EMS Internal Audit #3x

Executive Summary To: MSD Directors, EMS Core Team Members From: EMS Internal Auditors Date: July 27, 2009 Subject: Third Internal EMS Audit Findings The Environmental Management System’s (EMS) Internal Auditors conducted their Third Internal EMS Audit June 15-18, 2009. The objective of the internal audit was to evaluate the EMS, how it conforms to the National Biosolids Partnership (NBP) Environmental Management System for Biosolids, to provide suggestions for improvement and to prepare the system for the third party audit. The results of the audit found the following nonconformances, as they relate to the Elements set forth by the National Biosolids Partnership. Element 1 – EMS Manual Major Nonconformance 01  Waste Management is currently performing biosolids related duties without a contract in place. Therefore, EMS responsibilities have not been documented. Element 2 – EMS Policy Major Nonconformance 02  The EMS Policy has not been communicated to all employees or contractors with biosolids related responsibilities. Element 3 – Critical Control Points Major Nonconformance 03  Operational controls and environmental impacts at some critical control points need further development.  Critical control points have not been reviewed or updated on a quarterly basis. Element 4 – Legal and Other Requirements Minor Nonconformance 01  A procedure for tracking or incorporating new changes in legal or other requirements has been ...