Cheyenne Drilling, LP

ISO 14001

ENVIRONEMNTAL MANAGEMENT PROGRAM

1.0 Purpose

This written ISO 14001 Environmental Management System (EMS) is a set of procedures meant to promote these benefits:

• Improved environmental performance,

• Reduced liability,

• Competitive advantage,

• Improved compliance,

• Reduced costs,

• Fewer accidents,

• Employee involvement,

• Improved public image,

• Enhanced customer trust, and

• Better access to capital.

For Cheyenne Drilling, it makes good business sense to have an effective EMS. In this way, we make the environment an organizational priority. Not only management but employee involvement is crucial. We encourage everyone at our company to think about the environment as part of product and process development and look at problems as opportunities.

The ISO 14001 Standard has been used as a model for our EMS. The ISO 14001 Standard is the widely accepted official international standard for environmental management systems.

2.0 Scope

This procedure applies to all Cheyenne Drilling operations and construction sites where nickel-cadmium and other batteries, certain pesticides, or mercury-containing thermostats no longer serve their intended purpose and must be discarded. This program is intended to minimize the hazards to human health or the environment from improper disposal of these wastes in landfills or disposal facilities.

The HSE Manager is responsible for developing and maintaining this program and ensuring its compliance with applicable regulatory guidelines. In addition, the HSE Manager is responsible for maintaining records of universal waste management. Drilling Managers over their responsible locations may assist in the documentation and submission of waste management reporting documentation.

ISO 14001 Environmental Management Systems

Cheyenne Drilling, LP Scope of Application

ISO 14001 Environmental Management Systems; Specification with Guidance for Use is a standardized, auditable set of procedures that your company can use to implement your environmental policies and to obtain certification of conformance through national or international registration certification systems. Certified conformance to the system standard may eventually become a requirement for international trade.

ISO 14001 is the one standard out of the ISO 14000 series to which you can choose to certify your environmental management programs. As ISO 14000, overall, is a voluntary set of standards, you can also choose to implement ISO 14001 without seeking certification. For example, you can implement ISO 14001 and self-declare that you comply with the standard. Otherwise you can implement it and have your environmental management system audited by a customer, based on an earlier contractual agreement.

Cheyenne Drilling, Inc. has found it helpful to have written ISO 14001 Environmental Management Systems in order to obtain certification that in turn will help:

· Provide access to international markets, particularly in instances where companies require that their suppliers be certified, and

· Help reduce wastes that would otherwise end up in the environment.

Use of this checklist helped determine how Cheyenne Drilling, LP would benefit from written ISO 14001 Environmental Management Systems.

1.0 References and Overview of EMS

14001 Environmental Management Systems

ISO 14000 is a series of voluntary environmental management standards and guideline reference documents, developed through the International Organization for Standardization (ISO) since 1993, which will help organizations of any size and level of environmental performance establish an environmental management system or improve an existing one.

The standards and guideline reference documents cover environmental management systems (EMS), eco-labeling, environmental auditing, life cycle assessment, environmental performance evaluation, and environmental aspects in product standards. The focus on management distinguishes these standards from performance standards. The standards, in their basic structure, are derived partially from the ISO 9000 quality management standards.

EMS helps an organization to establish and meet its own policy goals through objectives and targets, organizational structures and accountability, management controls and review functions all with top management oversight. EMS does not set requirements for environmental compliance nor do these standards establish requirements for specific levels of pollution prevention or performance. The Environmental Management Systems specification document calls for environmental policies that include a commitment to both compliance with environmental laws and pollution prevention.

The ISO standards do not directly require environmental compliance nor do they establish specific performance levels. Instead, the standards will guide an organization through the essential steps of implementing an environmental management system, including:

· Developing internal commitment and an environmental policy.

· Establishing objectives and targets.

· Implementing the system through organizational structures and accountability.

· Measuring and evaluating progress.

· Review and continuous improvement.

ISO 14001: The Centerpiece of the Standards

At the heart of the ISO 14000 series are two standards: ISO 14001 Environmental Management Systems; Specification with Guidance for Use, which contains the core auditable elements of an EMS program, and the broader companion standard, ISO 14004, Environmental Management Systems - General Guidelines on Environmental Management Principles, Systems and Supporting Techniques. These two standards were adopted and published in September 1996.

Other published standards in the series are:

· ISO 14010, Guidelines for Environmental Auditing; General Principles of Environmental Auditing;

· ISO 14011, Guidelines for Environmental Auditing; Audit Procedures, Auditing of Environmental Management Systems; and

· ISO 14012, Guidelines for Environmental Auditing; Auditor Qualifications

International Scope.

These standards are expected to be embraced by the international community, and U.S. businesses that seek to maintain or develop international markets will very likely be required to become certified. The focus of these new standards will be on integrating environmental management decision making into existing management systems.

As companies have become more and more integrated into a world market, there has been concern that businesses in countries with more stringent environmental regulations face a competitive disadvantage. ISO 14000 attempts to address these concerns by establishing a uniform set of standards agreed upon by the international business community.

The International Organization for Standardization (ISO)

ISO is a private international standards body based in Geneva, Switzerland. Founded in 1947, ISO promotes the international harmonization and development of manufacturing, product, and communications standards through its technical committees. More than 8,000 ISO standards have been promulgated, for everything from paper sizes to film speeds. More than 120 countries belong to ISO as full voting members, including the United States. The official U.S. representative to the ISO is the American National Standards Institute (ANSI), located in New York.

How to Participate

· The process of developing the ISO 14000 standards is completely open and any interested party may participate. Industry, government, small and medium-sized businesses, academia and environmental groups currently make up the U.S. Technical Advisory Group (TAG) membership.

ANSI’s Role

The American National Standards Institute (ANSI) maintains policies and procedures for the development, review and coordination of voluntary standards that are designated as American National Standards. However, ANSI is not a standards developer. ANSI, headquartered in New York, is the official U.S. member body to ISO, and its membership derives from organizations, companies, and government agencies.

Status of ISO 14000 Standards

The following outline shows the different subcommittees or work groups under the ISO 14000 standards initiative (referred to as TC-207) and the standards they are currently developing:

· Subcommittee 1 - Environmental Management Systems (EMS)

- Objective: To establish standards for setting environmental policy, objectives, and responsibilities and to implement them through planning, measures of effectiveness and control of environmental impact.

- ISO 14001 Environmental Management Systems; Specification with Guidance for Use (published and adopted)

- ISO 14004 Environmental Management Systems; General Guidelines on Principles, Systems, and Supporting Techniques (published and adopted)

· Subcommittee 2 - Environmental Auditing

- Objective: To standardize environmental auditing and related environmental investigations.

- ISO 14010 Guidelines for Environmental Auditing; General Principles of Environmental Auditing (published and adopted)

- ISO 14011 Guidelines for Environmental Auditing; Audit Procedures, Auditing of Environmental Management Systems (published and adopted)

- ISO 14012 Guidelines for Environmental Auditing; Auditor Qualifications (published and adopted)

· Subcommittee 3 - Environmental Labeling

- Objective: To develop standard terminology, definitions, symbols, test methods, test summary, and reporting standards.

- ISO 14020 Environmental Labeling; Guiding Principles for Environmental Labeling Programs (committee draft status)

- ISO 14021 Environmental Labeling; Self-Declaration Claims (committee draft status)

- ISO 14024 Environmental Labeling; Guiding Principles for Practitioner Programs (committee draft status)

· Subcommittee 4 - Environmental Performance Evaluation

- Objective: To develop guidance for evaluating environmental effects of products and services and the effect of business operations on the environment.

- ISO 14031 Environmental Performance Evaluation (draft not available)

· Subcommittee 5 - Life-Cycle Assessment

- Objective: To develop standardized programs for analyzing environmental impacts of products, processes and services during their life cycle, including the production and utilization of raw materials, manufacturing practices, distribution methods and options related to disposal or recycling.

- ISO 14040 Life-Cycle Assessment (committee draft status)

· Subcommittee 6 - Terms and Definitions

- Objective: To standardize terminology and coordinate use of standards with other committees within ISO.

- ISO 14050 Terms and Definitions (committee draft status)

· Workgroup 1 - Environmental Aspects in Product Standards

- Objective: To develop guidance for use by other technical committees for including environmental elements in existing or forthcoming product standards.

- ISO 14060 Environmental Aspects in Product Standards (committee draft status)

WRITTEN ELEMENTS

Our ISO 14001 Environmental Management Systems consist of these 18 elements:

· Purpose

· Environmental Policy

· Environmental Aspects

· Legal and Other Requirements

· Objectives and Targets

· Environmental Management Program

· Structure and Responsibility

· Training, Awareness, and Competence

· Communication

· EMS Documentation

· Document Control

· Operational Control

· Emergency Preparedness and Response

· Monitoring and Measurement

· Nonconformance and Corrective and Preventive Action

· Records

· EMS Audit

· Management Review

WHY DEVELOP A WRITTEN PLAN?

The written ISO 14001 Environmental Management System (EMS) is a set of procedures meant to promote these benefits:

· Improved environmental performance,

· Reduced liability,

· Competitive advantage,

· Improved compliance,

· Reduced costs,

· Fewer accidents,

· Employee involvement,

· Improved public image,

· Enhanced customer trust, and

· Better access to capital.

It makes good business sense to have an effective EMS. In this way, you make the environment an organizational priority. Not only management but employee involvement is crucial. Encourage everyone at your company to think about the environment as part of product and process development and to look at problems as opportunities.

2.0 Environmental Management Program

EMS FORM 1(A)

ENVIRONMENTAL RISK IDENTIFICATION PROCEDURE

Purpose/Scope

The purpose of the EMS Risk Identification Procedure is to identify activities performed by Cheyenne Drilling, LP within the scope of the Environmental Management System, and to identify environmental risks associated with these activities

Key Responsibilities

HSE Manager – Manages annual review sessions with operations and management personnel to identify Cheyenne Drilling activities and associated environmental risks. Receives information on changes in activities performed, and modifies the EMS to account for new or changed activities (as needed). The HSE Manager also shall maintain a current list of all work activities and associated environmental risks.

Drilling Manager – Each Drilling Manager shall be responsible for identifying and providing staff from operational departments to participate in the annual review of work activities and associated environmental risks. Drilling Managers shall also alert the HSE Manager when there are changes in work activities and/or environmental exposure risks.

Procedure

Identification of Activities & Risks

In order to perform adequate environmental exposure risk assessment for Cheyenne Drilling work activities, Cheyenne Drilling shall conduct an annual work session facilitated by the HSE Manager which will identify all work activities. Environmental risks associated with each activity shall also be identified during the annual work session. Special attention shall be paid to the identification of each waste stream from all each work activity. The activities and risks shall be recorded on the Environmental Risk List (Form 1b) of the EMS program.

(MOC) Management of Change

When new activities are added to Cheyenne Drilling operations, or existing activities change, the Drilling Managers shall notify the HSE Manager of these changes. The HSE Manager shall update the Environmental Risk List based on any changes made, and shall evaluate/communicate any other changes needed in the EMS.

Key Documents / Reference

· Environmental Risk List (Form 1b)

Structure and Responsibility

EMS FORM 2(A)

IDENTIFICATION OF LEGAL REQUIREMENTS

Purpose/Scope

The purpose of this document is to define the procedure for recognizing applicable legal requirements, identifying associated compliance tasks, and for modifying the list of requirements and tasks when work operations or legal requirements change. This procedure also identifies how Cheyenne Drilling, LP maintains access to legal requirements (laws & regulations).

Key Responsibilities

HSE Manager – Identifies applicable legal requirements based on an understanding of work activities performed by Cheyenne Drilling, LP. The HSE Manager maintains a list of applicable requirements and tasks in the Compliance Matrix (Form 2b) of this program. The HSE Manager shall be responsible for identifying changes in legal requirements (regulatory changes) and shall keep the Compliance Matrix as up to date as possible.

Drilling Manager – Each Drilling Manager shall be responsible for identifying and alerting the HSE Manager where there are changes in work activities that could change legal requirements of this program. Drilling Managers shall also notify the HSE Manager when changes in contractual requirements occur

Procedure

Identification of Legal Requirements & Compliance Tasks

The HSE Manager identifies legal requirements and tasks applicable to Cheyenne Drilling, LP operations. Legal requirements include federal, state and local laws & regulations. In addition, enforceable agreements, agency orders, permits and contractual requirements are included in such legal requirements definitions. Applicable legal requirements and compliance tasks are listed in the Compliance Matrix (Form 2b) of this program.

Access to Legal Requirements and Compliance Tasks

Cheyenne Drilling, LP maintains access to current legal requirements through regulatory agency internet web sites, print publications, and service subscriptions to compliance management services. Copies of applicable permits associated with Cheyenne Drilling, LP operations are maintained in the appropriate office, located at either Woodward, Oklahoma; Garden City, Kansas; and Ft. Worth, Texas.

(MOC) Management of Change

When new activities are added to Cheyenne Drilling operations, or existing activities change, the Drilling Managers shall notify the HSE Manager of these changes. The HSE Manager shall review compliance data through internet websites, publications, subscription services and online referrals to evaluate whether changes are needed in the EMS program and to ensure that all Cheyenne Drilling, LP operations are in compliance with federal, state and local environmental regulations. A review of these regulations and the EMS Program shall be conducted by the HSE Manager on a minimum of a quarterly basis.

Key Documents / Reference

· Compliance Matrix (Form 2b)

Training, Awareness and Competence

Every employee can have an impact on the environment and any employee can have good ideas about how to improve environmental management efforts. For these reasons, our training program casts a wide net. Our training objectives are as follows:

EMS FORM 3(A)

ROLES AND RESPONSIBILITIES

Purpose/Scope

The purpose of the EMS Risk Identification Procedure is to identify activities performed by Cheyenne Drilling, LP within the scope of the Environmental Management System, and to identify how assigned responsibilities are communicated to Cheyenne Drilling personnel.

Key Responsibilities

HSE Manager – Maintains EMS procedures and the compliance matrix, including role and responsibility assignments. The HSE Manager also provides employees with information regarding the EMS program and its contents, including responsibilities of each employee.

Drilling Manager – Each Drilling Manager shall be responsible for communicating and implementing the EMS program and its policies. Drilling Managers shall oversee contractor work to ensure compliance with the EMS program, and will take necessary action to make changes when needed. Drilling Manager shall alert the HSE Manager when there are changes in activities that could change environmental risks or applicable legal requirements.

Employees – Employees are responsible for understanding Cheyenne Drilling’s environmental policy and the EMS program and its components. Employees shall learn the environmental risks associated with each work activity. Employees are also responsible for reporting any potential non-compliance events or environmental incidents which may occur.

Procedure

Assignment of EMS and Compliance Roles & Responsibilities

EMS roles and responsibilities are defined and documented in each of the EMS procedures. Compliance roles are identified in the Compliance Matrix (Form 2b).

Assignments Communicated

EMS and compliance roles and responsibilities are clearly communicated to employees during initial job assignment and orientation and through annual EMS training sessions. The EMS procedures and the Compliance Matrix are distributed during initial employee assignment and at training sessions.

Assignments Updated

EMS and compliance roles and responsibilities are reviewed and updated as necessary to reflect assignment changes. Assignments are also reviewed annually as part of the annual EMS audit.

(MOC) Management of Change

When new activities are added to Cheyenne Drilling operations, or existing activities change, the Drilling Managers shall notify the HSE Manager of these changes.

Key Documents / Reference

· Compliance Matrix (Form 2b)

Operational Control

EMS FORM 4(A)

ROLES AND RESPONSIBILITIES

Purpose/Scope

The purpose of this document is to define the procedure for establishing and implementing operational controls with Cheyenne Drilling, LP’s operations. Operational controls are developed and implemented to comply with legal requirements and to address key environmental risks and potential emergency response activities.

Key Responsibilities

HSE Manager – Maintains a list of controls identified in the Compliance Matrix. Changes the list when a new or modified control is identified by Drilling Managers. Assists Drilling Managers in maintaining consistent and technically correct control methods, and in developing emergency response procedures.

Drilling Manager – Assist in developing and maintain controls for activities performed at their locations, including controls for compliance obligations and emergency response procedures. Notify the HSE Manager when control titles or procedures are modified, and ensure all personnel follow control methods.

Employees – Follow all identified controls. Alert supervisors if controls appear out-of-date or are not functional for any reason. Update control methods as requested.

Procedure

Identify & Maintain Controls

Controls are developed and implemented at the operational level to translate legal requirements to field operations and to address key environmental risks and potential emergency response actions.

Controls in Place

Controls are identified by title for each compliance task. Tracking of the legal requirements and the controls in the compliance matrix provides a clear explanation from specific environmental compliance obligations to associated field controls.

Cheyenne Drilling, LP may also require use of specific controls. In the event a client requires use of specific controls, these controls will also be identified on the compliance matrix and included in training programs.

Waste Management Procedures

Waste management procedures are one type of control developed by Cheyenne Drilling, LP. Waste management procedures applicable to each location include, but are not limited to…

· Cheyenne Drilling, Inc. corporate waste management procedure

· Waste determination identification

· Site specific list of waste streams and haz/non-haz classifications

· Container management and inspections

In addition, some Cheyenne Drilling clients require the use of the client’s waste management procedures. In the event a client requires use of client waste management procedures, the HSE Manager shall review and compare procedures to ensure client procedures are at least as stringent as those of Cheyenne Drilling.

Emergency Response Procedures

Each Cheyenne Drilling facility and/or location shall have an emergency response plan that includes at least an annual test drill and review process. In the event a client requires use of client emergency response procedures, the HSE Manager will review and compare procedures to ensure client procedures are at least as stringent as those of Cheyenne Drilling. If the client procedures are acceptable, the site specific plans may be modified to include the information required by the client emergency response procedures.

Communication

Effective environmental management requires effective communications. Communications will help Cheyenne Drilling:

• Motivate the workforce;

• Explain the environmental policy (both internally and externally) and how it relates to the overall business vision/strategy;

• Ensure understanding of roles and expectations;

• Demonstrate management commitment;

• Monitor performance; and

• Identify potential system improvements.

Effective internal communications require mechanisms for information to flow top-down and bottom-up. Since employees are on the "front lines," they are often an excellent source of information, issues, and ideas.

Communicating with external parties is also important for effective environmental management. Obtaining the views of neighbors, community groups, and customers, among others, will help our company understand how we are perceived by others. Information from external sources can be critical in setting environmental and other business goals.

EMS Documentation

To ensure that our EMS is well understood and operating as designed, we need to get information to the people doing the work. In addition, there are external parties that might need to understand how our EMS operates, such as customers, registrars, regulators, lending institutions, and the public.

A "road map" of our EMS explaining how the pieces fit together can be a very useful tool. EMS documentation can be viewed as a series of explanations or statements of how EMS criteria (such as ISO 14001) apply to our company. EMS documentation is related to (but not the same as) EMS records. EMS documentation describes what our system consists of (i.e., what we do), while EMS records demonstrate that our company is doing what it said it would do. EMS records are described later in this EMS.

Document Control

People in the Cheyenne Drilling, LP organization use various documents (drawings, work instructions and the like) as they perform their duties. To ensure that our personnel are consistently doing the job right, Cheyenne Drilling provides them with the right tools. In this case, the tools needed are the correct and up-to-date procedures, drawings and other documents. Without a mechanism to control EMS documents, we’d have no way of knowing (or verifying) that people are working with the right tools.

To ensure that everyone is working with the proper EMS documents, our organization has a procedure that describes how documents are controlled. This procedure ensures that:

• EMS documents can be located,

• They are periodically reviewed,

• Current versions are available where needed, and

• Obsolete documents are removed.

Operational Control

To ensure that our environmental policy is followed and that our objectives are achieved, certain operations and activities must be controlled. Where an operation or activity is complex and/or the potential environmental impacts are significant, these controls should take the form of documented procedures. Procedures can help our company to ensure regulatory compliance and consistent environmental performance. Procedures can also play a key role in employee training.

Documented procedures cover those situations where the absence of procedures could lead to deviations from the environmental policy or our objectives and targets. Determining which operations should be covered by documented procedures and how those operations should be controlled is a critical aspect of developing an effective EMS.

To keep track of what procedures are needed, we use the following method(s):

Operational Control

Purpose/Scope

The purpose of this document is to define the procedure for establishing and implementing operational controls with Cheyenne Drilling, LP’s operations. Operational controls are developed and implemented to comply with legal requirements and to address key environmental risks and potential emergency response activities.

Key Responsibilities

HSE Manager – Maintains a list of controls identified in the Compliance Matrix. Changes the list when a new or modified control is identified by Drilling Managers. Assists Drilling Managers in maintaining consistent and technically correct control methods, and in developing emergency response procedures.

Drilling Manager – Assist in developing and maintain controls for activities performed at their locations, including controls for compliance obligations and emergency response procedures. Notify the HSE Manager when control titles or procedures are modified, and ensure all personnel follow control methods.

Employees – Follow all identified controls. Alert supervisors if controls appear out-of-date or are not functional for any reason. Update control methods as requested.

Procedure

Identify & Maintain Controls

Controls are developed and implemented at the operational level to translate legal requirements to field operations and to address key environmental risks and potential emergency response actions.

Controls in Place

Controls are identified by title for each compliance task. Tracking of the legal requirements and the controls in the compliance matrix provides a clear explanation from specific environmental compliance obligations to associated field controls.

Cheyenne Drilling, LP may also require use of specific controls. In the event a client requires use of specific controls, these controls will also be identified on the compliance matrix and included in training programs.

Waste Management Procedures

Waste management procedures are one type of control developed by Cheyenne Drilling, LP Waste management procedures applicable to each location include, but are not limited to…

· Cheyenne Drilling, Inc. corporate waste management procedure

· Waste determination identification

· Site specific list of waste streams and haz/non-haz classifications

· Container management and inspections

In addition, some Cheyenne Drilling clients require the use of the client’s waste management procedures. In the event a client requires use of client waste management procedures, the HSE Manager shall review and compare procedures to ensure client procedures are at least as stringent as those of Cheyenne Drilling.

Emergency Response Procedures

Each Cheyenne Drilling facility and/or location shall have an emergency response plan that includes at least an annual test drill and review process. In the event a client requires use of client emergency response procedures, the HSE Manager will review and compare procedures to ensure client procedures are at least as stringent as those of Cheyenne Drilling. If the client procedures are acceptable, the site specific plans may be modified to include the information required by the client emergency response procedures.

Emergency Preparedness and Response

Despite Cheyenne Drilling’s best efforts, the possibility of accidents and other emergency situations still exists. Effective planning and preparation can reduce injuries, protect employees and neighbors, reduce asset losses and minimize production downtime.

Our Emergency Preparedness and Response Plan include provisions for:

• Assessing the potential for accidents and emergencies;

• Preventing incidents and their associated environmental impacts;

• Plans/procedures for responding to incidents;

• Periodic testing of emergency plans/procedures; and

• Mitigating impacts associated with these incidents.

Consistent with our organization’s focus on continual improvement, Cheyenne Drilling reviews emergency response performance after an incident has occurred. This review can help determine if more training is needed or if emergency plans/procedures should be revised.

Each Cheyenne Drilling facility and/or location shall have an emergency response plan that includes at least an annual test drill and review process. In the event a client requires use of client emergency response procedures, the HSE Manager will review and compare procedures to ensure client procedures are at least as stringent as those of Cheyenne Drilling. If the client procedures are acceptable, the site specific plans may be modified to include the information required by the client emergency response procedures.

A copy of the Emergency Response Plan procedures may be obtained in the Cheyenne Drilling, LP HSE Manual, Part 7.

Monitoring and Measurement

An EMS without an effective monitoring and measurement program is like driving at night without the headlights on—you know that you are moving, but you can’t tell where you are going. Monitoring and measurement enables our company to:

• Gauge its environmental performance;

• Analyze root causes of problems;

• Identify areas where corrective action is needed; and

• Improve performance/increase efficiency.

In short, monitoring helps the company manage its business better. Pollution prevention and other strategic business opportunities are identified more readily when current and reliable data is available.

Nonconformance and Corrective and Preventive Action

Our EMS will also need to change as our company changes and grows. When system deficiencies are encountered, our company will need a process to ensure that:

• Problems (including nonconformities) are investigated;

• Root causes are identified;

• Corrective actions are identified and implemented; and

• Corrective actions are tracked and documented.

EMS nonconformities and other system deficiencies should be analyzed to detect patterns or trends. Identifying these trends will allow you to anticipate and prevent future problems.

Focus on correcting and preventing problems. Preventing problems is generally cheaper than fixing them after they occur (or after they reoccur). This approach is consistent with the continual improvement philosophy.

Management Review + System Audits + Corrective Action = System Improvement

Records

The value of records management is fairly simple—we are able to prove that our company is actually implementing the EMS as designed. While records have value internally, over time we may need to provide evidence of EMS implementation to external parties (such as customers, a registrar, or the public). Records management is often viewed as bureaucratic, but it is hard to imagine a process or system operating consistently without keeping accurate records.

Management Review

Just as a person should have periodic physical exams, our EMS is reviewed by management from time to time to stay "healthy." Management reviews are the key to continual improvement and to ensuring that the EMS will continue to meet our company’s needs over time.

Management reviews also offer a great opportunity to keep our EMS efficient and cost-effective. For example, some organizations have found that certain procedures and processes initially put in place were not needed to achieve their environmental objectives or control key processes.