EMS Element 16. Problem Solving

Owner: EMS Coordinator
 Approver: EMS Core Team/EMS Management Review Team

Purpose/Overview

To define the organization's process for:

• handling and investigating Environmental Management System (EMS) nonconformance
• taking action to mitigate resulting adverse environmental impact(s) and/or consequences arising from accidents, incidents or nonconformances
• initiating and completing corrective and preventive actions and confirming their effectiveness

Definitions

• Nonconformance - failure to conform to USMC EMS Conformance Guide standards, applicable legal, and/or base requirements (e.g., operating procedures, management reviews, etc.)
• Department-level Nonconformance - a nonconformance isolated to a particular unit, area or function within MCAS Miramar. Examples could include: failure to properly train unit personnel, improper waste handling within a unit, failure to conduct environmental inspections, etc.
• System-level Nonconformance - a nonconformance which may affect multiple units, areas or functions or MCAS Miramar as a whole.  Examples could include:  Failure to achieve EMS objectives and targets, failure to follow established internal communications procedures, failure to maintain records in accordance with applicable records retention requirements, etc.
• Corrective Action - generally a reactive process used to address problems after they have occurred
• Preventive Action - generally a proactive process intended to prevent potential nonconformance before it occurs or becomes more serious; focuses on identifying negative trends and addressing them before they become significant

USMC EMS Conformance Criteria

• The installation follows a structured problem solving process that identifies and defines problems with compliance or the EMS, analyzes causes and alternative solutions, selects and implements actions, and follows up to ensure problems are solved
• The installation documents its problem solving efforts

MCAS Miramar EMS Procedure/Process Description

1. Overview of Nonconformances

1.1 Nonconformance items, as defined above, may be identified by: personnel at any level of MCAS Miramar, contractors or interested parties. Nonconformance can be system-level (e.g., ineffective management system component) or unit-level (e.g., improper storage of hazardous waste).

1.2 The scope of corrective and preventive action taken will be commensurate with the magnitude of the nonconformance and related impacts.

2. Unit-Level Nonconformance

2.1 When a unit-level nonconformance is identified, the identifier is responsible for notifying the affected Unit Environmental Coordinator.

2.2 Upon being notified of a nonconformance, the Unit Environmental Coordinator investigates the problem, identifies the root cause(s) and determines necessary corrective and preventive action to be taken.

2.3 The Unit Environmental Coordinator records the results of the investigation on the Corrective/Preventive Action Notice form and forwards the completed form to the Environmental Program Manager. The EMS Coordinator enters relevant information from the Corrective and Preventive Action Notice into the Corrective/Preventive Action Log. The EMS Coordinator uses this log to track the completion status of corrective actions.

2.4 The EMS Coordinator updates and/or revises EMS policies and/or procedures to reflect changes that result from the identified corrective/preventive action. Additionally, if the Environmental Program Manager determines that the department-level nonconformance is occurring throughout the organization, it is his/her responsibility to notify affected Unit Environmental Coordinators to implement the appropriate corrective action.

2.5 The status of corrective actions is reviewed by the EMS Core Team accordance with the MANAGEMENT REVIEW EMS element. The Environmental Program Manager reports the status of outstanding corrective actions and performance relative to resolving corrective actions to the EMS Core Team. The EMS Core Team is responsible for expeditiously resolving any deficiencies identified during these review.

3. System-Level Nonconformance

3.1 When a system-level nonconformance is identified, the identifier is responsible for notifying the Environmental Program Manager.

3.2 Upon notification of a System-level Nonconformance, the EMD Director investigates the impact(s) and root cause(s) and identifies necessary corrective and preventive action to be taken. The results of the investigation are documented on the Corrective/Preventive Action Notice Form and relevant information recorded on the Corrective/Preventive Action Log for tracking purposes.

3.3 The EMD Director responsible for implementing and communicating the corrective/preventive action to affected personnel.

3.4 The EMD Director updates and/or revises EMS policies and/or procedures to reflect changes that result from the identified corrective/preventive action.

3.5 The status of corrective actions is reviewed by the EMS Core Team in accordance with the MANAGEMENT REVIEW EMS element. The EMD Director reports the status of outstanding corrective actions and performance relative to resolving corrective actions to the EMS Core Team.  The EMS Core Team is responsible for expeditiously resolving any deficiencies identified during these review.

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