Development and Implementation of EMS

Dr. Akepati S. Reddy School of Energy and Environment Thapar University Patiala (PUNJAB) 147 004 INDIA

Overview of the Approach

Planned to include multitude of steps (as many as 34 steps) Implemented in phases and include the following key tasks: Preparation for the development and implementation of EMS Formulating policy, setting objectives and targets and development of environmental management programs Training; development of systems programs and procedures, and operational procedures; and documentation EMS implementation and checking for
compliance with the ISO 14001 requirements conformance with the planned EMS functionality at ground level

Registration to ISO 14001

Overview of the Approach

Preparation for the development and implementation of EMS
1. 2. 3. 4. Launch meeting and nomination of Cross Functional Team (CFT) Training of the CFT Development of EMS project plan Review of the EMS project plan in the CFT and scheduling its implementation

Overview of the Approach

Phase-1:
1. Process mapping

2.
3.

Review of other management systems (like QMS, OHSMS) if already in place

Definition of views and concerns of interested parties

4.
5. 6.

Identification of applicable legal and other requirements

Identification of significant environmental aspects Review of technological options

7.
8. 9.

Setting of Environmental objectives and targets, and programs and operational controls
Scoping of EMS and formulation of Environmental Policy Management review of requirements, aspects, objectives, targets, policy and programs

Overview of the Approach

Phase-2:
1. 2. 3. 4. 5. 6. Employee awareness training Auditor Training (Internal and also Lead Auditor Training) Development of documented operational control procedures for key operations Documentation of EMS manual Internal auditing of documents against ISO 14001 requirements Management review of programs and procedures

7.

Corrective and preventive actions

Overview of the Approach

Phase-3:
1. 2. 3. Communication of responsibilities Identification of competence training needs, and scheduling and imparting competence training Creation of facilities and capabilities, and implementation of EMS programs and operational procedures

4.
5. 6.

Internal auditing of implemented programs and procedures of EMS and overall functioning of the EMS
Management review of the EMS Corrective and preventive actions

Overview of the Approach

Phase-4: ISO 14001 registration process:
1. Application for registration

2.
3. 4.

Pre-assessment auditing
Management review of the EMS Corrective and preventive actions

5.

Certification audit

0.1. Launch Meeting & Nomination of CFT

Managers of different departments can attend the meeting and the unit head can preside over it and
Objective to develop and implement EMS may be explained Facilitator/consultant hired for assisting may be introduced

Facilitator may
Explain the EMS concept and benefits of having an EMS Describe the approach that will be followed for the development and implementation of EMS Explain his own role in the process

Plants organizational setup may be described to the facilitator Unit head may nominate a Cross Functional Team (CFT) for the development and implementation of the EMS and its roles and responsibilities may be described Definition of roles and responsibilities of the CFT Employees of the unit may be issued a memorandum by the unit head

0.2. Training of the CFT

Objectives behind this training can be
to make the CFT aware of EMS concept, EMS approach for managing environmental obligations, and requirements of ISO 14001 standard to provide information on the assistance available from various sources for the development and implementation of EMS

Aspects to be covered in the training can be

EMS approach to industrial environment management Overview of ISO 14000 series of standards and their relevance Requirements of ISO 14001 Books, Literature, Guidance manuals, web sites, etc. for providing assistance in the implementation of EMS

0.3. Development of EMS project plan

Can be prepared by the facilitator
Tasks involved in the EMS project may be identified and divided into groups for implementation in a phased manner

For each of the task the following details may be worked out
Brief description of the task Time required for implementing the task Responsibilities and means/resources for implementing the task Prerequisites for taking up the task

Sequencing and scheduling of the tasks, and suggesting the time required for completing the EMS project

0.4. Review of the EMS Project Plan

The project plan may be reviewed by the CFT for
assessing feasibility and practicability of implementing the EMS project finalizing the implementation schedule finalizing roles and responsibilities of developing and implementing the EMS project and communicating them to the concerned working out procedure for making available of needed resources

1.1. Process Mapping

Meant primarily for identifying Environmental Aspects Activities Involved are Nominating process mapping team (PMT), defining responsibilities and providing process mapping training Development of first level process map of the plant Division of target processes into sub-processes for draft process maps development (supervisors jurisdiction!) Supervisor training on the development of draft process maps Development of draft process maps & their peer review Review of draft process maps for identifying additional information/data and clarifications required Collection of necessary primary and secondary data Finalizing As Is Process Maps and documentation Resources and time are required - sampling and analysis of different inputs and outputs may be needed

1.2. Review of other management systems that are in place

The review is supposed to help in ensuring
Compatibility of EMS with other management systems Integration of EMS with other management systems (wherever feasible)

Procedures and programs remain simple

Facilitator of the CFT may carryout the and MR of the QMS may assist the facilitator

1.3. Definition of Views and Concerns of Interested Parties

Identifying the interested parties whose views are important to the organization Development and implementation of procedure for obtaining information from the interested parties and defining their views and concerns

Views and concerns of at least the Employees, Management and Key customers of the plant may be considered
Defined views and concerns of interested parties may be documented and considered in setting the objectives and targets

1.4. Identification of Applicable Legal and Other Requirements

Development of procedure
For the identification and ensuring access to the legal requirements, and for interpreting the requirements For the obtaining information on the other requirements to which organization subscribes

Identification of sources of information on the legal requirements and on the other requirements Application of the procedures and identifying the legal and other requirements applicable to the organization Documenting and communicating the requirements to appropriate function and level

1.5. Identification of Significant Environmental Aspects

Development of procedure for
Identification of environmental aspects (process mapping information) Identification and evaluation of impacts Identification of significant environmental aspects

Application of the procedure for identifying significant environmental aspects while using the following inputs
Process mapping information Applicable legal and other requirements Views and concerns of interested parties

Documentation of the information on environmental aspects and their evaluation for significance

1.6. Review of Technological Options

Technological options review is a continuous process Review of technologies and management practices and procedures will be limited to SEAs of the plant Develop a program for the technical review and implement
Involve identification of sources of information on technologies and management practices and procedures

Document the outcome of the review

1.7. Setting of Environmental objectives and targets, and programs and operational controls
Use following as basis for setting the objectives and targets
significant environmental aspects applicable legal and other requirements views and concerns of interested parties Technological options Organizations financial, operational and business requirements

Document the objectives and targets and also the programs and operational controls to be employed for achieving them

1.8. EMS Scoping and Environmental Policy Formulation

CFT can define the scope of the EMS Draft an environmental policy that conforming to ISO 14001 requirements in the light of
Applicable legal and other requirements Significant environmental aspects Views and concerns of interested parties Policies of other management systems and higher level environmental policy (if any)

Draft policy can be circulated for review before finalizing and signing by the top management

1.9. Management Review-1

Review is meant to ensure that
The tasks implemented are in compliance with ISO 14001 requirements All activities and operations are considered in identifying SEAs Environmental legislation and regulations are comprehensively reviewed for identifying the legal requirements Views and concerns of interested parties are obtained and defined Technological options, and management practices and procedures are sufficiently reviewed Due consideration is given to the following while formulating environmental policy and setting objectives and targets All SEAs and all applicable legal and other requirements Views and concerns of interested parties The programs and the operational controls are appropriately chosen for achieving the objective and targets

2.1. Employees Awareness Training

Awareness training may cover all employees including employees of contractor Training procedure can include training of a selected group of employees by the facilitator who in-turn may train all the employees

2.2. Auditor Training

Lead auditor training
MR and his deputization may be given this training External agency may be approach for providing the training

EMS internal auditor

A team of personnel from different departments/functions may be trained External agency may be employed for imparting the training

Records of training may be maintained

2.3. Development & Documentation of procedures for operational controls

Document procedures for operational control for all the identified key operations wherever documented procedures are need
Procedures should stipulate operating criteria Should also cover the SEA of goods and services used

Communicate the procedures

2.4. Documentation of EMS Manual

Facilitator and M/S of CFT may be made responsible for the documentation EMS document should include
Description of core elements of EMS and their interactions Direction to the related documentation

EMS document can be annexed with other essential documents of the EMS

2.5. Internal Auditing of Documents against ISO 14001 Requirements

Internal auditors will conduct the audit and MR (who is also M/S) will coordinate the auditing exercise

Objectives of auditing include

Assessment of compliance of the documents with the requirements of ISO 14001 Assessment of the programs and procedures and other arrangements for their sufficiency to achieve the objectives and targets and to implement environmental policy

2.6. Management Review-2

(Documented) operational control procedures of key operations Internal audit reports will be key inputs Implementing the decisions and recommendations of management review

2.7. Corrective and preventive actions

Implementation of the Developed Procedures and Programs

Implementation of the procedures and programs requires Communication of roles, responsibilities and authorities Making available of documented procedures/ work instructions at all places where they are needed Identifying and providing the training needed Creation and maintenance of the necessary records identified in the procedures and programs Creation of requisite infrastructure (including monitoring and control devices) Making arrangements for the calibration and maintenance of the facilities (specially monitoring and control devices)

24. Communication of Responsibilities

Employees of entire plant are involved in the development, implementation and maintenance of EMS Everyone of the plant should know his specific role and responsibility relating to EMS Systems programs and procedures, and SOPs and SWPs include definition of responsibilities CFT will compile and document roles and responsibilities and authorities of key personnel of the plant: CEO, EMR and Cross Functional Team Heads of different departments, areas and functions Leaders of programs like internal audits, teams like emergency preparedness and response team, and others M/S or EMR may ensure communication of responsibilities EMR will ensure communication of responsibilities defined in different procedures and programs to all relevant personnel Overlap of roles, responsibilities and authorities will be identified, documented and ambiguities will be removed Communication of responsibilities will be simultaneous to the development of programs and procedures Time required for compiling and communicating responsibilities of key personnel: one week

25. Competence Training

Every employee should Know his role and responsibilities in the development, implementation and maintenance of EMS Have competence to play his role and fulfill his responsibilities Competence requires a combination of education, training and experience Competence can be ensured through Employing personnel with necessary education and experience Identifying training needs, providing training and tracking the training Areas of competence training required On the systems programs and procedures CFT in consultation with the facilitator will identify the training needs Facilitator will provide the training On the methods and skills required for performing the tasks that have significant environmental impacts Departmental heads will identify and regularly evaluate training needs of the employees within the department Evaluate the training received and maintain training records (employee name, job description, training required and training imparted)

25. Competence Training (contd..)

Training coordinator or EMR in consultation with the departmental heads will decide on The method of training , the level and detail of the training to be provided The training plan, program and schedule The resource persons for the preparation of training material and imparting training CEO and CFT will provide the resources needed for providing the training needs identified Training may be Training of new employees Refresher training Training of employees as and when his tasks or the work instructions are changed Audit programs will ensure that the training program is implemented and effective Time required: Training on the systems programs and procedures requires about one months time Training related to the tasks is a continuous process

26. Creation/development of Needed Facilities and Capabilities

Major activities associated with are Creation and maintenance of the necessary records identified in the procedures and programs Creation of requisite infrastructure (including monitoring and control devices) Making arrangements for the calibration and maintenance of the facilities (specially monitoring and control devices) Assessment and identification of the resources (including time) required for creating/developing the facilities/capabilities
The person directly responsible for implementing the program/ procedure and head of the area/function may be responsible

CEO may make available of the needed resources

CFT may review the identified and assessed resource needs Sanctions and approvals needed for the development or for procurement/creation, installation and commission

Department head may ensure creation/development of the needed facilities/ capabilities MR may ensure implementation of each of the procedures and programs and report in this regard to the CFT & management Time required: 3 to 4 months

27: Internal EMS Audit

EMS audit Part of the management review process through it the management indicates its interest in EMS to employees Concerned with system and not with employees supposed to constructive and helpful to employees A snap shot in time EMS audit objectives: systematic, objective and documented evaluation of EMS for determining compliance of the implemented EMS with EMS documentation Requirements of ISO 14001 reporting audit findings (non-conformances and observations) in the form of audit reports and raising corrective and preventive action requests Observation - not a non-conformance but presence or absence of a practice that can either strengthen or weaken the EMS Non-conformance not meeting the ISO 14001 requirements or not complying with the planned arrangements for environmental management can be major and minor non-conformances

27: Internal EMS Audits (contd..) Activities Involved

Preparing for audit Defining objectives and scope Obtaining managements support and commitment of resources Identifying audit team leader, appointing audit team and training of the team Preparing audit plan and schedule/time table Preparing audit materials (checklists/protocols, reporting sheets, questionnaires, etc.) Communicating audit plan to audit team, management and employees Conducting preliminary document review Conducting audit Opening meeting Tour of the site Conducting closing meeting Follow-up activities Prepare and submit audit report to management Develop corrective and preventive action plans and time frames Following up the corrective and preventive action requests

27: Internal EMS Audits (contd..)

MR of EMS may ensure conducting the audit obtains necessary sanctions and approvals from CEO and ensures availability of needed resources for conducting the audit select audit team leader and, in consultation with him, the other team members ensures action on the corrective/ preventive action requests sends the audit report for review by the CFT decides on the corrective and preventive action requests to be referred for review by the CFT keeps track of the corrective and preventive actions being implemented reports the management at regular intervals on audit findings and conclusions status of actions taken against corrective/ preventive action requests maintains records of the EMS audit (auditors, audit schedule, audit procedures and audit findings)

27: Internal EMS Audits (contd..)

Audit team conducts the audit Audit team leader, in consultation with other members and MR, will prepare plan and schedule for the exercise collect, analyze and document evidences for supporting the audit findings Obtain evidences through visual observations, document review and interviews with employees presents audit findings and conclusions (non-conformances and observations) as audit report to the MR Uses closing meeting for discussing the findings with the auditee representatives and raising corrective/ preventive action requests CFT reviews audit findings and refer some of the corrective/ preventive action requests to the corrective/preventive actions review system Procedures and guidelines in place for internal EMS audit will be used in conducting the exercise

28. Management Review-3

Act part of the systems PDCA cycle Essential for continuous improvement of the EMS Management should determine who will be involved in the management review process and when it will be conducted MR of the EMS may ensure that the information needed for the management review is furnished Audit results (EMS audit and compliance audits) Progress on achieving the EMS objectives and targets Environmental performance of the plant Reports on EH&S incidents/accidents/emergencies Internal suggestions, external communications and views and concerns of the interested parties Changes in the operations & activities and products & services of the plant New scientific/technological data on materials and processes Changes in the legal and other requirements applicable Status reports on the implementation of corrective and preventive action requests Results of action items of previous management review

28. Management Review-3 (contd..)

Conducting management review meeting Documented procedure may be followed Agenda of issues to be included in the review may circulated Minutes of the review meeting may be prepared and circulated to all attendees and individuals who are assigned with action items Attendees Summary of key issues discussed Action items (decisions and recommendations) emerged Management review should Fine tune the EMS Identify deficiencies of the EMS and assess functioning of the EMS Make necessary changes to the policy, objectives and other elements of EMS for removing deficiencies and improving EMS Allocate additional resources wherever needed Decisions and recommendations of the management review should be documented and communicated and their incorporation into the EMS should be ensured by the MR Action items arising from review should be tracked, acted upon and reported to the management by the MR

29. Corrective & Preventive (CP) Actions

For taking care of deficiencies and problems identified with the implemented EMS
CP action process to be used for completing CP actions Raising of CP action requests and entering into a CP action database
Database is meant for preparing, managing and tracking CP action requests Requester raises a CP action request Coordinator checks appropriateness, maintains the database, identifies recipient and assigns CP action requests Decision on due date for completion and allocation of additional staff and financial and other resources required

Resolving CP action requests and implementing

Analyses root causes, identifies appropriate CP actions, documents and communicates implementation of the CP actions Incase of overdue reviewing CP action request and fixing new due date

29. Corrective & Preventive (CP) Actions (contd..)

CP action process (contd..)
Verification of the implemented CP actions for effectiveness Coordinator and requester to verify the effectiveness Reissue of CP action request in case of ineffectiveness Closing of CP action request Incorporating needed changes into related documented procedures and implementing

Responsibilities
MR of the EMS will be coordinator Requester can be auditor or lead auditor, or any employee, or any person from other interested parties Environment manager or manager of the affected department will be the recipient CFT and CEO for reviewing selected CP action requests, overdue of solutions reports and completed CP action requests and for allocating resources needed Top management for reviewing summary of completed CP action requests in the management review meetings

ISO 14001 Registration Process

Key players in the registration process
Firm which has implemented EMS and applying for registration Registrar or Registration Body accredited by a national level accreditation body firm has option to select a registrar grants certificate of registration after assessing firms EMSs in accordance to ISO 14001 registration program, if Conforming with the requirements of ISO 14001 standard Conforming with the firms own policies and procedures Conforming with the requirements of registration program Accreditation body a country may have a national level registrar accreditation body awards accreditation to registering bodies if meeting the prescribed criteria

ISO 14001 registration process involves:

Making application to the registrar Pre-assessment audit, if opted by the firm Stage-1 registration assessment (document review or audit) Stage-2 of registration assessment (certification audit) Certification/registration and maintenance of registration and continuous assessments (surveillance audits)

ISO 14001 Registration Process (contd..)

Using Registered Firm Mark (RFM) & Accreditation Body Mark (ABM)
Registered firms are entitled provided they accept the conditions prescribed for using ABM a written consent from the registration body required AFM can be used only on correspondence, advertizing and promotional material in conjunction with RFM RFM and AFM should not be used for misleading or in unacceptable manner In case of non-conformance with requirements of registration program, firm should discontinue use of RFM Prior to making any significant changes to EMS the firm should notify registrar in writing and registrar should conform in writing Registrars representatives should visit the firm at least once a year and firm should give access to them Audit team members should follow the criteria for confidentiality, conflict of interest and ethical standards Registrar and his representatives should not disclose any information unless it is in the public domain or it is required by law Effective dates for the changes made to Registration Program should be notified and sufficient time should be given for amending EMS

Rights and responsibilities

30. Application for Registration

Firm selects and contacts the registrar and requests for information on registration and application forms preliminary information form, EMS checklist, etc. Firm may go for self-assessment of its readiness for registration (EMS checklist sent by registrar can be used) Sends filled preliminary information form and applications for registration to the registrar Registrar reviews the submitted preliminary information and filled applications and
Sends his quote for ISO 14001 registration/certification Recommends pre-assessment audit, id needed and if the firm has already not requested for it

Signing agreement for the registration process Registrar timely intimates names of audit team and facilitates firms appeal against appointment of any of the auditors

31. Pre-assessment Audit

Voluntary and optional service of registrar Involves evaluation of firms EMS against ISO 14001 requirements Not meant for assessing (firms) EMS eligibility for registration Results are submitted as report for appropriate corrective and preventive actions against the non-conformances Can be used to perform functions related to stage-1 of registration audit
Determining firms readiness for registration audit Explaining mechanics, structure and requirements of registrars ISO 14001 registration program Understanding firms EMS and its scope of registration; environmental aspects of the firm and site specific characteristics; applicable legal requirements; technical expertise required for registration audit, etc.

If gap between pre-assessment and registration audits is large separate stage-1 of registration audit is required

34. Certification/Registration Audit/Assessment

Carried out in accordance to requirements of Registrars own ISO 14001 registration program Objective to determine whether the EMS is implemented as intended by the firm and in accordance with ISO 14001 ISO 14001 standard requirements Firms own policies and procedures Requirements of the ISO 14001 registration program RAB identifies two stages in registration assessment Stage-1: Planning process for registration assessment Concerned with planning for stage-2 audit/assessment gaining understanding about the EMS in the context of firms significant environmental aspects gauging firms preparedness for stage-2 of registration audit
having fully operational EMS for minimum specified period Completion of at least one full cycle of EMS including effectiveness evaluation through management review Fully operational EMS audit process and its effectiveness evaluation through management review Completion of one EMS audit cycle completion and verification of significant number of CP action requests

34. Certification/Registration Audit/Assessment: Stage-2

Stage-1: Planning process for registration assessment (contd..) Includes document/desk audit and technical review/ site visit Stage-1 of the assessment supports decision regarding eligibility of the firms EMS stage-2 of registration assessment Taken up 6 weeks to 6 months before the stage-2 assessment Stage-2: On-site registration assessment/audit Concerned with evaluation and verification through objective evidence collection to show that the EMS is conforming to the requirements of ISO 14001 firms own policies, objectives and procedures requirements of the ISO registration program of the registrar On the basis of the assessment The firm is provided with an assessment report and corrective action requests Assessment report, including recommendations related to eligibility of the firm for registration, is submitted to registrar Regulatory non-compliances, if found, are handled and reported as per the methods prescribed by the registrar

34. Certification/Registration Audit/Assessment: Registration

Registrar reviews the assessment teams report and takes decision regarding issue of certificate of registration
In case of major non-conformances, partial or full reassessment is suggested prior to registration
Firm should respond to corrective action requests within the timeframe decided (submit corrective actions and/or milestone plans; and complete and verify action requests) In the event of recommendation of full reassessment, no time frame is fixed and no need for the firm to respond

In case of only minor non-conformances, these are resolved through correspondence and registration is granted
actions for correcting non-conformances can be verified during subsequent continuous assessments

Finding a regulatory non-compliance does not mean automatically failed audit

Can be recommended for registration if the EMS is addressing the non-compliance and if the non-compliance is not a major non-conformance with ISO 14001 requirements

Maintenance of Registration
Requires continued adherence to the requirements of registrars ISO 14001 registration program Registration is maintained on the basis of continuous assessments or surveillance audits satisfactory resolving of the corrective action requests responding directly to registrar regarding the action requests within the timeframes decided by registrar Firms can opt the following options for continuous assessments 3 year registration cycle yearly surveillance audit each covering 1/3 to of the total EMS reassessment of the EMS every 3rd year 2 year registration cycle six monthly surveillance audit each covering 1/4th of the EMS covering the total EMS over the 2 year period Biannual reassessment option reassessment of the total EMS Requests for expansion of scope of registration to other operations/ activities or to other standards Require a scope expansion assessment/audit either independently or in conjunction with a surveillance audit

Maintenance of Registration (contd..)

Suspensions or withdrawals of registration and refusal of renewal of registration
Non-conformance with ISO 14001 standard or with the requirements of ISO 14001 registration program Using Registered Firm Mark in unacceptable and misleading manner Violation of signed agreement with the registrar Non-conformance with corrective action requests (not meeting timeframes in responding, ineffectiveness in resolving requests Firm requesting for withdrawal of registration

In case of disagreements with the registrars decisions regarding registration the firm can prefer appeals
Appeals are disposed as per the procedures prescribed in the ISO 14001 registration program of the registrar Decisions relating to appeals can be brought to the accreditation bodys attention if appeals are not handled as per the procedure

Flow scheme of activities towards ISO 14001 registration

27-10-03 Review of existing QMS (1 week) Development of EMS project plan (1 week) 2

27-10-03 Definition of views & concerns of interested parties (3 weeks) (6-10-03) Process Mapping (3 weeks)

Launch Meeting (1 day)

Nomination of CFT (1 week)

EMS implementation training for CFT (1 day)

Review & scheduling of EMS project plan (2 days)

17-11-03 Identification of significant environmental aspects (3 weeks)

27-10-03 Identification of Legal & other Requirements (2 weeks)*

* One day training on legal requirements

Flow scheme of activities towards ISO 14001 registration (contd..)

2

12-01-04 Lead auditor training (1 week)

09-02-04 Internal EMS auditor training (1 week)

22-12-03 Setting of environmental objectives & targets (1 week)

29-12-03 Scoping of EMS & formulation of environmental Policy (2 weeks)

12-01-04 Development of EMPs (3 weeks)

02-02-04 Management Review-1 (1 day)

8-12-03 Review of 3 tech.options (Continual process)

12-01-04 Employee awareness training 3 weeks)

Flow scheme of activities towards ISO 14001 registration (contd..)

5-04-04 Communication of responsibilities (1 week) 5 12-04-04 Competence training (3 weeks) 19-04-04 Corrective and preventive actions (2 weeks) 9-02-04 Development of SOPs & SWPs (4 weeks) 4 9-02-04 Development of EMS programs & procedures (8 weeks) 29-03-04 Documentation Of EMS manual (2 weeks) 08-03-04 Creation/development of Facilities/capabilities (12 weeks)

12-04-04 Internal auditing (document audit) (1 week)

19-04-04 Management review-2 (1 day)

Flow scheme of activities towards ISO 14001 registration (contd..)

6 26-04-04 Application for ISO 14001 Registration (2 weeks) 10-05-04 Adequacy Audit (2 weeks) 24-05-04 Management review-3 (1 day) 8 31-05-04 Internal EMS Audit-2 (1 week) 07-06-04 Corrective and preventive actions (2 weeks)

28-6-04 Corrective and Preventive Actions (2 weeks)

7-06-04 Management Review-4 (1 day) 7

21-7-04 Total internal Audit (1 week)

28-06-04 Management Review-5 (1 day)

12-07-04 Certification Audit (1 week)

ISO 14001 registration