussion of MWTtechnology and systems integration because it allows greater flexibility in selecting the most appropriateMWT technology.

What Is Integration?

Integrate is defined as “to make whole or complete by adding or bringing together parts.” This concept

is especially important because, too often, MWT has been viewed as a necessary evil or as an overheadcost, entirely separate from the quality functions The lack of integration of MWT into quality andenvironmental management has caused problems in selecting the technology that best met all of thestakeholders’ needs (the community as well as the environment) or in satisfying the three Es of sustainabledevelopment Integration solves this problem by linking QMS and EMS, where possible, to save cost,time, and effort and to satisfy all stakeholder needs through communication, efficiency, and performance.How Does One Achieve Integration of MWT with ISO 9001 and ISO 14001?The ISO 9001 QMS and the ISO 14001 EMS standards share many parallel elements, which makes iteasy to link them together The means advocated here to achieve MWT technology integration is twofold:

1 Use the process outlined by these system standards to examine quality and environmental needsand goals side by side, considering quality and environmental concerns

2 Ask the right questions to ensure that each element is satisfied for both quality and environmentalconcerns with a goal of attaining environmental sustainability

To do this more effectively, a primer on human toxicology, human health risk assessment, and icology is provided in other chapters of this Handbook Life-cycle analysis is also examined to helpevaluate economic impacts that will prove useful when canvassing MWT options and deciding the bestmeans to achieve quality and environmental sustainability outcomes

ecotox-Step-by-Step Integration of MWT into an ISO 9001 Quality and ISO 14001 Environmental Management System

This subsection outlines the major questions on integrating MWT into an organization’s quality andenvironmental management systems There is not enough space for a detailed discussion of all elements

of the ISO 9001 and ISO 14001 standards requirements as they relate to MWT technology, but all elementsare covered in some fashion, and helpful suggestions are provided When reviewing this subsection, it isrecommended that the reader have available a copy of the ISO 9001 and ISO 14001 standards, along withtheir guideline documents

Policy

An organization’s policy with respect to quality and the environment is fundamental to frame thecontext of MWT technology selection and how it will be integrated into these systems The goals setout in the policy drive performance, and the remainder of the system (including MWT technology)must support policy

A fundamental question is: What is the organization’s commitment to environmental sustainability?

If there is a commitment to ESD, then the MWT technology chosen to be integrated in the systems must

be made with this policy goal in mind If there is no commitment to ESD, one might ask whether itcould be In the near future, environmental sustainability may be an external requirement — it would

be wise to consider this as a policy goal even if one’s organization does not presently require it.Remember that, at a minimum, ISO 14001 requires that an organization’s environmental policy beappropriate to the nature, scale, and environmental impacts of its activities, products, and services Thereshould also be a commitment to pollution prevention, legal compliance, and related matters, and con-tinual improvement over the ISO 9001 QMS goals of meeting customer quality expectations is desired

A separate environmental policy with these elements could be promulgated Insertion of these statements

in the quality policy is also a means of achieving QMS and EMS systems integration The commitmentsmade in policy will provide clear direction for MWT technology selection

The planning elements in the ISO 14001 standard strongly parallel design requirements under ISO

9001 For any integration of MWT technology into an ISO QMS and EMS system, the potential andactual causes (aspects) of such technology should be identified, as should the potential effects (impacts).Proper MWT selection is significant because it brings us front and center to human and ecotoxicologyrisk assessment paradigms and involves the economic elements (satisfying customer needs at a reasonablecost) and community concerns (equity) essential for environmental sustainability All must be consideredand satisfied

One of the paradigms to examine when planning is:

Poor Quality • Poor Yield • Waste • Negative Environmental Aspects • Negative Environmental Impacts

• Reduced Profits, Adverse Worker and Community Health Risk or Outcomes, and Long-Term ronmental Damage

Envi-The reverse and positive side of this planning paradigm is:

Good Quality • Good Yields • Minimal to No Waste • Minimal to No Environmental AspectsMinimal to No Environmental Impacts • Maximum Profits, Minimal to No Adverse Worker orCommunity Health Risk or Outcomes, Minimal to No Environmental Damage, Possibly Demon-strated Environmental Improvement

It is important to remember that living systems operate in an environmentally sustainable fashion Innature, all waste materials are recycled in a manner that is consistent with the capacity of the environment

A major industrial design consideration for MWT is to achieve this performance characteristic as much

as possible The planning process will involve — and ISO 14001 requires — consideration of legal andother requirements, which, combined with the human toxicology and ecotoxicology risk assessments,will help set priorities, objectives, and targets for planning MWT integration

The simplest model for MWT integration planning is to look at all MWT in a linear fashion as follows:MWT Input → MWT Process → MWT Output

Examining MWT technology in a linear fashion, yet applying a systematic approach, allows use of alogical planning process to achieve quality and environmental system integration Although it is displayedlinearly for simplicity, this is actually a cycle with the endpoint (MWT output) representing a reintro-duction of material — as an input to production or sustainable commerce, or as an input to theenvironment for complete assimilation

MWT Input Planning

Input is the first area to consider in planning MWT Questions that can be asked include:

1 What waste stream(s) will the MWT be treating?

2 What volume of waste over what period of time will be treated?

3 Will the mixed waste stream be of a consistent quality or will it be variable?

4 What are the physical, chemical, and biological characteristics of the mixed waste material to betreated?

In quality and environmental management terms, the importance of knowing what type or types, howmuch, and the properties of the waste to be treated cannot be over-emphasized MWT input must beestimated as accurately as possible when planning appropriately for quality and environmental manage-ment system integration

“Why?” is another important input question, and the answer is more complex than it might seem atfirst When considering input for MWT, one should examine opportunities to reduce pollution at thesource Questions that can be asked include:

1 Can a design change be made upstream that will produce the product or service so that MWTcan be avoided entirely?

2 Can there be process changes to prevent pollution or minimize the waste to be treated?

If waste can be reduced at the source, it extends the life of the equipment Alternatively, the MWTprocess can be avoided entirely, thus eliminating the risk to human health and ecological destructionaltogether, which would be the optimal environmentally sustainable option

Other chapters in this volume that deal with industrial waste classification, waste characterization,and in situ and laboratory techniques for characterizing wastes will help answer questions about MWTtechnology input

Three Environmentally Sustainable Options for MWT Process PlanningOnce the input or the mixed waste is characterized adequately (including the estimated mixed wastevolume), the next step is planning for the MWT process

To achieve total environmental sustainability, there are three possibilities for MWT technology:

1 Transformational reprocessing of mixed waste into something that can be reintroduced to duction or sold to a customer

pro-2 Transformational reprocessing of mixed waste for release to the environment with no humantoxicological or health risk, or ecotoxicological impact or risk

3 Transformational reprocessing of mixed waste for release to the environment with minimizedimpact and risk to human toxicological or health risk, or ecotoxicological impact or risk.The first two possibilities listed above are the superior choices, of course They are examples of a MWTclosed-loop system process, where treated mixed waste is recycled into something that is used, remanu-factured or sold, or is rendered into a material that has no negative impact on the environment or possiblyeven has a positive impact (e.g., waste biotransformation or composting) The third option is an opensystem process, where some potentially hazardous material is released to the environment, preferably atlevels well below human and ecological risk

An open system could be sustainable if the amount released to the environment does not impoverishthe utility and productivity of an ecosystem for this and future generations — a process that requiresscientific risk assessment, economic analysis, and multiple impact analysis to prove substantially andbeyond a reasonable doubt that it is harmless Open system environmental sustainability is possible, andfor some mixed waste streams it may be the only practical option available

Examples of mixed waste processes that can be used for transformation/reprocessing for recycling,reuse, and possible reintroduction to the economy are as follows:

1 Separation techniques The systemic question is: Can the mixed waste be unmixed easily, or notmixed to begin with, to permit production of a useful product? The MWT professional, workingwith the design team to separate waste streams as far upstream as possible in the manufacturingsystem so that waste products remain simple or more pure, is an example of good quality andenvironmental management system planning for MWT Gravimetric settling or filtration processesare also possible MWT techniques that could be used to separate materials for reuse or resale.

2 Concentration techniques The systemic question is: Can the mixed waste be processed in a waythat captures and concentrates the waste material to permit production of a useful product?The MWT professional is looking for a means to concentrate the hazardous material before itreaches the environment, and thus produce a useful material An example of this technique is

to capture hazardous materials from a waste stream and re-release them into a manufacturingprocess, such as using activated carbon to capture solvents from wastewater and then usingthermal desorption to release them to a processing stream Another example would be to use

a cationic resin to capture low levels of heavy metals from a wastewater stream and then releasethe metals from the resin in an acid bath that could be turned over to a plating operation Yetanother example would be to use a condenser column to capture unpolymerized monomer(e.g., butadiene or styrene) from a synthetic rubber operation and then reintroduce the capturedmaterial to the polymerization operation In all of these situations, the waste is captured andconcentrated as part of the treatment process to produce something useful for manufacturingand not introduced into the environment

3 Select thermal techniques The systemic question is: Can the waste material be transformed ically and physically through heat to permit production of a useful product? A good example isthe steam gasification of fossil fuel and carbon-containing wastes described by Dr Terry Gallowayelsewhere in this handbook Using this technique, high sulfur coal and solid waste can be trans-formed into carbon disulfide, middle distillates, and asphalt and other hydrocarbons withoutcombustion or carbon dioxide generation This technique is especially useful for complicatedcarbon-containing wastes

chem-Wet air oxidation, hydrothermal oxidation, and molten salt oxidation, also discussed elsewhere

in this handbook, offer the means to be able to transform materials with some energy expenseinto other materials that may be useful or reduce and eliminate environmental impact

4 Select non-thermal treatment technologies The systemic question is: Can the waste material betransformed chemically and physically to permit production of a useful product? Dehalogenation

of, for example, a large concentrated pool of polychlorinated biphenyls from transformers is anexample of this process Electrochemical and direct oxidation are other examples These MWTprocesses are described in more detail elsewhere in this handbook

Examples of mixed waste processes that can be used for transformation/reprocessing for recycling,reuse, and possibly for release to the environment are as follows:

1 Select thermal techniques The systemic question is: Can the mixed waste be transformed throughheat into a material that will not pose a human or ecological health or toxicity risk and can beassimilated by the environment with no negative impact? The two primary techniques would beplasma transformation or incineration; both are discussed elsewhere in this handbook In somesituations, it may prove technically and economically infeasible to process the material into some-thing useful; thus, transforming it into a simple material (e.g., carbon dioxide or carbon monoxide,totally assimilated by the environment) may be the best or only option If the volume of wasteprocessed is low, this may prove to be a sustainable option given the toxicity of the starting mixedwaste material With carbon dioxide reduction becoming a greater priority, however, carefulconsideration should be given to this option Perhaps the carbon dioxide produced from theincineration could be concentrated or sequestered in some fashion by a secondary treatment toprovide a closed system

2 Select non-thermal treatment The systemic question is: Can the mixed waste be transformedthrough chemical or biological means into a material that will not pose a human or ecologicalhealth or toxicity risk and can be assimilated by the environment with no negative impact?Biological destruction, discussed elsewhere in this Handbook, is an example of transformingmaterials using the nanotechnology of life forms to produce material that can be composted oreasily assimilated into the environment without impairment Key factors to consider are the type

of material to be biologically decomposed, what it becomes in the organism, the time for thistransformation to take place, and the volume of mixed waste materials to be processed Biologicaltransformation, for example, might produce compost, fertilizer, or even foodstuffs as a side benefitfrom chemically transforming mixed waste material Ozonation, photolysis, gas-phase destruction,inorganic decomposition, and radiation-induced oxidation — discussed elsewhere — are otherprocesses in which waste is chemically transformed into environmentally benign materials

3 Stabilization and solidification technologies The systemic question is: Can the mixed waste betransformed through physical means into a material that will not pose a human or ecologicalhealth or toxicity risk and can be assimilated by the environment with no negative impact? In thisoption, the mixed waste material becomes, at best, a diluted material that uselessly occupies space,posing a reduced or negative environmental impact For some mixed waste, such as highly radio-active isotopes, vitrification — the dilution of the radioactive material into a solid solution (e.g.,glass) — may be the only and best long-term solution if the material cannot be recycled, concen-trated, or reused If radioactive wastes can be diluted to an extremely low concentration (i.e.,vitrified), lower in radiation than naturally occurring radioactive ores, then an environmentallysustainable solution has been reached The difficulty is that the energy and material costs toconduct environmentally sustainable vitrification are high The cost and technical challenges, aswell as opportunities, for vitrification and other solidification MWT technologies are discussedelsewhere in this handbook

The processing techniques cited above represent transformational reprocessing of mixed waste forrelease to the environment with minimized human toxicological, human health, and ecotoxicologicalimpact or risk The processing questions are the same — it is the totality or degree to which they aresatisfied that makes the distinction between minimal environmental impact and sustainable operation

A key point is whether there is low risk at a scientifically acceptable level (i.e., no negative environmentalimpact now or for future generations), indicative of assimilation into the environment or sustainability,

or whether the MWT technology is operated at some risk above the scientifically verifiable level butwithin regulatory and legal standards

Output

For planning purposes, try to begin here: examine MWT and rank the value of planned technologyagainst meeting EMS policy objectives and the three Es of sustainability At this point in the planningprocess, the design considerations should review legal and regulatory requirements The following arethe types of questions that should be considered when examining the MWT output in an ISO 9001 andISO 14001 context

1 Will the planned MWT produce an output that:

a Will stimulate new environmental aspects and impacts, through release of matter or energy tothe environment?

b Will change positively or negatively a current quality or environmental aspect or impact?

c Will involve new or different legal and regulatory rules?

d Can be sold or reintroduced to production?

e Can be reintroduced to the environment with no negative aspect or impact to this or futuregenerations?

2 Will the output:

a Be classified as hazardous (i.e., ignitable, reactive, corrosive, toxic)?

b Produce a substance that will be harmful to the employees working with it?

c Generate a hazardous air emission?

b Generate an ozone-depleting substance?

e Produce a substance subject to land disposal restrictions?

f Produce a substance subject to water emission restrictions?

g Produce a material requiring special labeling or packaging requirements?

In examining MWT output, the chapter in this volume dealing with the laws and regulations governingMWT technology listed national and international regulatory bodies and various regulations that should

be referenced and consulted; thus, information will not be repeated here At this stage, however, thelinear analysis of MWT technology ends and we return, if needed, to the beginning of a cyclic planningprocess If the answer to any of the MWT output questions posed above is “Yes,” other MWT technologies

or means to minimize human and ecological health risks should be weighed Careful consideration should

be given to manufacturing or service process modification to ensure that everything has been donetechnically and feasibly to develop the most effective MWT technology for your quality and environmentalgoals In short, return to the beginning of the planning process and weigh the risks and benefits of theMWT chosen

The systemic question for planning in MWT technology is:

1 Is there a negative aspect or impact?

2 If so, what is its type, magnitude, duration, and potential cost to the environment in equity andeconomic terms?

3 Is this aspect or impact controllable through substitution, prevention, or further MWT?Ask these questions at the beginning and the end of a planning circle to identify cost-efficient envi-ronmental improvements before new MWT technology is implemented Then evaluate the MWT optionsidentified against policy and the three Es to identify the best one, or combination, to meet yoursystem’s needs

MWT, by definition, is an “end-of-pipe solution” that must be planned and implemented when allother technological means have been exhausted to prevent “waste” or non-useful product from beingintroduced into the environment The systemic planning paradigm for sustainable development advo-cated in quality and environmental management is to view all waste as unused resources The unusedresource then requires developing a plan for a useful purpose for it If MWT can be planned as atransforming technology, in which waste is reintroduced as a useful product or introduced at environ-mentally benign levels, the more MWT integrates itself into a system of economically and environmentallyvalue-added technology

The planning component outlined here also provides a link back to quality and environmental policy.The inputs, process, and outputs of the chosen MWT will determine objectives, targets, and programsneeded for consistent operation of the MWT within a quality and environmental management system.The objectives will be the overall integration of the MWT technology as related to the three Es; the targetswill be the measurable milestones indicating positive progress toward objectives; and the programs will

be the means by which the objectives and targets will be achieved

Program Elements

Policy and planning define the needed programs and what they will achieve The next areas discussed

— implementation and operation, checking and corrective action, management review, and continualimprovement — are the “how-to” elements for integrating MWT into environmental and quality man-agement programs

Implementation and Operation

Once the objectives and targets for MWT technology have been defined through the policy and planningprocess, a roadmap exists to assist in defining the program that puts the MWT in place (implementation)and for its ongoing performance in attaining targets and objectives (operation)

Six elements form the focus for implementing and operating MWT technology within an integratedISO 9001 quality and ISO 14001 environmental management system:

1 Structure and responsibility

2 Training and competence

3 Communication

4 Documentation

5 Operational control

6 Emergency preparedness

Structure and Responsibility

ISO 9001 and ISO 14001 both require management to ensure that the organization is capable of meetingall the requirements of these systems Management must commit resources, align (integrate) environ-mental management with other management systems, define responsibilities and accountability, buildawareness and motivation for quality and environmental goals, identify the knowledge and skills needed,establish processes for communication and reporting, and put in place operational controls for its EMSand QMS systems as a whole These structure and responsibility areas need to be included for MWTtechnology

Critical questions to ask when integrating EMS and QMS are:

1 What is the relationship between an individual’s performance, quality responsibility, and mental responsibility with respect to MWT technology?

environ-2 How do personnel who are accountable and responsible understand the consequences of MWTtechnology failures or noncompliance?

3 How do personnel who are accountable and responsible anticipate, recognize, document, andprovide feedback about quality or environmental improvement opportunities or problems withMWT technology?

4 How do personnel who are accountable and responsible initiate action to comply with quality andenvironmental policy, programs, objectives, and targets for the MWT technology?

By asking these questions and using the ISO 14001 and ISO 9001 standards and their guidelines forcomparison, one can easily identify structure and responsibility gaps between how MWT technology ismanaged now and how it is planned to be managed According to Section 4.4.1 of ISO 14001, the roles,responsibilities, and authorities shall be defined, documented, and communicated in order to facilitateeffective environmental management MWT technology would need to be included in this A solutionwould be to ensure a chain of responsibility for MWT technology throughout the organization, includingroles for quality and environmental management representatives

Training and Competence

ISO 9001 and ISO 14001 both require that training needs be identified and that employees receive trainingcommensurate with their function Element 4.4.2 of ISO 14001 is more specific and requires thatemployees at each relevant function be aware of:

• The importance of conformance with environmental policy and procedures

• The significance of actual or potential environmental impacts and the benefits of improvedpersonal performance

• Their roles and responsibilities

• The potential consequences when operating procedures are not followed

Competency is based on education, training, and/or experience To be compliant with ISO 14001,training procedures with the goals listed above must be in place.

The following training factors are designed to link MWT technology with quality and environmentalsustainability objectives They should be examined and included when necessary:

• Specific regulatory requirements

• Relevant corporate policy, goals, objectives, and/or industry standards

• Data collection and input, process, and output measurement techniques

• Safety and health factors for workers, the community, and the environment

• Normal operations and maintenance

• Upset situations

Because many accidents result from human error, effective employee education in MWT technology

is critical when trying to minimize failures Once MWT technology has been planned, it is important toensure that a training needs analysis, a documented training implementation plan, and an evaluation ofthe training program’s effectiveness are performed

Communication

Internal and external communication is important when integrating MWT technology into a quality andenvironmental management system Internal communication is essential so that MWT technology oper-ates efficiently within the entire quality and environmental management system External communication

is necessary to satisfy the equity and right-to-know inquiries of other stakeholders

The recent trend has been for greater knowledge and transparency for environmental, health, andsafety issues and their impact on the community Societal growth toward sustainable development willmake open, clear communication about MWT even more important in the future Communication withboth internal and external parties is important because of the role of MWT technology in pollutionprevention and in minimizing the health risks to workers, the community, and the environment for thisand future generations

ISO 9001 and ISO 14001 have overlapping internal communications requirements for the quality andenvironmental elements These are important when integrating MWT technology communication Theserequirements include:

• Policy

• Management reviews

• Results of audits

• Results of monitoring, measurement, and control of suitable process activities

• Roles and responsibilities

• Training requirements

• Operational and process controls

• Corrective and preventive actions

• Objectives and targets

ISO 14001 also requires internal communication for environmental aspects and emergency responseprocedures These last two are particularly important for MWT technology due to its endpoint natureand its potential connection to workers, the community, and the environment

One procedure could handle internal communication requirements for both the quality and mental systems This procedure could also be used for external communication Not all of the nineelements listed above are required to be communicated by the ISO standards Environmental aspects,the EMS itself, and the quality and environmental policy are required public communications, and aprocedure for receipt, documentation, and response to relevant inquiries from interested parties is also

environ-required Because MWT technology can directly impact the environment and the public, areas of publicinquiry regarding MWT could focus on:

• Worker, community, and environmental aspects and impacts

• How the MWT recycles material

• How MWT prevents pollution

• Consequences of MWT technology failure when there is an upset condition

External communications about these questions and other questions deemed relevant should beaddressed as part of the integrated communication process

Documentation

Review of the ISO 14001 and ISO 9001 standards indicates that both standards are heavy on records anddocumentation to support quality and environmental actions ISO 14001 is somewhat less documenta-tion-intensive than ISO 9001 ISO 14001 does not require an EMS manual, whereas ISO 9001 does;however, most clients implementing both systems tend to develop an EMS manual because it is valuable

as a directory or map to the system In fact, revisions of ISO 14001 in 2001 might require an EMS manual.Even if one were to choose not to use the ISO systems, U.S regulatory standards and concerns aboutlegal liability with regard to MWT technology would almost certainly require a significant effort todocument planning, operations, maintenance, and other activities Both the ISO quality and environ-mental management standards have been designed to provide at least the minimum information needed

to support an independent audit And, given today’s electronic information systems, maintaining andchanging the documents to a system are far easier than in the past

Because documentation is essential in any quality or environmental management system, Tables9.1.1

and Table 9.1.2 list all sections in the ISO 9001 and ISO 14001 standards where written records orprocedures are required The tables provide a roadmap to the formal documentation process requiredfor quality and environmental management standards For a system to be completely integrated, all ofthese documentation requirements must be satisfied

Not all documentation requirements are specific to MWT technology For example, a policy mightnot specifically mention MWT directly An audit of MWT technology, however, will likely be a requiredrecord in the system if the waste treated is on the list of significant environmental aspects and impactschosen by the company MWT elements in the table that are more important for ISO QMS and EMSsystem documentation are in bold type

For definition, documentation refers to written procedures for ensuring that the environmental andquality management process meets the criteria of the ISO standards as well as regulatory and legalrequirements, voluntary codes for quality and environment, and ultimately the policies set forth by theorganization Records are the written objective evidence that the procedures are carried out as specifiedand are effective

The systemic question for documentation is to review ISO 9001 and ISO 14001 system requirementswith respect to the MWT technology being implemented and ask:

What documentation, procedures, and records are required within our system to meet the environmentaland quality policy, objectives, and targets?

A practical suggestion would be to merge or embed MWT technology documents within the fourlevels of documentation that emerge in the document hierarchy for an ISO QMS or EMS This hierarchy is:QMS/EMS Policy → QMS/EMS Manual → Standard Operating Procedures → Work Instructions

Maintenance procedures, work practices, and records for MWT technology should be included in theMWT operations manual It should contain schedules and anticipated and actual aspects of, and impacts

to, the environment

TABLE 9.1.1 ISO 14001 Documentation Requirements with Emphasis (bold) on Elements of Particular Importance to Mixed Waste Treatment

4.2 Documented environmental policy

Records indicating communication of policy to employees

4.3.1 Procedure for identifying aspects

4.3.2 Procedure for identifying and accessing legal and other requirements

4.3.3 Documented objectives and targets

4.3.4 Documented environmental programs

4.4.1 Documented roles, responsibility, and authority

4.4.2 Procedure for identifying training needs

Records indicating communication of impact of work activities and consequences of departing from operating procedures

4.4.3 Procedure for internal communication

Procedure for external communication

Records for consideration of external communication of significant aspects

4.4.4 Information on core elements of management system

4.4.5 Procedure for controlling all documents

4.4.6 Identification of operations and activities associated with significant aspects

Procedures covering situations where absence could lead to deviations from policy, objectives, and targets Procedures related to identifiable aspects of goods and services used

4.4.7 Procedure to identify potential and response to emergency situations

4.5.1 Procedures to monitor and measure key characteristics of operation

Recording of information to track performance, relevant operational controls, and conformance to objectives and targets

4.5.2 Procedure for defining responsibility and authority for handling and investigating nonconformance,

taking action to mitigate impacts, and initiating and completing corrective and preventive action Record of any changes to documented procedures

4.5.3 Procedure to establish and maintain records

Document retention times

4.5.4 Procedure for audits

Records of audits

4.6 Records of management reviews of:

– Environmental management system

– Possible changes to policy

– Possible changes to objectives and other elements of EMS

– Audit reports

TABLE 9.1.2 ISO 9001 Documentation Requirements with Emphasis (bold) on Elements of Importance to Mixed Waste Treatment

4.1.1 Documented quality policy, objectives, and commitment to quality

Records indicating communication of policy to employees

4.1.2.1 Documented responsibility, authority, and interrelation of personnel

4.1.2.2 Identify resource requirements

4.1.2.3 Identify management representative

4.1.3 Records of management reviews of:

– Quality management system

– Possible changes to policy

– Possible changes to objectives and other elements of QMS

– Audit reports

4.2.3 Document how the quality requirements shall be met

4.3.1 Documented procedures for contract review

4.3.3 Identify how a contract is amended

4.3.4 Records of contract reviews

4.4.1 Documented procedure to control and verify design of product

4.4.2 Documented plans of design and development activity

4.4.3 Identify organizational and technical interfaces

4.4.4 Identify and document product requirements

4.4.5 Documented design output

Documented reviews of design output documents

4.4.6 Records of design reviews

4.4.7 Record of design verification

4.5.1 Documented procedure to control all documents and data

4.5.2 Documented procedure identifying current document revision status

4.5.3 Records of document and data changes

4.6.1 Documented procedure to ensure purchased product conforms to requirements

4.6.2 Records of acceptable subcontractors

4.6.3 Records of purchase documents

4.6.4.1 Records of product verification and release

4.7 Documented procedure for control of customer-supplied product

4.8 Documented procedure for identifying product receipt, delivery, and installation

Documented procedure to identify individual product or batches

4.9 Documented procedures defining manner of production, installation, servicing

Records of compliance with standards/codes, etc.

Records of process parameter monitoring and controls

Identification of requirements for any process qualifications

4.10.1 Documented procedure for inspection and testing activities

4.10.2.2 Recorded evidence of time exercised at subcontractor premises

4.10.2.3 Records of incoming product released for urgent production

4.10.5 Records providing evidence that product is inspected and/or tested

4.11.1 Documented procedure for control, calibration, and inspection of measuring and test equipment

Records of inspection for test software or comparative references

4.11.2 Identify all inspection, measuring, and test equipment

Identify process employed

Identify inspection, measuring, and test equipment calibration status

Records of calibration

Records of out of calibration

4.12 Identify inspection and test status of product

4.13.1 Documented procedure for handling nonconforming product

4.13.2 Identify responsibility for review and authority for dispositioning nonconforming product

Record of customer acceptance of nonconforming product

4.14.1 Documented procedure for implementing corrective and preventive action

Records of changes to procedures resulting from corrective and preventive action

4.15.1 Documented procedure for handling, storage, packaging, preservation, and delivery of product

4.16 Documented procedure for identifying, collecting, indexing, access, filing, storage, maintenance, and

disposition of quality records

Emergency Preparedness

Emergency preparedness is one of the elements of ISO 14001 that is unique (i.e., not part of ISO 9001).Emergency preparedness is also vitally important for MWT technology In many cases, MWT technologywill be implemented to prevent occurrence of a serious environmental consequence; and, therefore, itwill be imperative that the consequences, response, and corrective action needed when an MWT tech-nology fails to be considered and planned for Procedures should also be developed to guard against anyunintended disruption in service

According to Section 4.4.7 of ISO 14001, “The organization shall establish and maintain procedures

to identify potential for and respond to accidents and emergency situations, and for preventing andmitigating the environmental impacts that may be associated with them The organization shall reviewand revise, where necessary, its emergency preparedness and response procedures, in particular, after theoccurrence of accidents or emergency situations The organization shall also periodically test such pro-cedures where practicable.”

The effort that went into planning will be of great use here All environmental aspects and impacts ofthe mixed waste that will be treated should be considered Failsafe systems or backups should be devisedand implemented, as necessary, in case of MWT technology failure

Some local, state, and federal regulations (U.S EPA SARA Title III) may contain specific ments for accident prevention, planning, and disclosure; and, when MWT technology is implemented,these regulations will need to be consulted and incorporated into the emergency preparedness portion

require-of the integrated EMS and QMS Emergency preparation for an MWT technology accident couldinclude training, hazard evaluation, scenario development drills, and emergency system evaluation

In the United States, with the advent of local emergency planning committees (LEPCs) and stateemergency response committees (SERCs) under EPA SARA Title III, required emergency planningaffords an opportunity to involve the community and provides another avenue to impart understanding

of the value of MWT technology in meeting the environmental and equity goals of sustainabledevelopment

Checking and Corrective Action

The purpose of checking and corrective action from an EMS, QMS, and ESD perspective is threefold:

1 Monitoring and measurement This involves input, process, and output measurement, includingthe analytical and calibration techniques needed, to prevent a negative impact to the workers, thecommunity, and the environment from MWT operation

2 Identification of nonconformance for corrective and preventive action Data developed from toring and measurement will trigger action to ensure that MWT technology is operating efficientlyand reliably with expected performance

moni-3 Records Checking and corrective action activities develop performance records of MWT ogy that may be used for management review and internal or external auditing purposes

technol-TABLE 9.1.2 (Continued) ISO 9001 Documentation Requirements with Emphasis (bold) on Elements of Importance to Mixed Waste Treatment

4.17 Documented procedure for internal quality audits

Records of the internal quality audits

Records of follow-up audit activities and implementation of corrective action

4.18 Documented procedures for identifying training needs

Records of training

4.19 Documented procedure for performing, verifying, and reporting servicing

4.20.1 Identify the need for statistical techniques

4.20.2 Documented procedure to implement and control the application of statistical techniques

Monitoring and Measurement

The ISO 14001 standard, under Section 4.5.1, requires that an organization establish and maintaindocumented procedures to monitor and measure key characteristics of its operations that might have asignificant impact on the environment A similar requirement under ISO 9001 is Section 4.20, understatistical techniques, requiring the establishment, control, and verification of process capability andproduct characteristics (if needed)

Referring to the linear flow diagram for MWT technology, it is suggested that a monitoring andmeasurement program be examined and established for the following three areas:

Previous sections in this Handbook have discussed industrial waste classification and waste terization, including laboratory and in situ techniques These techniques are useful primarily in deter-mining the qualitative aspects of the mixed waste stream for QMS and EMS system input Additionalsections in this handbook describe measurement and sampling techniques, including statistical inferencesand analytical instrumentation These techniques are especially useful for quantitative monitoring ofinput, process, and output from MWT technology

charac-For MWT technology, several monitoring and measurement approaches are recommended and usefulfor tracking progress toward quality, environmental, and sustainable development goals within an inte-grated system These approaches monitor:

1 Total mass or volume of emissions to the environment per unit time Examples would be poundsper month from a MWT technology to the air, soil, or water

2 Total mass or volume of waste treated per unit of production Examples would be pounds or liters

of waste generated per unit of production or some set number of production units

3 Total mass or volume of potential waste material recycled into production or transformed intoother useful product per unit of production or some set number of production units

4 Energy consumed per mass or volume of waste treated or transformed per unit of production orsome set number of production units

The first is a direct measure of MWT technology impact on the environment; the second is an estimate

of input to MWT technology; the third is a measure of transformational capability of MWT technology,including a means to measure pollution prevention through MWT technology use; and the last is ameasure of the energy needed for MWT technology operation Setting up monitoring and measurementprocesses using some or all of these approaches can easily be used for financial analysis of MWTtechnology and provides linkage to the quality of actual production processes

The overarching question with respect to monitoring and measurement is:

Are MWT technology monitoring and measurement methods adequate to prevent a negative impact fromthe MWT operation to workers, the community, and the environment; ensure that MWT technology isoperating efficiently, reliably, and with expected quality performance; and develop records for MWTtechnology performance useful for management review and auditing purposes?

In some cases where sustainable development is approached or attained, monitoring and measurementmay actually demonstrate environmental improvement

Identifying Nonconformances and Specifying Corrective and Preventive Action

A perfectly designed and maintained system will never experience a breakdown; however, the real worldsuggests that disruptions might occur and perfect operation of a system might not be 100% Nevertheless,perfect operation should always be an ultimate goal and, guided by ISO 9001 and ISO 14001, can beapproached and attained for MWT technology The overall record of safety would likely demonstratethat MWT technology within a quality and environmental management system has an excellent perfor-mance record with few accidents and failures Earlier we discussed failsafe and backup systems as a part

of the system to prevent negative environmental impact should MWT technology fail Identifying conformances, correcting them, and instituting preventive action are the keys to ISO 9001 and ISO 14001continual improvement activities To comply with the standards, a learning organization using an ISOsystematic approach to quality and environmental protection must incorporate these processes for MWT

non-A nonconformance is the failure to comply with some criteria or standard In this case, it would bethe failure to comply with one of the numerous “shall” requirements in the ISO 9001 and ISO 14001standards A nonconformance can either be minor or major under an ISO inspection regimen A minornonconformance is some portion of the ISO 9001 and ISO 14001 systems that objective evidence wouldshow is not being followed A major nonconformance is the complete absence of one of the elements ofthe ISO 9001 and ISO 14001 standards, leading to a potential or actual breakdown in the quality orenvironmental management system It may also be a series of many minor nonconformances thatconstitutes a potential or actual breakdown If an organization is seeking or has attained ISO 9001 andISO 14001 certifications, then ensuring that nonconformances do not result when MWT technology isapplied — especially major nonconformances — becomes a critical matter

The corrective and preventive actions for both quality and environmental concerns are fairly forward in the ISO 9001 and ISO 14001 standards In short, they help in establishing a procedure forhandling and investigating nonconformities This includes assignment of responsibility, evaluation of theseverity of the problem caused by the nonconformity, determining the corrective action needed tomitigate the impacts caused, initiating and completing the corrective action, ensuring that the correctiveaction is sufficient to eliminate the cause of quality and environmental nonconformance, and recordingthe changes in procedure resulting from the corrective action

straight-MWT can be considered a subset or one of the many processes within the system that would need toconvey a corrective and preventive action procedure Some ISO registrars and companies use specificsystem corrective action forms as part of their registration process or systems For professionals respon-sible for MWT technology, the elements listed above must be satisfied — and will be with an integratedprocedure for corrective and preventive action Some of the recommendations for further reading at theend of this section supply sample forms, procedures, and letters for satisfying corrective and preventiveaction documentation requirements for the ISO 9001 and ISO 14001 standards

Records

ISO 9001 and ISO 14001 have similar requirements for records The documentation tables above (Tables9.1.1 and 9.1.2) list record-keeping requirements for these standards As mentioned earlier in this sectionsection, electronic communication greatly facilitates efficient handling of this type of information Section4.5.3 of ISO 14001 requires that an organization “establish and maintain procedures for the identification,maintenance and disposition of environmental records.” Given the MWT role as the negative environ-mental impact prevention mechanism at the end of a production process cycle, developing proceduresfor record-keeping within an ISO 14001 and ISO 9001 system is especially relevant

The overarching records question for MWT technology integration is:

Are MWT technology records adequate and complete to verify compliance with all elements of the ronmental and quality management system (ISO 9001 and ISO 14001, if applicable) and do they dem-onstrate performance toward attaining sustainability goals set forth in the policy, aspects, impacts,objectives, and targets?

envi-Note that at this point MWT technology records are linked all the way back to policy At the end ofthe workday, and during auditing and management review, a record of MWT technology performance

is useful in demonstrating that policy goals (and the MWT objectives and targets developed during theplanning process) are ultimately met Records support the claim that the procedures in the system work.Audits

Auditing for the QMS and the EMS provides a tool for integrated quality assurance, verifying thattechnical and management practices exist and are used to achieve an organization’s quality and environ-mental goals If environmental sustainability is the goal of a chosen MWT technology, the audit candetermine whether that goal is attained The audit, through examination of a process and how it operates

— alone and as part of the system — provides objective evidence that the stated quality and environmentalgoals and conformance with the ISO 9001 and ISO 14001 standards have been achieved The objectiveevidence attained through an audit is then used for the management review and continual improvementcycles described below

Two types of audits are important to MWT technology to determine its functionality within a qualityand environmental management system The first is an internal audit, or first-party audit Internal auditscan be focused on either an area or an entire system in which MWT technology operates Internal auditsare required by both ISO 9001 and ISO 14001, and a program must be in place to ensure that they occur.They are an integral part of ensuring that a chosen MWT is functioning properly within a QMS andEMS system

A third-party audit, or external audit, is the second type of audit important to MWT technology Anobjective external party always conducts this audit for ISO 9001 or ISO 14001 certification It may beconducted by an ISO registrar or a representative from another body, such as the Chemical ManufacturersAssociation (CMA), as long as that body subscribes to the Responsible Care Program

Regulatory compliance inspections, such as by EPA and OSHA authorities in the United States, areanother example of an external audit While such audits are usually focused and narrow, they areimportant to MWT technology Because ISO 14001 requires a commitment to regulatory and legalrequirements and because a procedure must be in place to identify what those requirements are, inte-grating MWT into an ISO 14001 EMS should assist in meeting these requirements

The second-party audit, or supplier audit, may be required if an external party supplies mixed wastematerial for processing For a professional MWT processing plant, this type of audit would be necessary

to evaluate consistent quality of material furnished to the MWT process by suppliers

An audit, whether internal or external, will try to establish objective evidence that what is said to bedone is, in fact, being done Objective evidence can take the forms of records, written procedures, SOPs,manuals, and policies, auditor observations, and documented/corroborated witness accounts of activities

If one subscribes to ISO 9001 and ISO 14001, Tables 9.1 and 9.2 in this section (referring to documentsand procedures most applicable to MWT technology) double as a preliminary audit checklist As men-tioned, the need for this documentation will vary with the MWT chosen and its overall place in a qualityand environmental management system, but the elements highlighted in the tables are the suggestedemphasis areas During a systems audit, the auditor must be provided with written or observable proofthat these elements are in place and functioning

Alternatively, the MWT professional should be prepared to answer an auditor’s inquiry to demonstratethat a certain element is covered by another part of the QMS and EMS system In other words, showthat a specific procedure or record is not applicable for the MWT technology or that there is a link toother aspects of the QMS and EMS system elsewhere

A good experience is to put yourself in the auditor’s place:

What would you need to see to feel confident in asserting that the MWT technology audited is a functioningand integral part of the QMS and EMS?

It is highly likely that MWT professionals will be part of internal audit teams, so this question can beanswered through experience