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Questionnaire Results: Federal-Mogul Corporation - page 2 / 8





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Saturn +5 ISO 14000 Pilot Project

EMS Issues

1. Does the company have what it considers a formal Environmental Management Systems (EMS) in place?

Yes. The Sparta plant is ISO 14000 certified.

  • 2.

    If not, what is the status of company efforts to develop an EMS? Not applicable.

  • 3.

    Does the company have a written EMS or a written policy statement on environmental man- agement within the company?

Yes. Federal-Mogul’s Sparta plant’s written EMS policy statement (specific to the Sparta facil- ity) is as follows:

Minimization of negative environmental impact is the responsibility of all employees and will be accomplished by:

  • Complying with all relevant environmental laws and corporate requirements.

  • Preventing pollution and eliminating waste at the source whenever feasible.

  • Recycling and reusing materials when practical.

  • Continually seeking to review and improve our adherence to these objectives.

Federal-Mogul, the parent company, also has a written corporate environmental policy state- ment (not necessarily compliant with ISO 14000) which is as follows:

Federal-Mogul is committed to a corporate policy that protects human health and the environment. Consistent with this policy, Federal-Mogul abides by all applicable envi- ronmental laws, regulations and standards. Federal-Mogul continues to maintain and improve upon programs whereby all operations achieve, or where appropriate ex- ceed, these requirements. A key component of Federal-Mogul’s environmental pro- grams is the use of pollution prevention practices.

4. Would you prefer your EMS system to be integrated with your QM system or would you prefer them to run separately? Why or why not?

Sparta’s ISO 14000 system is fully integrated with its QS9000 quality management system.

When Sparta first starting exploring the issues of becoming ISO 14000 certified, the company started down the path of keeping the systems separate. About halfway through the process, however, and after long meetings about the merits of integration versus separation, the decision was made to integrate the systems. A major concern of Sparta in considering integration was that, in theory, if a QS9000 auditor found a problem in a quality management procedure he might decide to pull certification of both the quality and environmental management systems or vice versa in the case of an ISO 14000 auditor. In other words, a problem found in an audit of one system might lead to losing certification in both systems if they are integrated. Sparta management finally decided that the likelihood of such an occurrence was remote at best. Sparta determined that one way to forestall any such problem is to take care in writing procedures for the separate systems so that a higher requirement in one system does not adversely affect an- other. (For example, QS9000 requires outside labs to certify calibration of certain equipment such as a natural gas meter. This meter also may be the same piece of equipment used to provide


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