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Corporation - EMS
Audit Report
Re-certification
This report and all its content is confidential and remains the property of Intertek.
Report issued at 19:21 GMT on 05-Jan-2017
Audit Summary Report
Scope of certification:
ISO 14001:2004:
Design, Development and Manufacture of Mechanical Locks, Keys, Latches and Electro-Mechanical Security Products
for Vehicle Manufacturers, Precision Die Castings and Assemblies.
Exclusions from scope:
No exclusions
Page 1 of 15
Audit Summary Report
Executive Summary
Management Support
Resources
Strengths Housekeeping on the outside of the plant
Documentation Process
Page 2 of 15
Audit Summary Report
Management Mature
Consistent evidence of management commitment, customer and/or interested party satisfaction, knowledge/awareness of policy and
objectives being demonstrated by the majority of staff. Responsibility and authority is evident and supported via data, trends and related
KPI¶s. Management reviews are complete and demonstrate support by the majority of personnel. Records are complete and demonstrate
positive trends in improvement and lessons learned.
Internal audits are being performed at planned intervals and are based on status and importance of the Management System. Data is
being collected on regular basis. Audit teams are trained, impartial and objective in their approach. Audit reports are clear, concise with
respect to content. Actions are being taken as a result of audit findings and timely responses are provided.
The corrective/preventive action process meets the minimum requirements as defined by the standard. Data does exist from such sources
such as customer and/or interested party complaints, internal audits, warranty analysis, defects, internal metrics and supplier performance.
The process includes a review of the effectiveness of the actions taken. There is evidence of problem solving tools being used to support
the process.
Data streams are being used as sources to drive continual improvement over time. These may include management system policy,
objectives, and audit results, analysis of data, CAPA and management reviews.
Operational Controls are planned and developed. Planning is consistent with many of the other Management processes. Objectives,
process requirements, needs for appropriate additional documents and resources, verification and monitoring activities and records
requirements have been determined, as appropriate. Processes and activities run consistently. Some data is collected to verify the
adequacy of operational controls with evidence of some improvement trends.
Resources Mature
Resources required for the effective maintenance and improvement of the management system have been defined and deployed.
Improvements have been noted in areas such as customer and/or interested party satisfaction, continual improvement, and process
variation. Levels of competency have been defined and documented within the existing management system.
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Audit Summary Report
Finding Summary
Major Minor
Issued during current activity Zero (0) Seven (7)
Closed from previous activities Zero (0) Two (2)
Page 4 of 15
Audit Summary Report
Review of Finding from Previous Intertek Audit: Reviewed findings from the previous Intertek audit and confirmed the findings
were both accepted in iEnable and the evidence viewed during this audit ensure these findings have been properly closed
and corrective actions have been effectively implemented.
Finding: DR-1
Procedures are not being followed in all cases
Requirement:
Establishing, implementing and maintaining a documented procedure(s) to control situations where their absence could lead
to deviations from the environmental policy, objectives and targets, and
Stipulating the operating criteria in the procedure
Objective Evidence:
Aerosol can puncturing unit was not labeled correctly. No information was filled out on the label.
Conclusion: Based on a review of CAPA Form and a well written Root Cause, Correction appropriate to the finding, a viable
Corrective/Preventive Action which should prevent the reoccurrence of the finding and Verification activities which confirm
effectiveness along with evidence provided Cliff Seltrecht, Maintenance Supervisor. The Containment Action was to complete
label and affix it to the container, Root Cause spoke to understanding labeling Requirements, Long Term Corrective Action
was to conduct Annual Refresher Training, Larry Thimmesch (Maintenance Supervisor), with Verification/Validation being site
walks conducted by Maintenance Supervisor. Additionally, viewed Hazardous and Universal Training for three associates
dated December 7, 2015.
Finding: DR-2
All elements of the standard are not covered in management review
Requirement:
Input to management reviews shall include
Results of internal audits and evaluations of compliance with legal requirements and with other requirements to which the
organization subscribes,
The extent to which the objectives and targets have been met
Objective Evidence:
Objectives and Targets were noted in management review but if they were met or if they fell short was not discussed.
Conclusion: Based on a review of CAPA Form and a well written Root Cause, Correction appropriate to the finding, a viable
Corrective/Preventive Action which should prevent the reoccurrence of the finding and Verification activities which confirm
effectiveness along with an Immediate Corrective Action of updating the Objectives and Targets Matrix, Root Cause
Objectives and Targets Matrix did not have a means to demonstrate the status of completion. Verification of Effectiveness
included viewed revised EMS Objectives & Targets Matrix with a ³STATUS´column now included. Additional Verification of
Effectiveness is the completed form for the FY 2016
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Audit Summary Report
Finding Detail
Finding #: Audit Criteria: Audit Criteria Corrective Action Corrective Action
Ref#: Plan Date: Implementation Date:
NC 1 of 7 SC ISO 14001:2004 4.3.1 02-Dec-2016 16-Dec-2016
Issued by: Classification: Document Ref#: Action Required:
Steven Ciaverilla Minor 4.3.1 Submit Corrective Action Plan
Finding:
The procedure established to ensure organization identifies the environmental aspects of its activities products and services
is not fully implemented.
Requirement:
4.3.1 Environmental aspects
a) to identify the environmental aspects of its activities, products and services within the defined scope of the environmental
management system that it can control and those that it can influence taking into account planned or new developments, or
new or modified activities, products and services, and
b) to determine those aspects that have or can have significant impact(s) on the environmental (i.e. significant environmental
aspects).
The organization shall ensure that the significant environmental aspects are taken into account in establishing, implementing
and maintaining its environmental management system.
Objective Evidence:
Universal Waste has not been identified as an environmental aspect.
Refrigerants have not been identified as an environmental aspect.
Groundwater Remediation of TCE
Finding justification
N/A
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Audit Summary Report
Finding:
The procedure established to ensure legal requirements to which the organization subscribes are taken into account in
maintaining its environmental management system, is not effective in all cases.
Requirement:
4.3.2 Legal and other requirements
a) to identify and have access to the applicable legal requirements and other requirements to which the organization
subscribes related to its environmental aspects, and
The organization shall ensure that these applicable legal requirements and other requirements to which the organization
subscribes are taken into account in establishing, implementing and maintaining its environmental management system
Objective Evidence:
Universal Waste has not been identified as a legal requirement
Refrigerants have not been identified as a legal requirement
The organization has identified its air permit as Title V when it is Non-Title V permit
Finding justification
N/A
Page 7 of 15
Audit Summary Report
Finding:
The procedure established to ensure legal requirements to which the organization subscribes including waste management
and labelling requirements are taken into account in maintaining its environmental management system, is not effective in all
cases.
Requirement:
4.3.2 Legal and other requirements
a) to identify and have access to the applicable legal requirements and other requirements to which the organization
subscribes related to its environmental aspects, and
The organization shall ensure that these applicable legal requirements and other requirements to which the organization
subscribes are taken into account in establishing, implementing and maintaining its environmental management system
Objective Evidence:
Two five gallon buckets of Universal Waste Batteries were found unlabeled and undated.
Two Universal Waste Lamps were found leaning against an I-beam adjacent to the containers
Containers were found open and unlabeled including paint and solvent being managed by a contractor, a five gallon bucket
adjacent to a bench grinder and drums of oily rags.
The label found affixed to all Universal Waste containers both batteries and lamps incorrectly indicates ³THIS WASTE IS
NOT REGULATED BY THE U.S. ENVIROMENTAL PROTECTION AGENCY´
Finding justification
N/A
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Audit Summary Report
Finding:
The procedure established to ensure the Top Management reviews the organization¶s environmental management system at
planned intervals including all required Inputs, is not fully implemented.
Requirement:
4.6 Management review
Top management shall review the organization¶s environmental management system, at planned intervals, to ensure its
continuing suitability, adequacy and effectiveness. Reviews shall include assessing opportunities for improvement and the
need for changes to the environmental management system, including the environmental policy and environmental objectives
and targets. Records of the management reviews shall be retained.
a) results of internal audits and evaluations of compliance with legal requirements and with other requirements to which the
organization subscribes,
g) changing circumstances, including developments in legal and other requirements related to its environmental aspects, and
The outputs from management reviews shall include any decisions and actions related to possible changes to environmental
policy, objectives, targets and other elements of the environmental management system, consistent with the commitment to
continual improvement.
Objective Evidence:
The organization¶s last Management Review conducted December 2, 2015 did not contain the following inputs and their
subsequent outputs:
Finding justification
N/A
Page 9 of 15
Audit Summary Report
Finding:
The procedure established to ensure receiving, documenting and responding to relevant communication from external
interested parties is not fully implemented.
Requirement:
4.4.3 Communication
With regard to its environmental aspects and environmental management system, the organization shall establish, implement
and maintain a procedure(s) for
a) internal communication among the various levels and functions of the organization,
b) receiving, documenting and responding to relevant communication from external interested parties.
The organization shall decide whether to communicate externally about its significant environmental aspects, and shall
document its decision. If the decision is to communicate, the organization shall establish and implement a method(s) for this
external communication.
Objective Evidence:
The organization has not maintained its process for recording external communications regarding regulatory matters on the
EMS Inquiry and Response Log specified in Section 5.3 of Strattec procedure E43L2M001, Communications.
Finding justification
N/A
Page 10 of 15
Audit Summary Report
Finding:
The procedure created to ensure person(s) performing tasks for it or on its behalf that have the potential to cause a significant
environmental impact(s) are competent on the basis of appropriate education, training or experience is not effective in all
cases.
Requirement:
4.4.2 Competence, training and awareness
The organization shall ensure that any person(s) performing tasks for it or on its behalf that have the potential to cause a
significant environmental impact(s) identified by the organization is (are) competent on the basis of appropriate education,
training or experience, and shall retain associated records.
The organization shall identify training needs associated with its environmental aspects and its environmental management
system. It shall provide training or take other action to meet these needs, and shall retain associated records.
The organization shall establish, implement and maintain a procedure(s) to make persons working for it or on its behalf aware
of
a) the importance of conformity with the environmental policy and procedures and with the requirements of the environmental
management system,
b) the significant environmental aspects and related actual or potential impacts associated with their work, and the
environmental benefits of improved personal performance,
c) their roles and responsibilities in achieving conformity with the requirements of the environmental management system,
and
Objective Evidence:
Job # 431 Plating and Waste Treatment Utility Person, which is highly related to significant environmental aspects of the
plating operation is not included in the Strattec Training Needs matrix.
Finding justification
N/A
Page 11 of 15
Audit Summary Report
Evidence Summary
The state of the management system is summarized below:
Process for Monitoring and Maintaining Compliance with Legal and Other Requirements
4.3.2 Legal and other requirements: Within the Environmental Manual the organization has created section 4.3.2 Legal and Other
Requirements which commits to fulfilling the requirements of the international standard and where it points to Appendix 2 which lists its
Legal and Other Requirements procedure E32L2M001.
The procedure states that it ensures access to legal requirements via websites including EPA, DNR, MMSD (Means the Milwaukee
Metropolitan Sewage District) OSHA and DOT. Other Requirements consist of Customer Requirements along with its ISO 14001:2004
certification. Additionally, the organization has created its Compliance Calendar-Legal and Other Requirements matrix where it lists its
legal requirements along with its when it needs to address the requirements and lastly when the it has completed the last evaluation of
compliance for its identified legal and other requirements.
Note in a review of the M-WI-Compliance Calendar-Legal &Other Requirements E32L2M001 under the SSC Compliance Calendar tab it
references ³Title V´permit when the permit is not a Title V but Facility Operation Permit.
Currently the organization is a LQG, Universal Waste (Lamps/Batteries, Mercury Switches, No Used Oil, One UST for Oily Water, SPCC
Plan, SWPP Plan (General Permit), Air Permit (1) Minor Sources, Tier II (copper, H2SO4, Nickel), no Form R, Wastewater Pretreatment
(w/treatment of pH/Metals), POTW for sanitary.
As the matrix does not identify refrigerants nor universal waste as legal requirements, the matrix references the air permit as Title V when it
is not, nor does the matrix list the organization¶s other requirements and only mentions ³customer requirements´in the procedure, a minor
nonconformance has been cited. Note, the organization does recognize customer requirements as being IMDS and its ISO 14001
certification. The organization utilizes the third party ³Universal Waste Bill of Lading´as its means to track how long Universal Waste
Lamps are stored on site. Viewed the Veolia Bill of Lading indicating that Universal Waste Lamps were shipped from the site on June 22,
2016.
Other than the one minor nonconformance being cited above, based on the evidence provided during the audit which supports the
requirements of the International Standard are being met, having no NOV¶s cited in the past year along with the organization¶s policy and
commitments, the procedure to identify and have access to legal and other requirements appears to be effectively implemented.
4.5.2 Evaluation of compliance: Within the organization Environmental Manual the organization the organization has created section 4.5.2
Evaluation of Compliance for the purpose of ensuring a procedure to periodically evaluate and document compliance with legal and other
requirements that are applicable to our activities and products.
Though the section points to the Appendix 2, for related documents, the Appendix 2 does not contain the M-WI-Compliance Calendar-Legal
&Other Requirements E32L2M001 document.
Concerning the M-WI-Compliance Calendar-Legal &Other Requirements E32L2M001 an excel document which in the last column indicates
when the most recent evaluation of compliance has been completed, due to several legal requirements not having been evaluated within
the certification cycle and therefore not being able to ensure the process of evaluation of compliance is effective for both its legal and other
requirements, a minor non-conformance has been cited.
Other than not having fully evaluated compliance for both its legal and other requirements, based on the evidence provided including
records of Evaluation of Compliance to both its legal and other requirements along with the periodicity the organization commits to and
completes an evaluation, the procedure appears to be effectively implemented.
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Audit Summary Report
Note, in section 5.5 the organization commits to meeting Quarterly to review and update the procedure of its aspects as well as its
objectives and the Target Matrix, however, these meetings have not been occurring per the interval described in the procedure.
Additionally, due to the organization not having identified refrigerants nor universal waste as an environmental aspect along with not
conducting quarterly reviews as required per the procedure; a minor non-conformance has been cited.
Other than the one minor non-conformance described above, based on the process established to identify the environmental aspects of its
activities, products and services including those aspects that have or can have a significant impact on the environment; the procedure
appears to be effectively implemented.
Review the results of previous audits and the performance of the management system over the
certification if last surveillance of the cycle
A review of previous audits in conjuncture with evidence reviewed and documented during the course of the audit including but not limited
to the core requirements of continual improvement, managing change, obeying applicable laws and pollution prevention, indicates the
organization¶s Environmental Management System is trending in a positive direction.
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Audit Summary Report
Page 14 of 15
Audit Summary Report
The nonconformity(ies) identified do not jeopardize the certification of the management system. Continued certification is
therefore recommended pending acceptance of the corrective action plans(s) for identified nonconformity(ies).
Client Acknowledgement
Management Scott Taylor
Representative Strattec Security Corporation
Name & Address: 3333 W. Good Hope Road
Milwaukee, Wisconsin 53209
This report is based on a sample of evidence collected during the audit; therefore the results and conclusions include an Page 15 of 15
element of uncertainty. This report and all its content is subject to an independent review prior to a decision concerning the
awarding or renewal of certification.
Appendix 2.0
2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015
Solid Waste (tons) 207.26 168.69 127.39 103.90 102.00 98.54 83.87 61.44 219.82 74.74 86.61 38.5 80.99 75.98
Hazardous Waste (tons) 140.96 140.03 102.55 53.82 56.28 33.41 35.66 21.53 27.67 36.39 53.81 33.32 62.55 38.3
Gas useage (1000 dekatherms) 128.00 73.81 71.70 71.36 64.90 72.39 70.52 53.27 53.94 57.94 56.93
Fiber Recycle (tons) 45.89 40.60 38.82 61.94 61.00 59.40 52.56 48.78 35.64 73.06 31.00 15.45 39.54 38.60
Water (X 1,000,000 gallons) 37.63 27.98 27.62 21.82 18.80 19.67 15.86 14.57 18.04 13.62 11.14 11.64 13.40 13.68
Air Emissions (tons) 21.72 20.50 18.80 17.75 17.69 17.52 19.87 19.88 22.86 7.22 7.44 8.73 9.07 7.55
Electric useage (million kWh) 22.76 20.54 17.90 15.62 13.84 13.98 12.57 12.14 14.06 15.69 16.31 17.15 17.10 17.88
Energy related Emissions x (100
tons) 242.88 189.74 172.24 167.88 166.58 195.43 207.39 203.88 213.15 214.80 222.65
2002
Environmental Performance (MKE)
2003
2004
205.00
2005
2006
2007
105.00
2008
2009
5.00
2010
2011
2012
2013
2014
Appendix 2.1
Page1 of 1
2007 work hours 2008 work hours 2009 work hours 2010 work hours 2011 work hours 2012 work hours 2013 work hours 2014 work hours 2015 work hours
totals 1,201,009 totals 848,820 totals 654,226 totals 761,294 totals 766,959 totals 752,236 totals 789,318 totals 852,944 totals 869,481
Solid Waste (pounds / man hour) 197,093 0.164 167,740 0.198 122,880 0.188 439,640 0.577 149,480 0.195 173,220 0.230 77,000 0.098 161,980 0.190 151,960 0.175
Hazardous Waste (pounds / man hour) 66,820 0.056 71,320 0.084 43,060 0.066 55,340 0.073 72,780 0.095 107,620 0.143 66,640 0.084 125,100 0.147 76,600 0.088
Gas useage (dekatherm / man hour) 71,710 0.060 71,360 0.084 64,902 0.099 72,390 0.095 70,520 0.092 53,270 0.071 53,940 0.068 57,940 0.068 56,933 0.065
Fiber Recycle (pounds / man hour) 118,800 0.099 105,120 0.124 97,560 0.149 71,280 0.094 146,120 0.191 62,000 0.082 30,900 0.039 79,080 0.093 77,200 0.089
Water (1,000 gallons man hour) 19,670 0.016 15,860 0.019 14,570 0.022 18,040 0.024 13,620 0.018 11,140 0.015 11,641 0.015 13,399 0.016 13,676 0.016
Air Emissions (pounds / man hour) 35,040 0.029 39,740 0.047 39,760 0.061 45,720 0.060 14,440 0.019 14,880 0.020 17,460 0.022 17,460 0.020 15,100 0.017
Electric useage (1,000 kWh / man hour) 13,980 0.012 12,570 0.015 12,140 0.019 14,060 0.018 15,690 0.020 16,310 0.022 17,150 0.022 17,100 0.020 17,878 0.021
Energy related Emissions x (tons / man hour) 16,224 0.014 16,788 0.020 16,658 0.025 19,543 0.026 20,739 0.027 20,388 0.027 21,315 0.027 21,480 0.025 22,265 0.026
0.025
0.000
Solid Waste Hazardous Waste Gas useage Fiber Recycle Water (1,000 gallons Air Emissions Electric useage Energy related
(pounds / man hour) (pounds / man hour) (dekatherm / man (pounds / man hour) man hour) (pounds / man hour) (1,000 kWh / man Emissions x (tons /
hour) hour) man hour)
FY 2018
Content Revision C (08/17)
Page 1 of 2
Maintain FY 2016
Maintain target average electric kW / labor hour QOS kWh
consumption Implement conservation procedures. average tracker Jun-18 S. Taylor
install nozzles
and auto shut off
Implement air conservation projects. on 10 presses Implementation Jun-18 S. Taylor
Outside reclaim
Part quality improvements, dross reduction, reduction over vs purchase
Reduce die cast reclaim rate zinc reclaim segregation improvements previous year tonnage. Jun-18 B. Becker
reduction over
Product shipping Reduce premium freight previous year KPI review Jun-18 A. Gerstmeier
Meetings,
Communicate EMS benefits and cost savings signage,
Communication from projects. instructions Implementation Jun-18 A. Gerstmeier
Return To: N/A M-WI-EMS Objectives and Targets Matrix.xlsx Min.Retention: Life of System
Storage/Archive: Livedocs Owner/Disposal: Env. Eng. Verify current Content/Template Revision
Uncontrolled document when printed SAQ2.0 QMS/EMS RECORD Template Rev. C (12/15)
FY 2018
Content Revision C (08/17)
Page 2 of 2
COST
Return To: N/A M-WI-EMS Objectives and Targets Matrix.xlsx Min.Retention: Life of System
Storage/Archive: Livedocs Owner/Disposal: Env. Eng. Verify current Content/Template Revision
Uncontrolled document when printed SAQ2.0 QMS/EMS RECORD Template Rev. C (12/15)