NQA EMS Handbook
74
t: 08000 522 424 e: [email protected] w: nqa.com Managing your environmental footprint guide to implementing an environmental management system
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handbook for ISO 14001
Transcript of NQA EMS Handbook
t: 08000 522 424 e: [email protected] w: nqa.com
Managing yourenvironmental footprint
guide to implementing an environmental management system
Introduction to environmental management systems (EMS) 2
Benefits of implementing an EMS 5
Correspondance with other standards 6
How to use this guide 8
Definitions 9
Principles of ISO 14001 12
Initial Environmental Review 14
Environmental management system elements 17
4.1 - General requirements 17
4.2 - Environmental policy 18
4.3 - Planning 22
4.4 - Implementation and operation 38
4.5 - Checking 53
4.6 - Management review 62
Registration to environmental management systems 65
Reference list 70
Contents
The concept of environmental management within businesshas evolved rapidly in recent years and pressure is beingplaced upon organisations more and more to mitigate anyadverse impact that their business may have on theenvironment, when this is further enforced by stringentenvironmental legislation, it makes it increasingly difficult toignore such issues.
In a climate of increased media and public scrutiny, organisationsof all sizes are now looking to formal management systems as aframework for improving performance.
The concept of environmental management systems (EMS)has spread across the world and through all sectors.
Many early environmental management systems were developed alongside quality management and took on many of the characteristic elements of the quality standard,ISO 9001. However, these systems were often developed ‘in-house’ and did not independently demonstrate that organisations were doing what they stated in their policy statements. This led to the creation of some of the first standardised environmental systems.
However, it was not until 1992 that a nationally-recognisedand universally-applicable standard was produced. This was published by the British Standards Institute and entitled BS 7750 Specification for Environmental ManagementSystems. It also took a quality systems approach toenvironmental management and was centred on the Deming Cycle - plan, do, check and act. The standard also allowed,for the first time, external and independent assessment of the system to ensure organisations met the requirements of the standard.
As the world’s first environmental management standard, BS 7750 raised considerable interest in the United Kingdom,but more importantly, in many other countries around the
world. This eventually led to calls for an internationally-recognised standard. The International Organisation forStandardisation (ISO) responded to these demands bysetting up a working group to develop a new set ofenvironmental standards (the ISO 14000 series), which couldbe implemented by all types of organisations, regardless oftheir activity or location.
The European Commission also responded to the increasedinterest in environmental management systems by developingthe Eco-Management and Audit Scheme (EMAS), for manufacturing companies within the European Union.
ISO 14001
In 1996, the first of the international EMS standards (ISO14001 and ISO 14004) were published. These standards laiddown specifications and guidance for the development of an environmental management system, which could be auditedand certified by independent certification bodies. These standards eventually superseded BS 7750 in the UK.
The adoption of the international environmental managementsystem (EMS) standard ISO 14001 can be a complementarydevice for adhering to the extensive environmental legislativerequirements and bring benefits to businesses, which include aprofitable difference to the bottom line.
On 15th November 2004, the revision process of ISO14001:1996 was completed and ISO 14001:2004 waspublished. The changes to the standard were aimed atmaking it more user friendly and to clarify some of therequirements. It also brings it into line with some of theclauses with ISO 9001:2000.
ISO 14004:2004 Environmental Management Systems –General guidelines on principles, systems and supporttechniques was also published on 15th November 2004.
Introduction to Environmental Management Systems
3
ISO 14001 is now the most widely-used environmentalmanagement standard in the world. The ISO Surveyreported that, as of December 2005, there were over 6,055organisations certified in the UK and an estimated 111,162worldwide in 138 countries. These figures are set to increaseas many more companies realise the considerable benefitsthat can be gained from taking a more systematic approachto environmental improvement.
BS 8555/ Acorn
In 2003, a new environmental management system standardwas published. BS 8555 enables environmental managementsystems (EMS) to be accessible to all and the IEMA AcornScheme allows recognition for implementation and operationat certain phases. BS 8555 provides guidance on how totackle environmental performance evaluation andimprovement, it makes EMS simple and easy. BS 8555 is titledEnvironmental management systems – Guide to the phasedimplementation of an environmental management systemincluding the use of environmental performance evaluation.
It seeks to provide guidance for all organisations who areseeking to implement a formal environmental managementsystem, for example ISO 14001 or the EU Eco-Managementand Audit Scheme (EMAS). BS 8555 makes particularreference to small and medium sized enterprises (SMEs) andoutlines a phased implementation process for EMS.
The standard focuses on environmental performance controland is broken down into six manageable phases. Thesephases can be tackled incrementally at a pace that suits theorganisation. Each phase is then broken down into a series ofmanageable stage profiles. Following through all the phasescould lead an organisation to being in a position to beassessed against ISO 14001 or EMAS.
It is ideal for small to medium sized organisations with a lowto moderate risk to the environment. In such cases, it maynot be necessary to move through all the phases. If anorganisation requires control of their environmental impacts
and risks rather than a full EMS based on ISO 14001,recognition through the IEMA Acorn Scheme at Phase 3 willgive customers and the public confidence that theorganisation are focused on controlling their environmentalrisks including ensuring compliance with legal requirementsand developing objectives and targets but will not place anunnecessary burden on the organisation.
The different phases are:
Phase 1 – Commitment and establishing the baseline,
Phase 2 – Identifying and ensuring compliance with legal and other requirements,
Phase 3 – Developing objectives, targets and programmes,
Phase 4 – Implementation and operation of the EMS,
Phase 5 – Checking, audit and review,
Phase 6 – Environmental Management System acknowledgement.
The main benefits of this incremental approach is that itoffers flexibility and the implementation and registration can proceed at a rate that takes into account the many other pressures and demands that will be facing anorganisation.
The Institute of Environmental Management and Assessment(IEMA) Acorn Scheme has been developed to provide ameans of recognising those organisations that evaluate andimprove their environmental management and performancethrough the phased approach. The scheme allows suchorganisations to gain recognition for their environmentalachievements along the way. The scheme requires theparticipants to implement a management system to meet theachievement criteria and stage profiles of the phases of BS 8555.A system of independent inspection has been established toprovide this recognition; such organisations are called Acorn
Inspection Bodies and are accredited by the United KingdomAccreditation Service (UKAS).
Many large organisations have started to require theirsuppliers to demonstrate good environmental management.Acorn Scheme recognition could be used as a tool by an organisation to demonstrate this. Acorn/BS 8555 canalso be used to help to develop relationships with externalparties such as suppliers, regulators and the general public. The phased approach is flexible and provides direction at each stage.
This route to environmental management also gives earlyindications of its effectiveness as it measures environmentalperformance from day one. By charting progress, it is easier for the management of an organisation to visualise and to plan resources and costs. It also allows for greater employee involvement and can increase staff morale. BS 8555also requires commitment to realistic timescales forenvironmental improvements.
An organisation can become registered to any phase withinthe Acorn Scheme up to and including level 5. Beyond level5, organisations should seek EMAS or ISO 14001 registration.To become registered to the Acorn Scheme, NQA willinspect the organisations environmental management systemagainst the stage profiles within the relevant phases of BS 8555 to ensure the achievement criteria laid down in BS 8555 have been met.
EMAS – Eco-Management and Audit Scheme
The origins of EMAS lie in European Council Regulation1836/93, which allowed voluntary participation by industrialcompany sectors in a Community Eco-Management and Audit Scheme (EMAS). This regulation was replaced by 761/2001 which now allows participation in the scheme by ALL organisations. The regulation requires EU MemberStates to form administrative structures for the scheme. In the UK, the Institute of Environmental Management and
Assessment (IEMA) carries out this function as the‘Competent Body'.
The general aim of EMAS is to ensure that the EuropeanCommunity develops policies and implements actions topromote sustainable development and environmental issues. Amongst other matters, this includes organisationsmanaging the environmental impacts of their products,activities and services by adopting a proactive approach with regard to:
• preventing, reducing and eliminating pollution at source, where possible,
• ensuring sound management and resources,
• using cleaner technologies, where available.
EMAS is transparent and a reliable environmental managementtool. It calls for maintenance of an effective EMS that meets therequirements of ISO 14001 via a system which ensures that apolicy is available, that objectives, targets and programmes areset to improve environmental performance and to ensurecontinuous improvement as a whole.
EMAS could be used by your organisation to exploit newopportunities and market places using your validatedenvironmental statement. EMAS demonstrates that you areserious about reducing your environmental impact andimproving environmental performance.
Differences between EMAS and ISO 14001
Although similar in content, ISO 14001 is an internationalstandard, whilst EMAS is a European standard. There are anumber of subtle differences between the two standardsoutlined below.
• EMAS requires an initial environmental review or preparatory review.
• EMAS requires preparation of a detailed public statement that must be verified by a third party to ensure that it accurately reflects the information portrayed. This mustbe verified every three years and an interim statementproduced annually, verified, and submitted to IEMA.
• EMAS requires that an open dialogue be established between the public and other interested parties. It also requires that employees be involved in the process; this is aimed at continually improving environmentalperformance.
• EMAS states that organisations must ‘provide for compliance with all relevant requirements regarding the environment'. Breaches of legislation and regulations may result in EMAS registration being withdrawn.
Benefits of implementing an environmentalmanagement system (EMS)
There are many reasons for organisations to decide toimplement an environmental management system - not least,the reduced risk of failing to comply with legislation. Othermajor benefits include reducing waste and increasingefficiency, an improved working environment and minimisingthe impact of the organisation on the local environment.
An EMS requires you to take a systematic view of yourenvironmental impacts and prioritise your actions. This allowsyou to focus time and resources towards the most significantimpacts and set realistic action plans for their improvement.Taking this approach can lead to several benefits for yourorganisation including:
• creating a framework for continual environmental improvement,
• assuring customers and the public of your commitment to meeting environmental responsibilities,
• improving relations with regulators,
• enhancing your market image or opening up new markets,
• meeting customer criteria for approved supplier lists,
• reducing raw material and utility costs through improved process efficiency,
• reducing the risk of environmental incidents occurring and minimising their impact,
• improving staff morale through involvement in environmentalimprovement initiatives.
The economic benefits of an EMS have been demonstrated in case studies of organisations of all sizes and activities. This may therefore be one of the key selling points if you need to convince your management team of the value of implementing an EMS. It is well worth documenting and communicating the cost savings that you identify as it will help to demonstrate the on-going value of goodenvironmental practice.
ISO 14001 and correspondence with other standards
The ISO 14000 series of standards encompasses a variety of standards and guidance documents on environmental management issues including topics such as guidelines for environmental performance evaluation (ISO 14031) and lifecycle assessment (ISO 14040, ISO 14041, ISO 14042 and ISO 14043).
A full and current list of the ISO 14000 series can beobtained directly from ISO at www.iso.ch
The first standards in the ISO 14000 family were published in1996. These were ISO 14001 and ISO 14004, which deal withenvironmental management systems.
ISO 14001 is the core management system standard whichspecifies the requirements for the formulation andmaintenance of an environmental management system.
The standard specifies the requirements for an EMS to enable an organisation to develop and implement a policyand objectives that take into account legal and otherrequirements and information about the significant aspects of the organisation.
This standard is supported by ISO 14004 which providesguidelines on the elements of an environmental managementsystem and its implementation, and discusses principal issues involved. It covers issues such as the establishment,implementation, maintenance and improvement of an EMSand its coordination with other management systems.
These 1996 standards were revised and ISO 14001:2004 andISO 14004:2004 were published in November 2004.
ISO 19001:2002 – Guidelines for quality and/or environmentalmanagement systems auditing is the standard that covers theprinciples of auditing an EMS.
Correspondence with other Standards
The table on the following page represents thecorrespondence between ISO 14001, ISO 9001 and theoccupational health and safety specification, OHSAS 18001.Environmental management systems closely follow theprinciples of quality management (plan, do, check, and act).This is particularly evident in the later stages of ISO 14001(documentation, document control, checking and correctiveaction and management review) which are more or less thesame as ISO 9001 but with the emphasis on environmentalprotection. It does however differ from ISO 9001 in somefundamental ways, particularly with regard to the conceptsfor continual improvement and legislative compliance.
In the same way that ISO 14001 mirrors ISO 9001; OHSAS18001 also reflects the key principles and structure of othermanagement systems. However, the link between
environmental management and health and safetymanagement is much stronger and almost all of the OHSAS18001 clauses are similar to ISO 14001. The potential forintegration of these two systems is obvious.
Similarities Between the Three Major Management System StandardsClause OHSAS 18001:2007 Clause ISO 14001:2004 Clause ISO 9001:2000
4.1 General requirements 4.1 General requirements 4.1 General requirements4.2 OH&S Policy 4.2 Environmental Policy 5.3 Quality policy4.3 Planning 4.3 Planning 5.4 Planning4.3.1 Hazard identification, risk assessment and 4.3.1 Environmental aspects
determining controls4.3.2 Legal and other requirements 4.3.2 Legal and other requirements 5.2 Customer focus
7.2.1 Determination of requirements relatedto the product
4.3.3 Objectives and programme(s) 4.3.3 Objectives, targets and programme(s) 5.4.1 Quality objectives5.4.2 Quality management system planning8.5.1 Continual improvement
4.4.1 Resources, roles, responsibility, 4.4.1 Resources, roles, responsibility, authority 5.1 Management commitmentaccountability and authority 5.5.1 Responsibility and authority
5.5.2 Management representative6 Resource management6.1 Provision of resource6.2 Human resources6.2.1 General6.3 Infrastructure6.4 Work environment
4.4.2 Competence, training and awareness 4.4.2 Competence, training and awareness 6.2.2 Competence, awareness and training4.4.3 Communication, participation and consultation 4.4.3 Communication, participation 5.5.3 Internal communication
and consultation 7.2.3 Customer communication4.4.4 Documentation 4.4.4 Documentation 4.4.2 Documentation requirements
4.2.1 General4.4.5 Control of documents 4.4.5 Control of documents 4.2.3 Control of documents4.4.6 Operational control 4.4.6 Operational control 7 Product realisation
7.1 Planning of product realisation7.2 Customer related process7.2.1 Determination of requirements related
to the product7.2.2 Review of requirements related to the product7.3 Design and development7.3.1 Design and development planning7.3.2 Design and development inputs7.3.3 Design and development outputs7.3.4 Design and development review7.3.5 Design and development verification7.3.6 Design and development validation7.3.7 Control of design and development changes7.4 Purchasing7.4.1 Purchasing process7.4.2 Purchasing information7.4.3 Verification of purchase product7.5 Product and service provision7.5.1 Control of production and service provision7.5.3 Identification and traceability7.5.4 Customer property7.5.5 Preservation of product7.5.2 Validation of processes for production and
4.4.7 Emergency preparedness and response 4.4.7 Emergency preparedness and response 8.3 Control of nonconforming product4.5.1 Performance measurement and monitoring 4.5.1 Monitoring and measurement 7.6 Control of monitoring and measuring devices
8.1 General8.2 Monitoring and measuring8.2.1 Customer satisfaction8.2.3 Monitoring and measurement of processes8.2.4 Monitoring and measurement of product8.4 Analysis of data
4.5.2 Evaluation of compliance 4.5.2 Evaluation of compliance 8.2.3 Monitoring and measurement of processes8.2.4 Monitoring and measurement of product
4.5.3 Incident investigation, nonconformity, corrective and preventive action
4.5.3.1 Incident investigation4.5.3.2 Nonconformity, corrective and preventive action 4.5.3 Nonconformity, corrective 7.6 Control of non-conforming product
and preventive action 8.4 Analysis of data8.5.2 Corrective action8.5.3 Preventative action
4.5.4 Control of records 4.5.4 Control of records 4.2.4 Control of records4.5.5 Internal audits 4.5.5 Internal audits 4.5.4 Audit4.6 Management review 4.6 Management review 5.6 Management review
5.6.1 General5.6.2 Review input5.6.3 Review output8.5.1 Continual improvement
This guide is primarily focused on those people who areabout to implement an environmental management systemin their organisation. As such, it is set out in a practical styleallowing the reader to use it as a DIY guide. The resultingenvironmental management system not only should meet therequirements of ISO 14001 but, also the underlying intentionof the standard.
The guidance will be helpful to organisations of all sizes andstructures. This publication will also be of particular interestto students and consultants who seek a better understandingof environmental management systems in general and ISO14001 in particular. The guide outlines the background toenvironmental management and how the internationalstandard ISO 14001 came into being. A summary is also givenof the key benefits and reasons for implementing anenvironmental management system. This will be particularlyuseful to some smaller organisations who are debating thepracticalities and cost of registration.
General terms and definitions used in the environmentalmanagement field are covered, however, this glossary isintended only to give guidance. The definitions are takenfrom the standards ISO 14001 and ISO 14004. The reader isreminded to refer directly to the original text whendeveloping their environmental management system.
The main section of the guide addresses each clause of thestandard. Broken down into four key headings, it aims to de-mystify the intentions of each clause and gives practicalguidance on how to implement the clause and meet therequirements of the standard. Read in conjunction with thestandard, the reader will be able to understand the meaningof each clause, what each requirement expects them to doand, following the guidance, get on and do it!
An interpretation and guidance to the intention of eachclause has been provided. It must be remembered that this isan interpretation only and the standard itself should bereferred to.
Each clause contains one or more self-assessment questions(SAQ’s). These can be used to either gauge the extent towhich you already meet the requirements of the standard orto measure your progress as you work through yourimplementation programme. The more questions you cananswer yes to, the further you have progressed toward fullimplementation. If you can answer yes to all the self-assessment questions, you are probably ready for registrationto ISO 14001. If not, work through this book or contact NQAat the address below.
NQAWarwick HouseHoughton Hall ParkHoughton RegisDunstableLU5 5ZX
E-mail: [email protected]: www.nqa.comSales Hotline: 08000 52 24 24
How to Use This Guide
Audit clientOrganisation or person requesting an audit.
Note: the audit client may be the auditee or any other organisation which has the regulatory or contractualright to request an audit.
Audit conclusionOutcome of an audit, provided by the audit team afterconsideration of the audit objectives and all audit findings.
Audit criteriaSet of policies, procedures or requirements.
Note: audit criteria are used as a reference against which audit evidence is compared.
Audit evidenceRecords, statements of fact or other information, which arerelevant to the audit criteria and verifiable.
Note: audit evidence may be qualitative or quantitative.
Audit findingsResults of the evaluation of the collected audit evidenceagainst the audit criteria.
Note: audit findings can indicate either conformity or non-conformity with audit criteria or opportunities for improvement.
Audit planDescription of the activities and arrangements for an audit.
Audit programmeSet of one or more audits planned for a specific time frameand directed towards a specific purpose.
Note: an audit programme includes all activities necessary for planning, organising and conducting the audits.
Audit scopeExtent and boundaries of an audit.
Note: the audit scope generally includes a description of the physical locations, organisational units, activities and processes, as well as the time period covered.
Audit teamOne or more auditors conducting an audit (supported ifneeded by technical experts).
Note 1: one auditor of the audit team is appointed as the audit team leader.
Note 2: the audit team may include auditors-in-training.
AuditeeOrganisation being audited.
AuditorPerson with competence to conduct an audit.
CompetenceDemonstrated personal attributes and demonstrated abilityto apply knowledge and skills.
Continual improvementRecurring process of enhancing the environmentalmanagement system in order to achieve improvements inoverall environmental performance consistent with theorganisation’s environmental policy.
CorrectionAction taken to eliminate a detected non-conformity.
Corrective actionAction to eliminate the cause of a detected non-conformity.
Definitions
DocumentInformation and its supporting media.
Note: the medium can be paper, magnetic, electronic or optical computer disk, photograph or master sample, or a combination thereof.
EnvironmentSurroundings in which an organisation operates including air,water, land, natural resources, flora, fauna, people, and theirinteraction.
Environmental aspectElement of an organisations activities or products or servicesthat can interact with the environment.
Note: a significant environmental aspect has or can have a significant environmental impact.
Environmental impactAny change to the environment, whether adverse orbeneficial, wholly or partially resulting from an organisation’senvironmental aspects.
Environmental management system - EMSPart of an organisation’s management system used todevelop and implement its environmental policy and manageits environmental aspects.
Note 1: a management system is a set of interrelated elements used to establish policy and objectives andto achieve those objectives.
Note 2: a management system includes organisation structure, planning activities, responsibilities, practices, procedures, processes and resources.
Environmental objectiveOverall environmental goal, consistent with environmentalpolicy that an organisation sets itself to achieve.
Environmental performanceMeasurable results of an organisation’s management of itsenvironmental aspects.
Environmental performance indicator - EPISpecific expression that provides information about anorganisation’s environmental performance.
Environmental policyOverall intentions and direction of an organisation related toits environmental performance as formally expressed by topmanagement.
Note: the environmental policy provides a framework for action and for the setting of environmental objectives and environmental targets.
Environmental targetDetailed performance requirement, applicable to theorganisation or parts thereof, that arises from theenvironmental objectives and that needs to be set and met in order to achieve those objectives.
Interested partyPerson or group concerned with or affected by theenvironmental performance of an organisation.
Internal auditSystematic, independent and documented process forobtaining audit evidence and evaluating it objectively todetermine the extent to which the environmentalmanagement system audit criteria set by the organisation are fulfilled.
Note: in many cases, particularly in smaller organisations, independence can be demonstrated by the freedom from responsibility for the activity being audited.
Management Performance Indicator - MPIEnvironmental Performance Indicator that providesinformation about the management efforts to influence anorganisation’s environmental performance.
Non-conformityNon-fulfilment of a requirement.
Operational Performance Indicator - OPIEnvironmental Performance Indicator that providesinformation about the environmental performance of anorganisation’s operations.
OrganisationCompany, corporation, firm, enterprise, authority orinstitution, or part or combination thereof, whetherincorporated or not, public or private, that has its ownfunctions and administration.
Note: for organisations operating more than one operating unit, a single operating unit may be defined as an organisation.
Preventive actionAction to eliminate the cause of the potential non-conformity.
Prevention of pollutionUse of processes, practice, techniques, products, services orenergy to avoid, reduce or control (separately or incombination) the creation, emission or discharge of any typeof pollutant or waste, in order to reduce adverseenvironmental impacts.
Note: prevention of pollution can include source reductionor elimination, process, product or service changes, efficient use of resources, material, energy substitution, reuse, recovery, recycling, reclamation and treatment.
ProcedureSpecified way to carry out an activity or process.
Note: procedures can be documented or not.
RecordDocument stating results achieved or providing evidence ofactivities performed.
StakeholderSee ‘interested party’.
Technical expertPerson who provides specific knowledge or expertise to theaudit team.
Note 1: specific knowledge or expertise is that which relatesto the organisation, the process or activity to be audited, or language or culture.
Note 2: a technical expert does not act as an auditor in the audit team.
Principles of ISO 14001The next section explains the five principles on which ISO14001 is based, and analyses each of the elements whichorganisations are required to implement. Whilst this guide isprimarily focused on ISO 14001, many of the elements arecommon to other environmental systems and, in particular,EMAS and BS 8555.The ISO 14001 model follows five basic principles to whichorganisations developing an environmental managementsystem should subscribe. These include:
PolicyEnsure commitment to the EMS and establish anenvironmental policy.
• Environmental policy: the environmental policy acts as the foundation for the entire EMS and, as such, the structure of the system should be designed to deliver its aspirations. In short, the policy should be a documented statement of how the organisation is committed to the protection of the environment, prevention of pollution, legislative compliance and continual improvement.
PlanningFormulate a plan to deliver the environmental policy.
• Environmental aspects: once the policy has been established, your organisation should identify and evaluate the environmental implications of its activities, products and services, to allow you to determine their significance and make informed decisions on how they can be controlled or improved. You must take into account all the environmental aspects that you can control and those you can influence and take into account planned or new developments, or new or modified activities, products and services. You must document and keep this information up to date and ensure that the significant environmental aspects are taken into account when you establish and implement your EMS and when you maintain it.
• Legal and other requirements: as one of the three core commitments of the environmental policy, your system should be structured to deliver legislative compliance. Toachieve this, procedures should be established to identifyand ensure access to relevant laws and regulations andother requirements to which your organisation subscribesthat relate to your environmental aspects. You must identify how these requirements apply to your environmental aspects.
• Objectives, targets and programme: with an understanding of the significant environmental issues and legal implications of your activities, the next step is to set goals for improvement. These objectives and targets should also consider your environmental policy, your commitments to the prevention of pollution, compliance with legal and other requirements and continual improvement. They should also take into account views of interested parties (stakeholders) and other business, financial, operational and technical factors. The objectives and targets that you set should be measurable where practicable. To ensure that policy commitments, objectives and targets are carried out, realistic and achievable action plans or programmes should be established which include the means and time frames by which your objectives and targets are to be achieved.
Implementation and operationDevelop the capabilities and support mechanisms necessaryto achieve the policy and objectives, targets and programme.
• Resources, roles, responsibility and authority: all management initiatives require an organisational structure - environmental management is no exception. Resources,roles and responsibilities and authority, relevant to the EMS,should be defined, documented and communicated inorder to facilitate effective environmental management. Aspecific management representative should be appointedby top management. They will ensure that the EMS isestablished, maintained and implemented in accordancewith ISO 14001 and that they report to top managementon the performance of the EMS for review includingrecommendations for improvement.
• Competence, training and awareness: to ensure that the requirements of the policy and the EMS are carried out asspecified, you must ensure that any persons performing tasks for the organisation or even on behalf of it that have the potential to cause a significant environmental impact are competent. This competence should be based on the appropriate education, training and experience of these individuals. You need to keep records so that you can demonstrate this competence. You need to identify training needs and establish an appropriate training programme and keep records of training that has been performed. You need to make sure that people working for or on behalf of your organisation are aware of:
• the importance of the environmental policy and the requirements of the EMS,
• the significant aspects and the potential impacts associated with what they do and the benefits of improving their performance,
• the part they play in meeting conformity with the EMS,
• the potential consequences of them departing from the procedures associated with the EMS.
• Communication: procedures should be established to record and respond to internal and external communications on environmental issues.
• Documentation: standard and consistent application of thesystem must be applied. This should be achieved through theestablishment and maintenance of information describing thecore elements of the system and their interaction andprovide direction to other related documents.
• Control of documents: all documents required by the EMSneed to be controlled. A procedure should be established toensure that all documents within the system are effectivelymanaged. This should include requirements for approvingdocuments before they are issued, reviewing and updating
documents, ensuring the location and revision of documentsand their removal and retention once obsolete.
• Operational control: you will need to identify and plan thoseoperations that are associated with your significant aspects (inline with your policy, objectives and targets they should beplanned and managed under specified conditions). You cando this by procedures to control situations, laying downoperating criteria and having procedures related to yoursignificant aspects and communicating them to suppliers andcontractors.
• Emergency preparedness and response: despite best-laidplans, accidents and emergency situations can still occur. To prevent and mitigate the environmental implications of such situations, procedures should be established toidentify and respond to accident and emergency situations.These must be periodically reviewed and tested.
Checking Monitoring and measuring environmental performance.
• Monitoring and measurement: to check the effectiveness ofthe system and to ensure that it is still on track you shouldmonitor and measure key activities that have significant impactsupon the environment. You also need to ensure that anyequipment that you use is calibrated and retain records todemonstrate this.
• Evaluation of compliance: you must periodically reviewcompliance with legislation and other requirements to which your organisation subscribes. This is to ensure that you are consistent with your commitment to compliance.You need to establish a procedure to do this for both legal requirements and other requirements to which you subscribe and keep records of the results of theseperiodic evaluations.
• Non-conformity, corrective and preventive action: a procedure should be established, implemented and maintained for taking corrective and preventive action. You need to identify and correct the non-conformity
at the earliest opportunity, investigate and determine theircause and take action to prevent the problem recurring.
• Control of records: records should be kept to provideevidence that the system is working satisfactorily. Suchrecords should be legible, identifiable and traceable to theactivity involved. There should also be a procedure for theidentification, storage, production, retrieval, retention anddisposal of these records.
• Internal audit: once the system is in place, it is vital to ensure that the theoretical intentions of procedures and instructions are being implemented in practice. To do this, regular and systematic audits should beconducted to verify that your EMS is operating as intended.An audit programme needs to be set and followed. Auditorsthat perform this task must be objective and impartial.
Management ReviewReview and continually improve the EMS with the objective ofimproving its overall environmental performance.
• Management review: at regular intervals, your managementteam should review the EMS to assess its continuing suitability,adequacy and effectiveness. This will allow them to addresspossible changes to the policy, objectives and targets, and theEMS as a whole, in light of changing circumstances and thecommitment to continual improvement. Certain inputs shouldbe made to this review process including (but not limited to)results of internal audits, evaluation of legal compliance,communications from interested parties, environmentalperformance and corrective and preventive actions.
In essence, the EMS should be viewed as a basic managementframework, which enables companies to coordinate and driveenvironmental improvements. It should be continuallymonitored and reviewed to ensure that it is responsive tointernal and external environmental factors affecting thecompany, (e.g. changes in legislation). Each person in theorganisation should be aware of their role within the EMS andaccept personal responsibility for environmental improvementsand conformances with the policy and procedures.
Initial EnvironmentalReviewIntroductionAlthough it is not a mandatory requirement of ISO 14001,many organisations find it useful to undertake an Initialenvironmental review before they develop their system. This review is often presented in the form of a writtenreport, which examines a broad spectrum of environmentalperformance criteria and sets out recommendations forimprovement. ISO14004 gives guidance on the potentialissues to be addressed and indicates that it could provide agood foundation for the development of an environmentalpolicy and EMS.
It must be remembered, however, that this review is a one off “snap-shot” of your environmental performance.Later on in the implementation programme, you willundertake a more systematic and detailed assessment ofyour company’s environmental performance and legislativecompliance, which will be continuously reviewed andupdated as circumstances change.
The initial environmental review does however, provide agood starting point for a strategic review of your company’senvironmental performance and attitudes towardenvironmental issues. The report can also act as abenchmark. So in the future you will be able to look backand know how far you have progressed.
ISO14004 suggests the following criteria can be used in the initial review to assess the current environmentalperformance:
• identification of applicable legal requirements and otherrequirements to which the organisation subscribes,
• identification of environmental aspects, including thoseassociated with normal operating conditions, abnormalconditions including start-up and shut down, and
emergency situations and accidents:
• this should include all of your activities, products and services so as to determine those that have or may have significant environmental impacts and liabilities.
• examination of existing environmental managementpractices and procedures, including those associated withprocurement and contracting activities,
• evaluation of previous emergency situations and accidents.
The review can also include additional considerations, such as:
• an evaluation of performance compared with applicableinternal criteria, external standards, regulations, codes ofpractice and sets of principles and guidelines,
• opportunities for competitive advantage, including costreduction opportunities,
• the views of interested parties, and,
• other organisational systems that can enable or impedeenvironmental performance.
Any evidence collected should be objective.
What to ConsiderThe following are some of the areas that organisations choseto consider during their environmental initial review. This listis by no means exhaustive.
• Main activities, products and services at the site.• Identify potential aspects and impacts:
o emissions to air,o releases to water,o land,o waste management,o raw materials and natural resources,o planning conditions,o visual impact,
o noise,o energy management,o emergency impacts.
• Site plan,• Site drainage,• Any environmental history:
o previous contaminative uses,o previous incidents,o previous breaches of environmental laws.
• Views of interested parties:o regulators,o public,o customers,o suppliers.
• Other activities that may enable or impede environmentalprotection or performance,
• Previous complaints.
WhomSome ideas of whom may be involved in the initial review areas follows:
• those working for the organisation that are to be involvedin the EMS,
o operations manager,o environmental/H & S manager,o supervisors,o other staff in key areas where their actions may have an impact, e.g. production.
• Key information providers such as maintenance personnel.
How to conduct the initial reviewThe following methods might be used to conduct your initialreview:
• interviews,• evaluation of internal and external communications,
complaints, etc,• gathering information,
o checklists for each operation identify:• emissions,• resources,
• personnel,• existing procedures,• level of training and competence,
o Eco-maps:• baseline assessment,• what is the problem?• what is the quality of the data?• what is the source of the data?• what are the facts, figures and environmental
indicators?• what are the timeframes and targets?• possible action and who should take it?
o process flowcharts,o site walkabout:
• familiarity with aspects and impacts,• housekeeping,• identify relevant operations,
o inspection.
Typical outputsThe initial review should be recorded and reviewed. Bydocumenting this process it can be used as a baseline for future reference and can be used to help to planimplementation and map the resources required.
• site plan with details,• general scope of the EMS,• list of likely aspects and associated impacts,• identification of initial opportunities:
o cost savings,o environmental performance improvements,o how to address concerns of interested parties.
Where to get helpSmaller organisations may also be able to consult a numberof outside sources for assistance, such as:
• Envirowise with regard to free help and advice,• The Environment Agency or local authorities with regard
to laws and permits including NetRegs (A new Website setup by the UK's environmental regulators to help small
businesses understand their environmental obligations),• water and sewerage undertakers – drainage,• trade or industry associations,• larger client organisations,• manufacturers of equipment in use,• professional help can also be sought from environmental
consultancy firms.
SummaryA good initial review is a strong foundation for a good EMS,it gets people involved in the process and be thorough inwhat you do. Use checklists and eco-maps to make recordsbut, ensure that you only collate useful information.Remember, this will be the baseline for establishing yourEMS.
Further guidance is available in ISO 14004:2004.
As discussed earlier, ISO 14001 is based on the ‘Plan, Do,Check, Act’ pioneered by the American quality expert W. Edwards Deming in the 1950s. This simple, but effective,structure is still used today to ensure that the environmentalaspects and impacts within the organisation are systematicallyidentified, assessed, controlled and monitored and that theyare continually improved.
Clause 4.1 - General requirements
Introduction
This is the standard’s intention, this clause establishes thebasic commitment of the organisation to document andsustain an environmental management system. The systemmust include a clearly mapped out organisational structureand documentation covering planning activities,responsibilities, practices, procedures and processes forachieving the requirements of the standard. Resources mustalso be provided for developing, implementing achieving,reviewing and maintaining the environmental policy.
ISO 14001 requirements
The organisation shall establish, document, implement,maintain and continually improve an environmentalmanagement system in accordance with therequirements of this International Standard anddetermine how it will fulfil these requirements.
The organisation shall define and document the scope of its environmental management system.
Interpretation
You need to evaluate and document how your EMS fulfilsthe requirements of ISO 14001. This could be done as part ofthe internal audit or as part of the management review.Either way, this must be traceable and demonstrate how youmeet the requirements.
The scope of the EMS must be defined by your organisation;this directly links the management system with the activities,products and services of your organisation. Your scope willdefine your EMS and what activities, operations, services andproducts are within it.
Environmental management system elements
Environmental management system model (Source BS EN ISO 14001:2004)
Continual improvement
Checking
Managementreview
Implementationand operation
Planning
Environmentalpolicy
18
You must document your scope; one way of doing this is toinclude it in your environmental policy.
If you are going to seek registration of your ISO 14001system with an accredited certification body, such as NQA,then your scope must agree with accreditation rules. Thismeans that you cannot ‘ring fence’ the scope of your EMS to exclude difficult areas or areas that are part of your site.
4.2 Environmental policy
Introduction
Having decided to develop an environmental managementsystem, the next most critical step is to set out what youwish it to deliver. Establishing an environmental policy cansimply and effectively state these aspirations and, moreover,communicate such commitments to your stakeholders. Thisis especially important for many smaller organisations as theyare under increasing pressure from major clients to developISO 14001. Sending this policy to customers can form part ofa marketing strategy and also assure clients that you haveembarked upon the road to ISO 14001 certification.
An environmental policy should act as your management’sdeclaration that environmental protection is a priority. Itshould also serve as a unifying vision showing environmentalconcern by the entire company. As such, the policy isprobably the most important document in the entire system.
ISO 14001 requirements
Top management shall define the organisation’senvironmental policy and ensure that, within the definedscope of its environmental management system, it;
a) is appropriate to the nature, scale and environmentalimpacts of its activities, products and services,
b) includes a commitment to continual improvement and prevention of pollution,
c) includes a commitment to comply with applicable legal requirements and with other requirements to which the organisation subscribes which relate to itsenvironmental aspects,
d) provides a framework for setting and reviewing environmental objectives and targets,
e) is documented, implemented and maintained,
f) is communicated to all persons working for or on behalf of the organisation, and
g) is available to the public.
Interpretation
In most management systems it is often the responsibility of the top management team to produce a policy. This is alsotrue for ISO 14001, and requires companies to define anenvironmental policy that is appropriate to the nature andscale of its operations.
The environmental policy should be developed and signed bythe top management of your organisation. It is also a goodidea for other senior managers to sign it, as their support willbe essential to the effectiveness of the EMS. Without thisvisible declaration, it is unlikely that the rest of the companywill give any credence to the system.
The policy should be consistent with the scope of the EMSand not imply a wider or indeed a narrower or differentscope than this. It must also cover all of the activities,products and services within that scope.
Your policy should contain three core commitments,including a commitment to continual improvement. Thisdoesn’t mean that you must improve in all areas at once, butthat the policy should drive your overall efforts to continuallyimprove your organisation’s environmental performance.
Since it serves as the framework for your EMS, it isworthwhile considering the structure and content of thepolicy. The statement should be more than just flowing proseand golden platitudes. Instead, it should set out clearcommitments and act as a springboard when settingenvironmental objectives and targets. In short, your policymust be brought to life in your plans and actions.
Finally, it does not matter how well written the policy is, ifnobody reads it. It will be ineffective if it is notcommunicated to the very people who will be most effectivein delivering its aspirations. The importance of communicatingthe policy to ALL members of staff cannot be overstated. Thisis clearly stated in clause 4.2.e.
The policy should be communicated to everyone working for or on behalf of the organisation. This should includecontractors, subcontractors, temporary staff and remote
workers. As well as communicating internally, the policyshould also be made available to members of the public andother interested parties (stakeholders). This does not meanthat you have to actively send out copies of your policy,although some organisations may choose to do so. However,if you receive an inquiry from an interested party then youshould be able to provide a copy.
Definitions Recurring process of enhancing the environmental management system in order to achieve improvements in overall environmental performance consistent with theorganisation’s environmental policy.(ISO 14001:2004)
Use of processes, practice, techniques, products, services or energy to avoid, reduceor control (separately or in combination) the creation, emission or discharge of anytype of pollutant or waste, in order to reduce adverse environmental impacts.(ISO 14001:2004)
Meeting or exceeding all applicable legal requirements and other requirements which relate to its environmental aspects.
Note: as your commitment is to comply with requirements that relate to yourenvironmental aspects, not just ‘environmental’ requirements, you will need to consider other requirements such as safety regulations that may relate to yourenvironmental aspects.
Continual improvement
Prevention of pollution
Legal compliance
The 3 Core Policy Commitments of ISO 14001
Hints for implementation
Most organisations have some form of environmental policy,even if it is not in a written form. For example, it is likely thatyour company is committed to understanding and complyingwith all applicable legislation. In addition, most wish to avoiddamage to the environment. However, only a feworganisations have actually established a written policy.
Your first step when developing the policy should be toestablish what principles or commitments to which yourorganisation currently subscribes. This can best be achievedby gathering a team together and brainstorming ideas.Consider carefully who to invite onto this team. Input from awide range of people in your company, includingmanagement should increase commitment and ownership.
At this stage, it is best to collate all the ideas presented at themeeting, possibly on a flip chart. Don’t worry about theexact wording of the policy yet, this will come later when youreview and draft out the policy.
It is important to keep your policy simple and understandableso try to answer the following questions during the brainstorming session:
• what are we trying to achieve through the environmentalmanagement system?
• what adverse environmental impacts do we want toaddress?
• what positive environmental attributes do we wish topromote in the policy?
• Posting it around the site on notice boards and inreception.
• Letters, memos.
• Including it with paycheques.
• Training sessions especially induction training for newstaff and contractors.
• Staff meetings or briefings.
• Intranet web pages/e-mail.
• Staff magazines.
• With visitors’ book for temporary staff andcontractors.
• Sales and marketing literature.
• Business cards.
• Newspaper advertisements.
• Annual reports.
• Public library.
• Local community meetings and open days.
• Visitor badges.
• Internet web pages/e-mail.
• External site notice boards.
Communicating the Policy Commitments of ISO 14001
Internally Externally
• who do we wish to proactively communicate with,regarding our environmental policy?
• how can we best communicate the policy to our selectedaudience?
• how can we best communicate the policy within thecompany?
• will we do what we said we would?
• shall we develop a stand-alone document or integrate itwith health and safety, quality, or other company policies?
• how will we review the implementation of ourenvironmental commitments?
Once you have answered all of these questions, sketch out adraft statement, taking into consideration the requirementsof the standard. Try to keep it clear, concise and above allunderstandable, and if possible keep it to one side of A4-sizewriting paper.
Next, circulate the draft statement among the developmentteam to ensure they are happy with the wording and thecommitments given. You need to ensure that your topmanager or management team sign the document and arecommitted to implement its aspirations.
Remember, your policy should be appropriate to theenvironmental implications of your activities, products andservices. So it is worthwhile reviewing the policy after youhave completed a more detailed evaluation of yourenvironmental aspects which is described in later sections.
Your policy may also need to be modified later following theManagement Review. As your organisation and itsenvironmental performance changes, so too, will your policy.The policy should be seen as a living document which drivesthe system and grows with it as it matures and not as a set of
commandments set in stone.
Common non-conformities
Some of the most common non-conformities found duringthe certification process include:
• the policy is not developed by “top management”,
• the use of a corporate policy where a site policy is moreappropriate,
• the policy is not consistent with the scope,
• commitment to continual improvement and prevention ofpollution is not clearly defined or missed out altogether,
• there is no commitment to compliance with applicablelegal requirements,
• no mechanisms for revising policy,
• the systems records do not support policy commitments,
• communication with persons working on behalf of theorganisation is inadequate or not carried out, particularlyin relation to contractors and subcontractors.
Self-assessment questions
• Have you developed a written policy statement?
• Is it appropriate to the nature and scale of youroperations?
• Does it address the three key policy commitments?
• Has it been effectively communicated internally andexternally?
4.3 Planning
4.3.1 Environmental aspects
Introduction
Before you set about improving environmental performance,you must firstly ask yourself the following questions:“What do we need to do?”“What do we need to do first?”
At this stage of the project it will not be easy to answerthese questions, but it does help to illustrate the importanceof evaluating your environmental performance andprioritising your actions so that the most important issues aretackled first. This is especially true if you have limited financialand human resources.
Evaluating how your organisation interacts with theenvironment forms the first step in the planning of your EMS.It allows you to identify, evaluate and understand how youractivities or elements of your activities (aspects) effect theenvironment. In addition, it allows you to use this informationto make informed decisions on the most important orsignificant issues, so that you can focus resources towardcontrolling and improving them.
Identifying significant environmental aspects is therefore oneof the most critical elements of the EMS, but it can be one ofthe most challenging. Decisions you make in this area canaffect many other system elements (such as setting objectivesand targets, establishing operational controls, and definingmonitoring needs). Careful planning and conduct of thisactivity will pay dividends in later stages.
ISO 14001 requirements
The organisation shall establish, implement and maintaina procedure(s)
a) to identify the environmental aspects of its activities,products and services within the defined scope of theenvironmental management system that it can controland those that it can influence taking into accountplanned or new developments, or new or modifiedactivities, products and services, and,
b) to determine those aspects that have or could havesignificant impact(s) on the environment (i.e. significantenvironmental aspects).
The organisation shall document this information andkeep it up to date.
The organisation shall ensure that the significantenvironmental aspects are taken into account inestablishing, implementing and maintaining itsenvironmental management system.
Interpretation
One of the most fundamental requirements of ISO 14001 isthe establishment of a documented procedure for identifyingthe environmental implications of the activities, products,processes and services of your organisation.
The elements of your organisations activities, products,processes and services that can interact with theenvironment are called “aspects”. Examples of aspects couldbe a discharge or an emission or perhaps the consumption ofa material. The term “aspects” includes those components ofactivities that “cause” environmental impacts (such as thedischarge of hazardous materials into a stream).
Examples of Relationships between Aspects and Impacts
Aspects Potential impacts
Emissions towater/sewer
Emissions toatmosphere
Wastegeneration
Electricity use
Use of re-cycled paper
Site run-off, spillage of oils,chemicals, etc.
Fumes and emissions frompaint spraying, vehicles,manufacturing processes, etc.
Hazardous and non-hazardous waste fromproduction activities; paper,wood metals, emptycontainers, etc.
Deterioration of water quality;Potential contamination of surface/foul waterdrainage systems and controlled waters;degradation of aquatic habitat and drinkingwater supply.
Deterioration of air quality.Negative impact on local air quality, climatechange, low-level ozone depletion.
Inadvertent disposal could result in pollutionof soil and controlled waters, and inadequatecontainment/storage could lead to nuisanceand odour problems.Where waste is sent to landfill, this could leadto leachate polluting land and water courses,resource depletion.
Resource depletion.Air pollution, climate change.
Conservation of natural resources.
“Impacts” are the change or alteration in the environment asa consequence of particular environmental aspects (forexample, fish killed as a result of the discharge). Impacts canalso be beneficial to the environment such as improvedwater quality as a result of a treatment process.
The distinction between aspects and impacts has beencreated to allow managers to focus their attention andresources toward controlling and managing those elements of their activities that create the impact in the first place.
In theory, the potential environmental impacts arising fromyour aspects could go on forever. It would be unreasonable,however, to expect businesses to address them all, especiallywhere they have no control over the aspect. To overcomethis, the standard gives organisations an amount of leeway to draw the boundary of their EMS around those aspectsover which it may have control and those it can have aninfluence over.
Your company will not be expected to manage aspects outsideits sphere of influence. For example, whilst your companyprobably has control over the quantity of chemicals it uses, it isunlikely that it can control the way they are manufactured.
When evaluating whether or not you can influence theaspects associated with an activity, product or a service youshould consider the legal and contractual authority, policies,local or regional issues that may have an effect and anyobligations or responsibilities that you may have towardsinterested parties.
You should also consider the implications of situations such asthe purchase of materials, for example chemicals or productscontaining hazardous materials.
Once you have identified the environmental aspects of your activities, products and services, you should determinewhich aspects could have “significant” impacts on theenvironment. These environmental aspects should beconsidered when setting your environmental objectives and operational controls.
It is important that once you have conducted an assessmentof your environmental aspects, that this information is keptup-to-date. In particular, the standard refers to new andplanned developments, new and modified activities, productsand services.
You will need to consider your significant aspects when youplan to change activities or develop completely newprocesses, activities and services. You should also make sure
that you document these considerations. These should thenbe fed into your system.
Hints for implementation
Identifying and evaluating your environmental aspects mayseem like an enormous task. Nevertheless, if you break theprocess down into logical steps it can be made much simpler.ISO 14004 gives practical guidance on identifying andunderstanding environmental aspects.
As an organisation, you should collect both quantitative andqualitative data on the characteristics of your activities,products and services. This would include the inputs and outputs into your organisation such as materials, energy, the technology that you use, your location and your facilities.
Remember to look at all activities, products, processes andservices of your organisation, not just the must obvious ones.Think about:
• production activities,• design and development,• procurement,• material and waste storage,• research,• packaging,• transport and distribution,• use and end of life,• maintenance,• office activities,• warehousing.
Whilst the need to examine your on-site operations might seem obvious, you should also consider the potential impacts of what you do off-site (such as servicing equipment at customer premises). Similarly, theenvironmental aspects of the materials, suppliers, andcontractors you use may be less obvious, but should still be considered.
To understand your environmental aspects, it helps tounderstand the processes by which you generate productsand services. A flow chart of your major processes mighthelp you understand the inputs and outputs of yourprocesses and how materials are used (see diagram). You may also want to consider the views of interestedparties. Some organisations have found external parties tobe a good resource to help identify your organisation’senvironmental aspects.
There are many readily available sources of information tohelp you perform your assessment. For instance, tradeassociations, regulatory agencies, your customers andsuppliers might provide useful information to support yourassessment.
PROCESS Finished Product
OUTPUTSnoise, odour and other community issues
OUTPUTSdischarges (air, land, water)
utilities (water, electricity and gas)
INPUTS
raw materials and natural resources
INPUTS
Potential Environmental Aspects under Normal Operating Conditions
AirGas emissions (e.g. volatile organic compounds, CO2, SO2, NOx CO, odours, etc.)Particulates (e.g. dusts and smuts)
WaterWater discharge (trade effluent discharge to sewer, biological oxygen demand, chemical oxygen demand, temperature)
Land Land occupation (e.g. soil erosion, disturbance, geology, hydrology, ground water flows and archaeology)Land contamination (e.g. contamination of land and groundwater with hazardous materials) water
Raw Material and Resource UseEnergy (e.g. consumption of electricity, fuels, gas, oils and coal)Process raw materialsAuxiliary materials (e.g. lubricating oils) Packaging materialsWater consumption (e.g. extracted water or mains water)Fuels for transportStorage and handling of materials
WastesHazardousNon-hazardousStorage and handling of wastesDisposal of waste
NuisanceNoiseVibrationTraffic and parkingVisual appearance/house keeping
OtherWildlifeBiodiversityCultural heritage (listed building, etc.)Environmental performance and practices of contractors and suppliers
It is vital to remember that processes do not always interactwith the environment constantly or continuously or both.This is especially true for emergency or accidental conditionswhere the impact might be acute and severe. It is vital,therefore, to consider the impacts of operations duringnormal and abnormal conditions. Any reasonably foreseeableemergency situations must also be considered.
For each of the environmental aspects you have outlined inthe previous step you should identify as many actual andpotential, positive and negative, environmental impacts aspossible. Also identify the part of the environment that willbe affected and how. For your identified aspects also includeany direct and indirect impacts.
Remember to look at the characteristics of the location ofyour organisation. This might affect the impact of youractivities, products and services such as local weatherconditions, the local water table conditions, flooding and thesoil type of your location(s). Also think about the length oftime which these changes may occur, for example, thechanges in the site after a sustained period of rain maycontinue to cause problems such as flooding and excess siterun-off even after the rain ceases.
Don’t forget to also look at new or planned developments,or new or modified activities, products and services.
The following information would also assist:
• cause and effect relationships that exist between thedifferent elements of your products, activities and services,
• potential or actual changes to the environment,
• any concerns of stakeholders with respect to theenvironment,
• aspects identified in regulations and permits, otherstandards or by industry associations, etc.
After your company has identified the environmental aspectsand impacts of its operations, the next step is to evaluatetheir environmental significance. This has two objectives;firstly, to ensure that the issues that have the greatest impacton the environment are clearly prioritised and addressed:secondly, it enables you to identify and evaluate currentcontrol mechanisms and decide what further steps may beneeded to deal with the significant aspects.
Abnormal Start-up
Shutdown
Part load operations
Change of product or operation
Partial failure
Maintenance
Vandalism
Visitors (e.g. customers or school parties)
Spillages
Raw material shortages
Contractor issues
Supplier issues
Emergency conditionsLoss of power, water or fuel supply
Loss of containment
Fire
Explosion
Overload of process
Storm and other natural disasters
Potential environmental aspects underabnormal and emergency conditions
There is no set approach for evaluating significance andvarious techniques are used. What may be significant for oneorganisation is not necessarily significant for another. One ofthe most popular methods is using scoring tables. It is up toyour company to choose the most appropriate method andset its own criteria for significance. This criteria involves botha technical analysis and some judgement by the organisation.The most important thing is that when you establish yourcriteria and apply them to your aspects that you areconsistent. Some possible criteria could include:
• severity, scale and duration of environmental impact,
• applicable legal requirements,
• concern from interested parties,
• employee concerns,
• financial implications,
• quantities used/released,
• controls in place/effectiveness of controls,
• monitoring and measurement,
• likelihood of occurrence.
You should keep this information up-to-date and review itperiodically. It can be useful to maintain it in a list, database orregister.
After you have identified the significant environmentalaspects, use this information in setting your objectives andtargets. This does not mean that you need to address all ofyour impacts at once. There may be good reasons (such ascost or availability of technology) for addressing someimpacts now and deferring some impacts for later action.There will also be several ways in which you improveenvironmental management without resorting to capital
expenditure. For example, on-site staff training andawareness can help to reduce accidents and usage of rawmaterials.
Common non-conformities
During the certification, your chosen certification body willaim to determine if your procedure for determiningsignificant environmental aspects is sound and properlyimplemented. If there are major environmental problemsassociated with your operations they should logically beidentified as significant (unless they are under effectivecontrol or management).
The certification body will also like to see a consistent threadof environmental issues identified in your aspects assessmentand in your policy, objectives and targets. In other words, ifan environmental aspect is determined as significant then itshould be managed within the system.
The certification body will not, however, define what criteriashould be used for significance this is for the company todecide.
Some of the most common non-conformities found bycertification bodies include:
• lack of comprehensive documented procedure foridentifying aspects,
• not all the activities, products and services within thescope of the EMS are covered,
• ranking is inappropriate to the significance of impact,
• incomplete coverage for past, current and plannedactivities,
• aspects under abnormal, emergency and accidentconditions are not considered,
• aspects that the organisation can have an influence overare not adequately considered,
• the significant aspects are not adequately considered indeveloping, implementing and maintaining the EMS,
• poor provision for keeping information up to date.
Self-assessment questions
• Have you established a procedure for identifying andevaluating the environmental aspects of your products,activities, and services?
• Have you determined which aspects have significant impacts?
• Is your procedure consistent?
4.3.2 Legal and other requirements
Introduction
Organisations are increasingly faced with a wide variety oflegal duties, and in particular, acts and regulations protectingthe environment. This trend is set to grow in the future, asgovernments around the world debate further controls andincentives for environmental protection. It is, therefore, vitalthat firms are aware of their current obligations, especially assome of the consequences of legal non-compliance caninclude fines, prison sentences, litigation, bad publicity andprocess abatement. Moreover, by anticipating future changes,firms could plan for and avoid some of the associated costsof compliance.
Our EMS should enable your organisation to:
• identify and evaluate and have access to applicable(current and future) legal and other requirements thatrelate to your environmental aspects and how they applyto your aspects,
• ensure that any relevant requirements are integrated intothe operational and management controls of your system.
ISO 14001 requirements
The organisation shall establish, implement and maintaina procedure(s)
a) to identify and have access to the applicable legalrequirements and other requirements to which theorganisation subscribes related to its environmentalaspects,
b) to determine how these requirements apply to itsenvironmental aspects.
The organisation shall ensure that these applicable legalrequirements and other requirements to which theorganisation subscribes are taken into account inestablishing, implementing and maintaining itsenvironmental management system.
Interpretation
Any legal requirements and regulations that apply to yourorganisation issued by a governmental authority which maybe international, national and local that has legal force shouldbe identified and factored into your operations.
These may include:
• legislation including acts (statutes) and regulations,
• decrees and directives,
• licences, permits, consents and authorisations,
• orders issued by a regulatory body (e.g. enforcement notice),
• court judgements,
• treaties, conventions and protocols.
It may assist your organisation to go “beyond compliance”with existing legal requirements. It may give you acompetitive advantage and enhance your reputation andrelationship with interested parties to go beyond compliance.
In addition to legal requirements, the standard also talksabout “other requirements” to which the organisationsubscribes. These “other requirements” may include:
• agreements with public bodies,
• customer agreements,
• guidelines,
• certification standards,
• industry codes of practice,
• corporate policies and requirements,
• pollution prevention guidelines,
• process guidance notes.
As the standard refers to all requirements that relate to yourenvironmental aspects, it means that you must not only takeinto account directly applicable environmental legislation butother requirements that may relate to your aspects such asCOMAH (Control of Major Hazards and Accidents).
You must also ensure that you have ready access to relevantlegislation. It is particularly important to ensure that you arekeeping up to date with any changes or any new requirements.
You need to ensure that you determine how these legal andother requirements apply to your aspects. For example, youmay have identified waste generation as an aspect and you mayhave identified that one of the applicable legal requirements isthe Environmental Protection (Duty of Care) Regulations 1991.You now need to determine how this will impact on you such
as preventing the escape of waste, only using a registered wastecarrier and ensuring that you keep transfer notes for a periodof two years after the disposal of the waste.
As with your significant aspects, you must not forget toconsider applicable legal and other requirements when youestablish and implement your EMS and during themaintenance of your EMS.
Hints for implementation
Considering the large volume of legislation now applicable toorganisations, this element of ISO14001 may seem like aparticularly daunting task. Nevertheless there are severalways in which your organisation can obtain informationabout applicable laws or regulations, without resorting toexpensive legal advice. These include:
• environmental business journals/newsletters/magazines,
• environmental compliance manuals,
• advice from regulatory agencies (e.g. the EnvironmentAgency, or local authorities) including NetRegs,
• trade associations (e.g. The Engineering EmployersFederation),
• environmental business clubs and networks,
• public libraries,
• the Internet (e.g. The Stationary Office web page),
• customers, suppliers and other companies.
Your organisation must establish a procedure for identifyingand having access to applicable legal and other requirements.The certification body will also want to see evidence thatyour company has evaluated compliance and that the EMS isdesigned to deliver compliance. It may be that you wish to
develop and implement internal performance criteria todemonstrate that you have met your requirements. Anexample of this may be limitations on the use of certainhazardous substances or limitations on discharges to thewater environment that are tighter than those permitted in adischarge consent. Where non-compliance is identifiedappropriate actions should be taken to rectify the situation. Itwould, therefore, be good practice to establish some sort ofmanual/register showing that you have identified the relevantlegislation and how it applies to your aspects anddocumented current controls for compliance. This manual orregister should be reviewed and updated as circumstanceswithin the organisation and your associated aspects changeand legislation evolves.
A pro-forma for this register could include the following headings:
• précis of legislation,
• purpose of legislation,
• coverage/scope of legislation,
• compliance requirements,
• current compliance status,
• responsibility for compliance,
• evaluation of compliance frequency.
Not only will this register provide evidence that you haveidentified and have access to legislation, but it will also providean excellent tool for training staff in legislative awareness.
Common non-conformities
Certification to ISO 14001 is likely to be withheld if a seriouslegislative breach is identified. Only in circumstances where adocumented agreement has been reached with a regulatormay certification be recommended.
Other potential non-conformities include:
• procedures not established or maintained,
• identification of legal requirements not sufficientlycomprehensive,
• little or no reference to other requirements,
• failure to recognise how laws, regulations or otherrequirements are relevant to the environmental aspects ofthe organisation,
• access to legal and other requirements cannot bedemonstrated,
• legal requirements not sufficiently considered within theoverall EMS,
• evidence of legal compliance cannot be demonstrated.
Self-assessment questions
• Have you identified applicable legal and other requirementsrelevant to your organisation’s environmental aspects?
• Have you determined how these requirements apply toyour aspects?
• Have you established and documented a procedure foraccessing and keeping up-to-date?
• Have legislative requirements been factored into theestablishment, implementation, maintenance and controlsof your management system?
• Is there a procedure to deal with any non-complianceidentified?
4.3.3 Objectives, targets and programme(s)
Introduction
Following your environmental aspects assessment, you willhave identified several aspects, some of which may be classedas significant. In addition, your review of relevant legal andother requirements may have highlighted areas of complianceobligations requiring tighter control. These issues will need tobe incorporated within your EMS. To enable this, you musttake the next step of setting objectives and targets andputting in place a programme. This programme is an actionplan that describes how the organisation will translate itsobjectives and targets into actions.
Moreover, your environmental policy contains a commitmentto continual environmental improvement so it is critical thatyour objectives reflect any aspirations outlined in your policy.The ongoing achievement of objectives will also provide clearevidence to the certification body that the EMS is effective indelivering continual improvement.
ISO 14001 requirements
The organisation shall establish, implement and maintaindocumented environmental objectives and targets, atrelevant functions and levels within the organisation.
The objectives and targets shall be measurable, wherepracticable, and consistent with the environmentalpolicy, including the commitments to prevention ofpollution, to compliance with applicable legalrequirements and with other requirements to which theorganisation subscribes, and to continual improvement.
When establishing and reviewing its objectives andtargets, an organisation shall take into account the legalrequirements and other requirements to which theorganisation subscribes, and its significant environmentalaspects. It shall also consider its technological options, its
financial, operational and business requirements and theviews of interested parties.
The organisation shall establish, implement and maintaina programme(s) for achieving its objectives and targets.Programme(s) shall include:
a) designation of responsibility for achieving objectives and targets at relevant functions and levels of the organisation,
b) the means and time-frame by which they are to be achieved.
Interpretation
Now that your organisation has identified its significantenvironmental aspects and understood what its legal dutiesare, the standard now asks you to factor these into the EMS.This does not mean that you must set improvementobjectives for every significant environmental aspect.Financial resources may not allow this, but you should at leastset objectives to ensure that the associated impacts areeffectively managed and controlled.
When setting objectives, consider your environmental policy,including its three core commitments. You must ensure thatyour objectives and targets are consistent with yourcommitment to compliance with legal and other requirementsand to continual improvement. You should also consider theviews of interested parties, your technological options, andfinancial, operational, and other business requirements.
It is critical that your objectives and targets are appropriateto your organisation. You need to ensure that the objectivesand targets that you do set are measurable where it ispracticable to do so. You also need to have objectives whichrelate to the entire organisation and the functions and/ordepartments that exist within your organisation, in this casethey will apply specifically to individual departments, activities,and services.
Once the objectives and targets have been agreed, the nextstep is to prioritise these and allocate resources andresponsibilities in agreement with managers and employees.These take the form of a management programme whichdetails who is going to do what and by when.
To ensure its effectiveness, your environmental managementprogramme should:
• designate responsibilities for achieving goals,
• define the means and time frame for achieving those goals.
Remember that your programme should be dynamic. Theprogramme should be modified when:
• objectives and targets are revised or added,
• progress in achieving your objectives and targets is madeor not made,
• products, processes and/or facilities change or otherfactors arise.
Your action plan need not be compiled into a singledocument. A “road map” to several plans is an acceptablealternative, as long as the key responsibilities, tactical steps andschedules are adequately defined in these other documents.
Hints for implementation
As part of your policy commitment to continual year-on-yearenvironmental improvement, you will make gradualimprovement, but not necessarily in all areas of activity or at alltimes. Your objective and targets should, therefore, reflect thiscommitment. Essentially, there are three types of objectives thatyou may wish to consider setting. These include:
• monitoring or investigative e.g. monitoring of energy consumption,
• management of control e.g. preparing procedures for thecontrol of emergency incidents/provide training on energyefficiency initiatives to staff,
• improvement e.g. the construction of bund walls to reducethe problems caused by spills of oil from tanks.
Keep your initial objectives simple, gain some early successes,and then build on them. Communicate objectives and targets(as well as your progress in achieving them) to all levels ofthe organisation. Consider a regular report on progress atstaff meetings.
The success of your EMS will often depend upon theenthusiasm of your staff. To engage their interest and buildcommitment, consider involving them when settingobjectives. Their knowledge and experience will often meanthat they are ideally positioned to establish, plan for, andachieve these goals.
For each objective, you should then set detailedperformance targets. Wherever possible, targets should beSMART:
• Specific,• Measurable,• Achievable,• Realistic and• Time-scales set.
In this way, the company will achieve its targets and achieveits objectives, which in turn demonstrates implementation ofits environmental policy. The environmental objectives ofyour organisation should be incorporated into your overallmanagement objectives.
As your objectives and targets need to be measurable wherepracticable, you should establish some form of measurableenvironmental performance indicators. These can be used totrack your performance and should be appropriate to whatyour organisation does and what it is trying to achieve.
Some simple tips for effective implementation of a programmeinclude:
• early involvement of employees in establishing and carryingout the programme,
• clear communication on the expectations andresponsibilities laid out in the programme to those whoneed to know,
• build on current plans and/or programmes for health andsafety or quality management.
Objectives Targets Performance Indicator
Minimise hazardous waste Reduce waste lubricating oils Waste produced per quantitygeneration by 25% in 2007 of product
Improve compliance with effluent Install automated monitoring Investmentdischarge permit limits equipment by the end of 2007
Reduce energy use Reduce electricity use by 5% in 2007 Amount of energy used
Reduce natural gas use by 10% in 2007
Improve employee awareness Hold monthly awareness training courses Number of incidents and accidentsof environmental issues
Train all employees by end of year
Reduce usage of hazardous chemicals Eliminate use of solvents in 2007 Quantity of raw material used
Reduce use of solvent-based cleaners by 50% by end of 2007
Examples of Objectives and Targets
Environmental Policy RequirementCommitment to prevention of pollution
Legal and Other RequirementsEnvironmental Protection ActWater Resources Act Hazardous Waste Regulations Control of Substances Hazardous to Health Regulations
Significant Environmental AspectConsumption of 1.6 tonnes of solvent-based materials per annumImpactsStorage, transport, use and disposal of solvent based materials presents environmental impacts in terms of land andgroundwater contamination, VOCs (volatile organic compounds) from solvents are a known greenhouse gas and theycontribute to the creation of ground level ozone gas.
ObjectiveTo reduce the consumption of hazardous chemicals TargetsEliminate use of solvents by 2007Reduce use of solvent based cleaners by 50% Train all employees on how to minimise use of cleaners by end of 2007
Task Items
Investigate potential alternative solvent-free cleaners
Develop techniques to reduce use of solvent-based cleaners
Develop training package on solvent minimisation techniques
Responsibility
LA
MG
MG
Start
1 July
1 July
30 Sept
Finish
30 Sept
30 Sept
15 Nov
Example Programme
Common non-conformities
Some of the most common non-conformities for this clauseinclude:
• objectives and targets do not reflect policy requirements,
• objectives and targets do not demonstrate continualimprovement,
• they are not linked to the identified significant aspects andlegislative requirements,
• objectives and targets are not set across all relevantfunctions and levels of the organisation,
• they are not documented and distributed to relevantsections for action,
• responsibilities are not adequately defined,
• no detailed means of achieving objectives and targets aregiven in a programme,
• environmental aspects of new projects are not consideredwithin the programme,
• time-scales are not met and/or are unrealistic,
• no demonstration of continual improvement.
Self-assessment questions
• Do you have documented objectives and targets atrelevant functions and levels within the organisation?
• Have you ensured that your objectives and targets areconsistent with the environmental policy (includingcommitments to pollution prevention, continualimprovement, and compliance)?
• Do the objectives and targets reflect legal and otherrequirements and the significant environmental aspects ofyour organisation?
• Have you considered technological options, financial,operational, business requirements and the views ofinterested parties?
• Have you established a process for tracking and reportingprogress and conformance with objectives and targets?
• Have you established an action plan or programmedetailing how you will meet your objectives and targets?
• Do they include responsibilities, means and time frames towhich they are to be achieved?
• Have you internally communicated the plan to relevantfunctions and levels of your organisation?
4.4 Implementation and operation
4.4.1 Resources, roles, responsibility and authority
Introduction
Despite playing a fundamental role, organisational and humanaspects of environmental management are often overlookedin comparison to the more physical and technical aspects ofenvironmental control. As a result many systems are poorlyunderstood and attract little or no support from staff.
When establishing your environmental management system itis critical to consider this human dimension. You shouldencourage participation at all levels within the companyincluding top management, middle management andoperational staff. For your system to be effective you mustalso clearly define and communicate each person’s rolewithin the system, whether it is the managing director or thewaste co-ordinator.
ISO 14001 requirements
Management shall ensure the availability of resourcesessential to establish, implement, maintain and improvethe environmental management system. Resourcesinclude human resources and specialised skills,organisational infrastructure, technology and financialresources.
Roles, responsibilities and authorities shall be defined,documented and communicated in order to facilitateeffective environmental management.
The organisation’s top management shall appoint aspecific management representative(s) who, irrespectiveof other responsibilities, shall have defined roles,responsibility and authority for:
a) ensuring that an environmental management system is established, implemented and maintained in accordance with the international standard,
b) reporting to top management on the performance ofthe environmental management system for review, including recommendations for improvement.
Interpretation
At an early stage of the EMS top management should play akey role by providing the resources needed to ensure thatthe EMS is implemented effectively. Ensuring this capability isone of the most important jobs of top management. Theseresources should take the form of adequate humanresources, skilled staff, technology and financial resources.You should make sure that these resources are providedwhen required and in an efficient manner.
In particular, your organisation should have contingency plansin case key personnel in terms of the EMS leave theorganisation. The standard refers to “ensuring the availability”not just provision of resources, such that competent peopleare available to fulfil EMS specific roles.
The time taken and resources required to develop thesystem will depend upon a number of factors including:
• site environmental conditions,
• process complexity,
• presence of other management systems (including ISO 9001 and OHSAS 18001),
• environmental knowledge and experience of staff,
• availability of staff,
• availability of outside consultancy support.
The cost of the effort of implementation of your systemshould be set against the savings that are often gained fromtaking more effective control of resource use and wasteproduction. Once these savings have been taken intoaccount the EMS often delivers a net pay back.
Any effective management system will need an advocate orchampion. This person will drive the system and ensure thatmomentum and enthusiasm for environmental improvementis spread throughout the company and thatrecommendations on how to improve the organisationsenvironmental performance are made to management. Theyshould therefore be carefully selected by top managementand given three core responsibilities. They should:
• ensure that the EMS is effectively established, implementedand maintained,
• report on its performance over time to the managementteam including recommendations for improvement and,
• work with others within the company to modify andimprove the EMS to deliver continual environmentalimprovement.
Hints for implementation
For smaller organisations defining additional resources andresponsibilities will not be an easy process. When identifyingthe resources that you will need to ensure successfulimplementation and running of an EMS look into thefollowing:
• infrastructure and organisational structure,
• IT systems,
• training and competence,
• technology,
• financial resources,
• other resources that may be specific to your organisation and its activities,
• current and future needs.
Wherever possible, try to make the best use of limitedresources by using existing management frameworks andkeeping the structure as simple as possible when identifyingresponsibilities and authority. Considering the following issueswill help you to set the right organisational structure for yourEMS.
Existing responsibilities and structures
Firstly review current written or unwritten structures forenvironmental management. Also consider integratingenvironmental responsibilities within existing quality, healthand safety, or other related functions. This will help tosimplify the management structure and reduce unnecessaryadministration.
Also think about the results of previous quality or health and safety audits. What does this information tell you aboutthe effectiveness of the existing structure and how it couldbe improved?
Significant environmental impacts
Your EMS should be focused towards controlling andmanaging your significant environmental impacts so it isimportant to consider which operations these relate to.Then determine who already manages these operations.Could they be used to manage environmental controls?
Objectives and targets
Consider who you have assigned to implement the objectivesand targets and relevant management programmes.
Once you have established the general structure for yoursystem the next step is to document it. One of the mosteffective ways to do this is through organisational charts.These charts are often found in quality manuals or businessplans, as they simply and clearly outline the overallmanagement structure. There are many other ways in whichyou could document specific responsibilities including:
• job descriptions,
• system procedures,
• operational procedures,
• environmental management programmes,
• minutes of meetings,
• memos.
Above all the most important issue to remember iscommunication. Do not forget to tell people what their rolesare (as well as the roles of others) and if these roles changemake sure people are kept up-to-date.
You should ensure that you are reviewing, on a regular basis,the allocation of resources and responsibilities.
Common non-conformities
In most companies responsibilities are clearly defined inorganisational charts, but changes may need to be made toincorporate environmental responsibilities. It is important toensure that the appropriate resources are available. Potentialnon-conformities include:
• appropriate resources not available,
• no contingency plans relating to ensuring the availability ofappropriate resources relating to the EMS,
• management representative responsibilities are not clearlydefined,
• failure to identify environmental responsibilities andauthorities of other personnel,
• meaningful changes to job descriptions are oftenoverlooked,
• responsibilities often not communicated to relevantpersonnel,
• no evidence of the environmental managementrepresentative reporting to top management on theperformance of the EMS.
Self-assessment questions
• Have your management team ensured the availability ofadequate resources to implement and control theenvironmental management system?
• Have you defined and documented roles andresponsibilities for environmental management?
• Have these roles been communicated to all relevant staff?
• Do you have an appointed environmental managementrepresentative?
• Have you documented their specific roles in establishingimplementing, maintaining and reporting on theeffectiveness of the EMS including improvements?
4.4.2 Competence, training and awareness
Introduction
Competence and training is often seen as a difficult issue,particularly in smaller companies, because of the costimplications that it often brings. However, if done properlytraining and ensuring appropriate competence throughoutthe organisation can produce several tangible benefits. Thesemay include a reduction in the consumption of raw materialand resources such as energy, fewer accidents and incidentsand greater efficiency overall.
For your EMS to be effectively implemented, it is vital thatstaff are competent to perform their appropriate tasks and that if a gap is identified in their abilities then theappropriate training and awareness is given. One reason forthis is that some of the most severe environmental impactsare caused by staff unsure or unaware of the correctprocedures. In addition, all staff will have some impact upon the environment (to a greater or lesser degree).Training and awareness will help to engage their interest inhow they can contribute to the overall environmentalimprovement effort.
ISO 14001 requirements
The organisation shall ensure that any person (s)performing tasks for it or on its behalf that have thepotential to cause a significant environmental impact(s)identified by the organisation is (are) competent on thebasis of appropriate education, training or experience,and shall retain associated records.
The organisation shall identify training needs associatedwith its environmental aspects and its environmentalmanagement system. It shall provide training or takeother action to meet these needs, and shall retainassociated records.
The organisation shall establish, implement and maintaina procedure (s) to make persons working for it or on itsbehalf aware of:
a) the importance of conformity with the environmentalpolicy and procedures and with the requirements of theenvironmental management system;
b) the significant environmental aspects and relatedactual or potential impacts associated with their work,and the environmental benefits of improved personnelperformance;
c) their roles and responsibilities in achieving conformitywith the requirements of the environmentalmanagement system and
d) the potential consequences of departure fromspecified procedures.
Interpretation
Persons working for or on behalf of the organisation isbroader than just employees. You must make sure that allrelevant persons are competent and this may includecontractors, subcontractors, temporary staff and remote
workers. Records must be retained by your organisation thatdemonstrate by means of a combination of education,training and experience these persons are competent toperform their tasks if it has the potential to cause a significantenvironmental impact.
On the whole, ISO 14001 requires you to give all personnelworking for or on its behalf some degree of training orawareness on environmental issues and the EMS. The degreeand scope of this training will depend upon each personsspecific job function. This raises the logical questions “Whoneeds to know what and how can we do it?”
Your next step should therefore involve identifying your skillsand competence needs. In assessing these needs, you shouldconsider both the general and specific aspects of training. Forinstance, your environmental management representativeand audit team will require detailed training in auditingtechniques. Whereas your administration staff may only needto know about the policy and the general environmentalimpacts of office based activities.
You must as a minimum make staff aware of:
a) the importance of conformance with the environmentalpolicy and EMS requirements,
b)the significant environmental impacts of their workactivities,
c) their roles and responsibilities in achieving conformity withthe environmental policy and relevant procedures,
d)the potential consequences of departure from specifiedprocedures.
All personnel should receive appropriate training. However,training is just one element of establishing competence,which is typically based on a combination of education, skillsand experience. For certain key roles (including tasks, whichcan or may cause significant environmental impacts), you
should establish criteria for measuring the competence ofindividuals performing those tasks. A training programmeshould reflect the responsibilities defined within the EMS.
It is also vital that you keep records of the training you havedelivered or attended. This issue is specifically required lateron in the system under records.
Hints for Implementation
The process of establishing competency can be a lengthyprocess. Because of the time involved in conducting a trainingneeds analysis and developing a training programme, look towhat your organisation has in place for other issues pertinentto your organisation such as quality or health and safety. Youmay wish to consider using such opportunities to incorporateenvironmental training.
Also look at current staff knowledge, understanding,experience, abilities and qualifications and build upon it. Yourexisting quality auditing team could be used for EMS audits ifthey are given appropriate instruction, training and supporton the issues to look out for such as environmental aspectsand appropriate legislation.
If taking staff away from the organisation is a problem,consider scheduling training opportunities to coincide withother meetings. For example, safety meetings, staff meetingsand operational briefings.
When identifying your training needs and developing yourtraining plan do not forget contractors, suppliers and newemployees. You may wish to develop an induction packcontaining guidance notes, the environmental policy andrelevant procedures. Also consider environmental skillsrequirements in your recruitment and tendering processes.This will help to reduce the costs of your training. It will alsogo some way to ensure that staff and contractors arecompetent to perform tasks.
Another way to help ensure competency is to questionemployees (involved in critical functions) on how theyperform various aspects of their jobs and get them todemonstrate them. Use the responses to determine whetherthey have the requisite skills and understanding to do the jobcorrectly. This will help you gauge whether additional trainingmay be needed.
Common non-conformities
This area of ISO 14001 is commonly cited as an area where anon-conformity can arise. Possible non-conformities with anEMS include:
• competence analysis not completed for all personnel ateach relevant function and level in the organisation,
• appropriate training not delivered especially where a gap incompetence has been recognised and a training need hasbeen identified and potential environmental impacts areassociated with particular responsibilities,
• competence can not be demonstrated or is inadequate orincomplete, particularly for emergency preparedness andresponse,
• competence for persons other than employees whose rolemay have potential or actual significant environmentalimpact such as sub-contractors, cannot be demonstrated,
• failure to keep competence records up to date or toundertake an evaluation process to check competence.
Self-assessment questions
• Has competency for those persons performing tasks thathave a potential to cause a significant environmentalimpact been established?
• Has a training/competency analysis been carried out?
• Has a training or action plan been developed?
• Has appropriate training been delivered or other actiontaken to meet the needs identified in the analysis at alllevels and within all functions?
• Are records kept to demonstrate competency?
• Are training records kept?
4.4.3 Communication
Introduction
No organisation operates in isolation. Whether yourorganisation is small or large you may be continuouslysending out messages to a wide range of stakeholders aboutyour environmental performance. It is critical, therefore, thatyour company projects the right kind of image, which reflectsthe concerns and interests of your business as a whole.
Despite this, communication is often overlooked inenvironmental management, largely due to the fact thatmany firms are unaware of who their audience is and whatmessage they are sending them.
A concept often described in environmental management isstakeholder pressure. This is generally taken to mean theinfluence that outside interested parties have on yourenvironmental performance. These stakeholders includeregulators, local communities, customers and competitors toname but a few. Equally, there are also internal stakeholders,such as employees, managers, contractors and shareholders,who will have a vested interest in how you performenvironmentally.
Taking control of communication will not only help youpromote a “greener” image in the market place, but it willalso ensure that your EMS is run effectively from within.
ISO 14001 requirements
With regard to its environmental aspects andenvironmental management system, the organisationshall establish, implement and maintain a procedure(s)for:
a) internal communication among the various levels and functions of the organisation,
b) receiving, documenting and responding to relevant communication from external interested parties.
The organisation shall decide whether to communicateexternally about its significant environmental aspects, andshall document its decision. If the decision is tocommunicate, the organisation shall establish andimplement a method(s) for this external communication.
Interpretation
ISO 14001 requires you to establish effective procedures for:
• receiving, documenting and responding to externalcommunications,
• communicating internally between levels and functionswho may need information, for example, to comply withlicences or legislation.
The purpose and benefits to this can include demonstratingthe organisations commitments to the environment and tocontinual improvement and raising awareness of such issues.
The key to external communication is to take control of theprocess. This will ensure that you are sending out the rightmessage. Think about what you want your stakeholders tothink or feel about your organisation. Communication is notjust about public relations. It is about actively understandingthe concerns of neighbours, community groups, andcustomers. This will allow you to consider their concerns
when setting objectives and targets. You should also have aprocedure for responding to complaints regardingenvironmental issues perhaps feeding them into the non-conformity/corrective action loop where necessary.
If your organisation makes the decision to communicate yoursignificant environmental aspects then you must decide howyou are going to do this. You must also document thisdecision. Most organisations do communicate about this issue;sometimes this may be by the use of an environmental logoor by publishing an environmental report. Often it can be byway of only responding selectively to those that ask specificquestions regarding your environmental performance; thiscould be through a customer questionnaire. Organisationsthat fall under certain regulatory regimes also communicateinformation on their significant aspects through monitoringreturns to its regulator. It is likely that only a small number oforganisations that implement an EMS will not communicate insome way on their aspects.
Internal communication is also fundamental to the effectivefunctioning of the EMS. It should be seen as a two-wayprocess allowing information to flow from the top-down andthe bottom-up. This will have several benefits, such asimproved employee motivation and participation. Moreover,staff are often an excellent source of information and ideas.Encouraging bottom-up communication will allow you toidentify potential improvements or rectify problems at theearliest opportunity.
Hints for implementation
The first step in designing a communications procedure is todetermine who is your audience. Make a list of internal andexternal audiences. Next, decide how you can best reachthem. Appropriate communication methods might vary fromgroup to group. Start by looking at your existing methods forcommunicating, both internally and externally. For instance, ifyou have a QMS consider using the complaints procedure todeal with environmentally related complaints.
Internal communication methods that have proved effectivein a variety of organisations include circulation of minutes ofmeetings, bulletin boards, posters, internal newsletters,suggestion schemes and suggestion boxes, websites, e-mailup-dates and establishing committees.
Remember communication is a continual process. Anycommunication strategy that focuses on one-off or short-term goals is unlikely to yield significant benefits and could becounter productive. Most organisations use a range ofmethods to provide an overall effective communicationstrategy.
Determine how proactive will be your externalcommunications strategy. Select an approach that fits yourorganisation’s culture and strategy. If you are part of a largerorganisation there may be a corporate policy regardingrelease of environmental information.
Communication with external stakeholders can be a veryeffective tool for environmental management and inpromoting the green credentials of your organisation. Bybeing proactive in the methods that you select you canenhance this. You should obviously consider the costsassociated with any methods that you select and ensure thatthe benefits justify the cost. One area to consider is how youwould communicate externally in the event of an accident oremergency situation to those who may be affected such asneighbours and regulators or those that would becomeinterested in such a situation for example, the press.
Again, there are various methods that have been tried andtested when it comes to communicating with externalparties. These includes informal discussions, open days, focusgroups with the local community, involvement in communityevents, press releases, websites, regular newsletters,published environmental reports and posting information in alocal library.
The information that is communicated also varies and willdepend upon your environmental aspects. It could include butis not limited to:
• general information about your organisation,
• environmental policy,
• commitment to pollution prevention and continualimprovement,
• your position relating to compliance with legal and otherrequirements,
• objectives and targets and strategies to improveperformance,
• information relating to the aspects of your products,activities and services,
• trends in your environmental performance,
• actions taken in response to accidents and incidents,
• contacts within your organisation,
• other relevant info such as how to obtain a copy of anenvironmental report,
• website details, focus groups etc.
Communication is important in ensuring effective function of theEMS internal and external communication can be used to thebenefit of your organisation by demonstrating to regulators,customers and the community at large that you have made acommitment to improving your environmental performance.
Common non-conformities
Potential non-conformities in this area of the standard include:
• communication procedures not established nor maintained,
• complaints recorded but not properly communicatedinternally,
• responses to communications not recorded in accordancewith procedures,
• poor communications with stakeholders and otherinterested parties such as contractors and suppliers,
• no record on the decision to communicate significantenvironmental aspects,
• the environmental policy is not publicly available ordisplayed in the workplace,
• internal communication is often neglected,
• training programmes, team briefings andrecommendations for improvement, etc not adequatelycommunicated.
Self-assessment questions
• Have you established a procedure for internalcommunication between various levels and functions?
• Are staff aware of the procedure?
• Do staff know how to handle a complaint or query?
• Have you established a procedure for receiving,documenting and dealing with communications fromexternal interested parties?
• Have you decided and implemented a methodology forcommunicating information on your environmentalaspects externally?
• Have you recorded your decision on whether toexternally communication on your significantenvironmental aspects?
4.4.4 Documentation
Introduction
Although documentation seems like the most bureaucraticelement of ISO 14001, it is difficult to imagine any managementsystem working consistently and effectively without clearinstructions. Simply, documentation provides the theoreticalintentions that will be put into practice by your company. YourEMS documentation will also act as a “road map” explaininghow each element of the system fits together.
ISO 14001 requirements
The environmental management system documentationshall include:
a) the environmental policy, objectives and targets,
b) description of the scope of the environmentalmanagement system,
c) description of the main elements of theenvironmental management system and theirinteraction, and reference to related documents,
d) documents, including records, required by theInternational Standard,
e) documents, including records, determined by theorganisation to be necessary to ensure the effectiveplanning, operation and control of processes thatrelated to its significant environmental aspects.
Interpretation
To ensure that your EMS is operating as originally intendedyou should establish a series of documents to describe thecore elements of the system and how each element relatesto each other. The documentation will help to ensureconsistent application of the system by providing clear
information to people carrying out tasks. In addition, externalparties (such as the certification body) will need tounderstand how your EMS is structured before they canverify that it meets the requirements of ISO 14001.
The standard requires you to look at your system and definehow you wish to run it. This should be a compilation of thebest practices and current methods. The golden rule is “writedown what you do and do what you have written down”.
Hints for implementation
ISO 14001 requires information, to be kept in paper orelectronic form, to describe the core elements of the EMSand provide reference to other related documents. Mostcompanies achieve this through the creation of a manual orhandbook. This will give the structure and pointers to wherethe organisations management system delivers therequirements of ISO 14001. Remember that there is no rightor wrong way to structure an EMS.
Some organisations choose to deliver elements of the EMSthrough existing procedures that are in place through theirquality management system or health and safety managementsystem. This will avoid duplication.
One way to think about your EMS documentation is to usethe figure shown below, which also applies to an ISO 9001documented system.
ISO 14001 DocumentHierarchy
The top manual acts as a series of explanations or statementsof how core elements of ISO 14001 apply to yourorganisation. It should also be a permanent documentedreference describing the system and referencing otherrelated procedures and records.
Try to keep your EMS documentation short and simple. Alsouse a format that currently works well for your company andcross-refer to other systems, which may meet your EMSstandard requirements (for instance, procedures for non-conformity and corrective actions under quality or health andsafety systems).
The EMS documentation does not need to describe everydetail of your EMS. It should however provide cross-references to other procedures and systems your companymay have e.g. ISO 9001, OHSAS 18001 etc.
If you have universal access to computers around yourorganisation, contemplate installing the documentation in anelectronic format. This has a number of advantages, such aseasier updating, access control, and ensuring that all readersuse the most up-to-date version of a document.
Common non-conformities
Potential non-conformities in this area include:
• documentation does not describe core elements of thesystem,
• documentation does not direct the user to relateddocumentation of the EMS,
• interfaces with the system are not clearly defined,
• the EMS does not cross reference procedures from othersystems such as health and safety or quality which deliverpart of the EMS.
Self-assessment questions
• Have you established a documented description of theEMS including the environmental policy, key systemprocedures, and relevant forms?
• Is a documented system established in paper or electronicform?
• Does this documented system explain the linkagesbetween system elements?
• Are appropriate linkages with other systems fullydocumented?
4.4.5 Control of documents
Introduction
The control of documents is the “hub” of any managementsystem and it is of vital importance to ensure that up to dateinformation is provided to the people who need it. Thismeans that you know where all the controlled documentsare situated and at what issue level they are.
You should ensure that the right documents are available at the right place and the right time. This will make sure that everyone is working with the right information or “singing from the same hymn sheet.” Procedures for dealing with changes and modifications must also beimplemented.
ISO 14001 requirements
Documents required by the environmentalmanagement system and by the International Standardshall be controlled. Records are a special type ofdocument and shall be controlled in accordance withthe requirements given in 4.5.4
The organisation shall establish, implement and maintaina procedure(s) to:
a) approve documents for adequacy prior to use,
b) review and update as necessary and re-approvedocuments,
c) ensure that changes and the current revision status ofdocuments are identified,
d) ensure that relevant versions of applicable documentsare available at points of use,
e) ensure that documents remain legible and readilyidentifiable,
f) ensure that documents of external origin determinedby the organisation to be necessary for the planningand operation of the environmental managementsystem are identified and their distribution controlled,
g) prevent the unintended use of obsolete documentsand apply suitable identification to them if they areretained for any purpose.
Interpretation
The requirements for document control under ISO 14001are a close reflection of the ISO 9001 standard. Thereforeorganisations that have a certified quality managementsystem are likely to have an advantage in this section.
Even if you do not have a quality management system, youmay have document controls for other business purposes(e.g. finance). It is worthwhile assessing how these controlsmay be adapted for your EMS.
As control of documents is a key issue in the operation of anEMS, only approved information should be provided and this
must be controlled by issue status and individual copynumber. Information needs to be accessible to all staff thatmay need it and any obsolete information withdrawn. Youwill also need to be identifying changes to versions ofdocuments that the organisation issues, for example, bytracking changes or a revision index.
All controlled documentation must be reviewed andapproved for adequacy. This is best carried out by the‘expert’ on the subject, probably the writer of the procedureor work instruction. Approval at this level also aids‘ownership’ of the system.
Documents shall be legible, dated (with dates of revision)and readily identifiable, maintained in an orderly manner andretained for a specified period. Procedures andresponsibilities should be established and maintainedconcerning the creation and modification of the varioustypes of document.
You must also consider how you are going to controlexternal documents including how they are identified withinyour system and how they will be distributed. This may applyto documentation such as a licence or permit issued by aregulatory body.
Hints for implementation
With the control of documents you should “keep it simple.”Do not make your procedure more complicated than itneeds to be. Limiting distribution also makes the job easier.For a small organisation it is often better to issue one manualwith all relevant documentation to the areas needing it. Thismeans that all documents will be in the same place andrequire the same action to keep them up to date. Alldocuments issued should be logged and controlled on amaster list.
The types of EMS documentation that should be controlledinclude:
• environmental policy,
• EMS manual,
• EMS systems procedures,
• forms or drawings,
• any working instructions/operational procedures,
• external documents that form part of your EMS e.g.licences, consents or permits, drainage plans from thesewerage undertaker etc.
The following aspects of documentation control can often befound on some of the most effective systems:
• unique titles,
• issue and revision date,
• effective date,
• approval signature,
• revision number and changes,
• documentation number (or other identifier),
• copy number,
• cross references.
It is also a good idea to establish a procedure regardingphotocopying of controlled information. Generally, it shouldbe discouraged. However, in some circumstances, it may beneeded. One method of ensuring no photocopies are madeis to use colour as identifying the authorised copies. Obsoletedocuments need to be taken out of the system to ensurethat they are not inadvertently used.
If all staff that need access to documents have access to acomputer, it may be worth considering an electronic system.This can significantly reduce the administrative work involvedin document control.
Prepare a document control index that shows all of yourEMS documents and the history of their revision and changesmade. Put this index in your manual. Also, if multiple copiesof documents are available at the facility, prepare adistribution list, showing who has each copy and where thecopies are located.
The review and approval of documents should be designatedas a task to individuals within your organisation that haveboth sufficient organisational authority and the technicalcapability to carry out this important function. Rememberthat all documents should be approved for adequacy prior touse by the most relevant and appropriate person.
Common non-conformities
Some of the most common non-conformities found bycertification bodies include:
• documents of external origin are not identified or theirdistribution controlled,
• documents are not approved for adequacy prior to use,
• documents and procedures are not available to those whoneed them,
• procedures and responsibilities for creating, modifying andcontrolling documentation are not properly defined,
• a document review process is not established. This maylead to obsolete documents still being in circulation andcurrent versions of documentation not being available,
• regular audits to establish effective documentation controlare not carried out.
Self-assessment questions
• Have you prepared a procedure to control EMSdocumentation including documents of external origin?
• Have you decided who needs access to copies ofdocuments and how many you will need?
• Have you established responsibilities and authorities fordocument preparation, approval for adequacy, revision,management, and removal?
4.4.6 Operational control
Introduction
Once you have put in place the structural elements of yourEMS the next stage is to prepare and implement controlmeasures to maintain and improve your environmentalperformance. These should apply, where appropriate, toactivities, products and services with significant environmentalaspects. These controls should also actively reflect thecommitments of your policy and the goals laid down in yourobjectives and targets. In fact these controls will in manyways provide the framework for their delivery.
Preparing these controls is only the first stage. They will haveto be implemented on an on-going basis and later audited toensure employees follow them.
ISO 14001 requirements
The organisation shall identify and plan those operationsassociated with the identified significant environmentalaspects consistent with its policy, objectives and targets,in order to ensure that they are carried out underspecified conditions, by:
a) establishing, implementing and maintaining adocumented procedure(s) to control situations wheretheir absence could lead to deviations from theenvironmental policy, objectives and targets,
b) stipulating operating criteria in the procedure(s),
c) establishing, implementing and maintainingprocedures related to the identified significantenvironmental aspects of goods and services used bythe organisation and communicating applicableprocedures and requirements to suppliers includingcontractors.
Interpretation
Determining which operations should be covered bydocumented procedures and how those operations shouldbe controlled is a critical aspect of developing an effectiveEMS. In deciding which activities need to be controlled, startby looking at the significant environmental aspects. Identifythe processes from which significant impacts arise, andconsider what types of controls might be needed to preventor manage these impacts.
If you are a manufacturing organisation, you should lookbeyond production activities by considering maintenance,contractors and relationships with suppliers, all of which cansignificantly affect your organisation’s environmentalperformance.
Moreover, documented procedures should cover thosesituations where the absence of procedures could lead todeviations from the environmental policy or from yourobjectives and targets.
Hints for Implementation
The most important step in developing operational controlsis to understand the activity. Concentrate on the criticalpoints of the activity that need to be managed to ensureconsistent control or improvement of environmentalperformance.
Start the process by developing draft procedures withemployees who at a later stage have to implement them.This will encourage their participation and the procedure ismore likely to succeed. Also consider existing procedures forquality and health and safety. Some of these may beadequate to control significant environmental aspects.
You may find that some of your significant aspects relate togoods purchased from suppliers. In addition, the activities ofcontractors may also affect your environmental aspects. It isvital, therefore, that controls covering their work areeffectively communicated to them.
Whenever possible, try to keep procedures short andsimple. Long-winded procedures do not add any greaterdegree of control.
As a general rule of thumb the more highly skilled andtrained your employees are, the less critical procedures willbe. The more complex the work or the greater the potentialimpact on the environment, the more important theseprocedures are.
Common non-conformities
Potential non-conformities include:
• operational control procedures are not related tosignificant environmental aspects,
• operational control procedures are not prepared orimplemented to avoid the possibility of contravening thepolicy, objective and targets,
• no mechanism is in place to identify the significantenvironmental aspects of goods and services and weakoperational control procedures are applied to suppliersand contractors,
• operating criteria are not stipulated or implemented in thefollowing areas,
• the identification and, where necessary, protection of drains,
• functions to minimise the potential for adverse environmental aspects.
• nuisance and visual effect of external grounds includingremoval of litter, wind blown dust, noise and odour arenot considered,
• operational control does not take into account the bestuse of raw materials, energy (and other utilities) and thecontrol of wastes and discharges,
• inadequate operational control in the handling, storage anddistribution of materials and finished products to minimisethe risk of damage and waste.
Self-assessment questions
• Have you identified those operations and activitiesassociated with significant environmental aspects?
• Have you established operational controls, includingoperating criteria?
• Do these controls cover the significant aspects of goodsand services?
• Have these been communicated to relevant employeesand are they aware of these controls?
• Have these controls been communicated to suppliers andcontractors?
4.4.7 Emergency preparedness and response
Introduction
No matter how well you design your EMS or how manycontrols are implemented, the potential for uncontrolled events
still remains. These could include accidents, spills, emergencysituations and natural disasters. In order to prepare for suchoccurrences, you should implement detailed procedures toidentify, plan, test and respond to them. This could minimise theassociated environmental impacts and reduce any otherpotential impacts on employee health and loss of production.
ISO 14001 requirements
The organisation shall establish, implement and maintaina procedure(s) to identify the potential emergencysituations and potential accidents that can have animpact (s) on the environment and how it will respondto them.
The organisation shall respond to actual emergencysituations and accidents and prevent or mitigateassociated adverse environmental impacts.
The organisation shall periodically review, and wherenecessary, revise its emergency preparedness andresponse procedures, in particular, after the occurrenceof accidents and emergency situations.
The organisation shall also periodically test suchprocedures where practicable.
Interpretation
An effective emergency preparedness and responseprogramme should provide immediate guidance on how to minimise the environmental impacts associated with suchuncontrolled events. Some of the key requirements of aprocedure for ISO 14001 should include:
• methods to assess the potential for accidents and emergencies,
• preventing incidents and their associated environmentalimpacts,
• immediate plans for responding to incidents,
• plans to mitigate impacts associated with these incidents,
• mechanisms to review and revise procedures after theoccurrence of an incident,
• periodic testing of emergency plans/procedures wherepracticable.
Consistent with your organisation’s focus on continualimprovement, you should review emergency responseperformance after an incident or accident has occurred. This review can help determine if more training is needed orif emergency plans or procedures need to be revised.
Hints for implementation
This area of your EMS may have direct links withrequirements under health and safety legislation and inparticular the Control of Major Accident Hazard Regulations 1999 if this legislation is applicable to yourorganisation. It is important that you closely examine existingcontrols. If your company has such an emergency responseplan, you should consider integrating environmental controlsas long as they do not compromise any other legal duties.
One of the first steps in preparing such a plan is to define anemergency response team. This team should be made up ofindividuals who have sound understanding of the site process,local conditions and settings and the requirements ofrelevant environmental and health and safety legislation andhave received the necessary training or are deemedcompetent in this area through their work experience,knowledge and skills.
Using the principles of risk assessment the team shouldidentify the potential for accidents and emergency situationsof all processes and activities. In addition to normaloperations, the team should also consider abnormaloperating conditions (such as start-up and shutdown).
Once this assessment is complete, the team should ask itselfwho will need access to the appropriate controls or plans. Asa rule of thumb, copies should be given to each of the keymanagers and everybody should have access to it. Othercopies can be placed at your reception desk and in each ofthe main buildings on site. Also, consider contractors orvisitors when distributing the plan or procedure.
Also communicate with local emergency services andregulators (Such as HSE, fire authority and the EnvironmentAgency) when developing the plan or procedures. Theymaybe able to advise on its structure and content and wish tokeep a copy of the plan or your procedures for their purposes.
Time is of the essence in emergencies and accidents, so,clearly outline key roles and responsibilities and reportingprocedures.
Conduct regular drills to train staff and get feedback on theeffectiveness of your plans or procedures. Ensure that youregularly review your procedures, in particular after an actualsituation has arisen. If necessary make any changes and re-issue the document to all concerned.
Checklist for emergency preparedness and response plan
Does your plan describe the following:
• key organisational responsibilities,
• potential emergency situations (such as accidents, spills,fires, explosions and natural disasters),
• emergency response procedures i.e. the actions to betaken in the event of a spill, release or other emergency,including emergency communication procedures,
• actions to be taken to minimise environmental damage,
• arrangements with local emergency services and regulators,
• the location of on-site hazards including hazardous rawmaterials, storage tanks, compressed air and wastes
• the potential for an emergency situation or accident at a nearby facility if relevant e.g. plant, major road, railwayline, etc.,
• the locations and types of emergency response equipment,
• maintenance of emergency response equipment,
• training or testing of personnel, including the on-siteemergency response team,
• testing of alarm/public address systems,
• evacuation routes and exits (map) and assembly points,
• possible assistance from neighbouring organisations,
• process of post-accident evaluation and theimplementation of necessary corrective and preventiveaction,
• periodic testing of emergency response plan/procedure?
This list is not exhaustive. Organisations will have differentconsiderations depending on the nature of their activities,products and services and their location.
Common non-conformities
Common non-conformities identified by certification bodiesinclude:
• all potential accidents or emergency situations not identified,
• failure to identify the potential environmental impactsarising from accidents and emergencies,
• emergency response plans not developed,
• emergency plans not reviewed after events and norecords to show this has occurred,
• training programmes not extended to include emergencypreparedness,
• failure to respond to actual emergency situations andprevent or mitigate the adverse impacts of such an event,
• contractors not informed of procedures,
• no periodic testing of procedures.
Self-assessment questions
• Have you established procedures to identify potentialemergencies and the potential for accidents?
• Do these procedures cover criteria for responding to andfor preventing and mitigating the environmental impacts ofaccidents and emergencies?
• Have you developed procedures to periodically reviewand revise these procedures particularly after theoccurrence of accidents and emergencies?
• Do you periodically test these procedures wherepracticable?
• Has staff been adequately trained in this area?
4.5 Checking
4.5.1 Monitoring and measurement
Introduction
Monitoring has long been recognised as a cornerstone ofeffective business management. It is important to track keyelements of your EMS which demonstrate how effective it isin delivering environmental improvements and legislative
compliance. Monitoring includes collecting information suchas measurements or observations over time. Thesemeasurements can be either quantitative or qualitative.
To prevent unforeseen occurrences you should ensure thatall operations and activities that have significant impact uponthe environment are measured regularly. This should alsoextend to monitoring of relevant instructions and theprogress towards meeting objectives and targets.
ISO 14001 requirements
The organisation shall establish, implement and maintaina procedure(s) to monitor and measure, on a regularbasis, key characteristics of its operations that can have asignificant environmental impact. The procedure(s) shallinclude the documenting of information to monitorperformance, applicable operational controls andconformity with the organisation’s environmentalobjectives and targets.
The organisation shall ensure that calibrated or verifiedmonitoring and measurement equipment is used andmaintained and shall retain associated records.
Interpretation
This is fundamental to your EMS in terms of tracking yourperformance on meeting your policy commitments. To meetthe requirements of ISO 14001, your organisation shoulddevelop procedures to:
• monitor key characteristics of operations and activities thatcan have significant environmental impacts,
• track performance (including how well you meet yourobjectives and targets),
• calibrate and maintain monitoring equipment.
You should plan what is to be measured, when and wherethis should take place and how you are going to do it.
Hints for Implementation
Monitoring and measurement may at first seem like a timeconsuming process, but you should make it relevant to yourneeds. Start with a relatively simple monitoring andmeasurement system and build upon it as your system grows.Look to the factors of your significant aspects that will give youthe most valuable information on how that aspect is controlled.Try to resist monitoring something just because you can. Focusyour resources on the most important measurements to yourbusiness and use staff that are competent.
Monitoring may include permit, licence or consent limits, inparticular ensure you are doing this at the required frequency.When monitoring a particular indicator, try to relate it to afactor or process over which you have control, for example,production or the volume of materials or other resourcesused etc.
You can use environmental performance indicators or EPIsto monitor performance. Examples are:
• concentration of particulates from stack emissions pertonne of coal consumed,
• concentration of heavy metals in effluent discharges pertonne of product produced,
• volume of waste produced per tonne of productproduced,
• volume of waste recycled or re-used,
• consumption of petrol per mile travelled,
• percentage of waste recycled or reused or both,
• consumption of energy, water or other utilities.
Management Performance Indicators or MPIs help establishorganisational intent. Some MPIs are:
• percentage of employees trained on environmental matters,
• number of environmental suggestions submitted,
• time taken to resolve non-conformities,
• time taken to deal with complaints,
Sufficient data will need to be collected and reviewed on aregular basis so that you can track your performance againstyour targets. If necessary, targets may need to be revised inthe light of data that is collated and reviewed. You may alsoneed to make corrections or improvements as a result of thisreview and more importantly, you should identify andcommunicate any successes that are identified.
To ensure that the information you are gathering is accurateyou should also establish procedures for equipmentcalibration or verification. Where necessary, the measurementstandards against which equipment is calibrated or verifiedshould be traceable to international or national measurementstandards. Again this requirement can be integrated withinexisting quality assurance controls.
Common non-conformities
Common non-conformities identified by certification bodiesinclude:
• significant impacts or key characteristics are not monitoredto track performance,
• objectives and targets are not tracked or sufficient data isnot held to demonstrate that this is taking place,
• procedures dealing with calibration of equipment are notestablished.
Self-assessment questions
• Have you established procedures to monitor and measurethe characteristics of operations and activities withsignificant environmental aspects?
• Do these procedures cover performance against ourobjectives and targets?
• Have you established procedures to maintain and calibratemonitoring equipment? Does this include the:
• calibration frequency,
• methodology for calibration,
• clear calibration status.
4.5.2 Evaluation of compliance
Introduction
This is a vitally important part of compliance with the ISO14001 standard. This was a new clause in ISO 14001:2004 butnot a new requirement. It was previously part of 4.5.1.Monitoring and Measurement, in ISO 14001:1996.
The evaluation of legal compliance is key to ensuring thatyour organisation meets it’s commitment to compliance withlegal requirements that you have made in your environmentalpolicy.
ISO 14001 requirements
4.5.2.1 Consistent with its commitment to compliance,the organisation shall establish, implement and maintaina procedure(s) for periodically evaluating compliancewith applicable legal requirements.
The organisation shall keep records of the results of theperiodic evaluations.
4.5.2.2 The organisation shall evaluate compliance withother requirements to which it subscribes. Theorganisation may wish to combine this evaluation withthe evaluation of legal compliance referred to in 4.5.2.1or to establish a separate procedure(s).
The organisation shall keep records of the results of theperiodic evaluations.
Interpretation
Your organisation will be required to undertake anevaluation of compliance against all applicable legal and otherrequirements. As in clause 4.3.1, this will take into accountcompliance against every piece of legislation and regulationsrelating to your environmental aspects and the otherrequirements applicable such as codes of practice.Remember, that this may include legislation that is not strictlyregarded as environmental, such as health and safetylegislation. This is an essential part of your EMS and you willneed to check compliance in practice, review this and take adecision on how you will carry this out and how often.
This evaluation will need to be against all these requirementsand the method and frequency will depend on variousfactors that are described in detail below. However youdecide to carry this periodic evaluation out for yourorganisation, you need to document this in a procedure andkeep records of the process to show that it is effective. Youcan have separate procedures for legal requirements andother requirements or have just one to cover both areas.
Hints for implementation
Compliance evaluation can cover either just one area ofcompliance or could be a process that covers multiplerequirements. It may be easier for your organisation just tohave one procedure and process to cover both theevaluation of compliance with applicable legal requirementsand other requirements rather than having separate
procedures and checks.
A variety of different methods and frequencies can beadopted by your organisation, this depends on which suitsthe needs and resources that are available and the size, typeand complexity of your activities, products and services.
Some suggestions of methods are:
• document and record reviews,
• site inspections,
• process inspections,
• legal compliance audits,
• interviews with key personnel,
• project reviews,
• routine sample analysis,
• test results,
• direct observations.
The frequency of your compliance evaluation will depend onthe nature of the requirements that apply to yourenvironmental aspects and your organisation. It will also bedetermined by other factors, such as past complianceperformance or perhaps specific legal requirements orconditions in permits or consents that require checking ofcompliance at certain intervals.
You may wish to integrate your periodic evaluation withother assessment activities such as health and safetyassessments or inspections, other management system auditsand quality assurance checks if this suits your organisation.
Common non-conformities
Common non-conformities identified by certification bodiesinclude:
• no documented procedures are in place for periodicallyevaluating compliance with legal and other requirementswhich relate to the organisation,
• all applicable legal requirements that relate to theenvironmental aspects are not considered such as relevanthealth and safety legislation,
• compliance is checked but no records exist of these checksbeing made.
Self-assessment questions
• Have you clearly established a procedure or procedureswhich cover the periodic evaluation of compliance withboth legal and other requirements?
• Are these checks being carried out in accordance with theprocedure or procedures?
• Can you demonstrate that the methods and frequency ofyour periodic evaluations are suitable for an organisation ofyour size, type and complexity?
• Are records being kept of your periodic evaluations?
4.5.3 Nonconformity, corrective andpreventive action
Introduction
Despite best intentions, you will never be able to create theperfect environmental management system. You will find thatproblems occur for a whole range of reasons, especially inthe earlier stages of development and implementation. Thesecould include:
• accidental spills,
• legislative breaches,
• complaints from neighbours,
• poor communications,
• lack of training,
• lack of understanding (of requirements),
• lack of implementation,
• faulty or missing procedures (lack of effectiveness),
• equipment malfunction (or lack of maintenance),
• failure to enforce rules.
ISO 14001 requirements
The organisation shall establish, implement and maintaina procedure(s) for dealing with actual and potentialnon-conformity(ies) and for taking corrective andpreventive action. The procedure(s) shall definerequirements for:
a) identifying and correcting non-conformity(ies) andtaking action(s) to mitigate their environmental impacts,
b) investigating non-conformity(ies), determining theircause(s) and taking actions in order to avoid theirrecurrence,
c) evaluating the need for action(s) to prevent non-conformity(ies) and implementing appropriate actionsdesigned to avoid their occurrence,
d) recording the results of corrective action(s) andpreventive action(s) taken,
e) reviewing the effectiveness of corrective action(s)and preventive action(s) taken.
Actions taken shall be appropriate to the magnitude ofthe problems and the environmental impactsencountered.
The organisation shall ensure that any necessary changesare made to environmental management systemdocumentation.
Interpretation
Whatever the cause of the actual or potential non-conformity (non-fulfilment of a requirement) you will needto establish a procedure so that the problem is investigatedand the root causes identified.
The non-conformity may relate to a requirement stated inrelation to the EMS such as failure to establish anenvironmental policy or in terms of environmentalperformance such as targets on waste recycling are not being met.
You should then identify, document and assign correctiveactions and ensure they are implemented through trackingand evaluation.
This process can be summarised in seven key steps:
• identify the problem (non-conformity),
• investigate and identify the root cause,
• devise a solution (in conjunction with relevant staff),
• implement a solution (corrective and preventive action),
• document a solution,
• communicate the solution,
• evaluate effectiveness and implementation of the solution.
Wherever possible, you should attempt, to focus onpreventive actions, rather than displacing or correcting theoriginal problem. For example, if drums of hazardous chemicals were placed incorrectly outside a bunded area, you wouldprobably correct this by moving them to the correct area, but,you should also think about what caused the problem in thefirst place and what will prevent it happening again. Giving stafftraining on storage of hazardous materials. On the whole,prevention is always better (and cheaper) than a cure (fixing theproblem after it has occurred).
Whatever actions you take they should be appropriate tothe magnitude of the problems and commensurate with theenvironmental impact encountered.
Hints for implementation
Again this is one section of ISO 14001, which has clear links toISO 9001. If you have a quality management system youshould already have a corrective/preventive action process.You could use this as a framework for environmental non-conformities, or if possible totally integrate the two systems.
At first, your EMS audit team will raise most of the non-conformities. However, in the long run, it is worthwhileencouraging all staff to play an active role in reporting non-conformities or observations. This is particularly importantfor near-miss incidents, which often go unreported.Understanding such events will allow you to put in placecontrol measures so that the problem is avoided. Preventionis always better than a cure.
Potential problems can be identified through a number ofmethods such as analysis of data including trend analysis orhazard operability studies. The internal audit process willperiodically identify non-conformities but identification ofnon-conformities can also be part of routine responsibilities,
such as daily checks by the supervisor that is closest to thework. They can make a record of the potential or actualproblems that may arise on a frequent basis.
It is also critical to ensure that problems identified by yourorganisation are addressed in a timely manner, again this willdepend upon the nature of the actual or potential non-conformity and the environmental impact.
Common non-conformities
Common non-conformities brought up in certification auditsinclude:
• procedures and responsibilities are inadequately defined toensure that non-conformities, corrective and preventiveactions are taken,
• procedures only deal with actual non-conformities notpotential non-conformities as well,
• no records of investigation of the cause of the non-conformities only of the action taken,
• failure to take appropriate corrective action,
• preventive action is not demonstrated to ensure that thesame problem does not arise again.
Self-assessment questions
• Have you developed and implemented procedures forinvestigating, correcting, and preventing system actual andpotential non-conformities?
• Have you defined the requirements for identifying andcorrecting non-conformities and taking action to mitigatetheir environmental impacts; investigate non-conformities,determine their cause and take action to prevent or avoidrecurrence?
• Have you recorded the results of corrective andpreventive actions?
• Have responsibilities been assigned for and trackingcompletion of corrective actions?
• Have you established a process to revise procedures or otherEMS documents based on corrective or preventive actionsor both?
• Are actions taken appropriate to the magnitude of theproblem and environmental impact encountered?
4.5.4 Control of records
Introduction
Records can be viewed as the lowest tier of documents inyour EMS (see diagram section 4.4.4), but will probablyrepresent the highest in terms of volume. The importance ofrecords is fairly simple; you must be able to produce evidencethat your EMS is operating as specified in your procedures.
Not only will they demonstrate the implementation of yourprocedures but they will also determine the extent to whichyour objectives and targets have been met, in line with yourenvironmental policy.
ISO 14001 requirements
The organisation shall establish and maintain records asnecessary to demonstrate conformity to the requirementsof its environmental management system and of theInternational Standard, and the results achieved.
The organisation shall establish, implement and maintain aprocedure(s) for the identification, storage, protection,retrieval, retention and disposal of records.
Records shall be and remain legible, identifiable andtraceable.
Interpretation
Records will need to be kept for many different elements ofyour EMS. For instance, ISO 14001 specifically requires thatorganisations have procedures for competence, training andawareness records and the results of audits and managementreviews. In addition your records system should also include:
• the results of compliance evaluation against legal and otherrequirements,
• details of non-conformities and corrective and preventiveactions,
• results of internal audits and management reviews,
• information on any environmental attributes of productssuch as their chemical composition,
• evidence of performance against the objectives andtargets,
• legal permits and authorisations, etc.,
• training, awareness and competency records,
• results of calibration and other such inspections,
• results of operational controls such as maintenance,
• incident reports from accidents on site,
• monitoring results and sampling data,
• internal communications, e.g. memos, leaflets andhandouts,
• external communications with customers, suppliers,contractors and other interested parties,
In the same way that procedures are controlled earlier in thestandard, you must establish an effective storage and
retrieval system to protect against damage or loss of records.This will include identification, collection, indexing, filing,storage, maintenance and retrieval. You should also stipulatein your procedures retention times of particular records. Thisshould take into account any legal requirements and anyother company policies on document retention.
Hints for implementation
Essentially, record management is very simple. Try not toover complicate it with complex procedures. Decide whatrecords you will keep, how you will keep them and for howlong. You should also consider how to dispose of recordsonce you no longer need them. If your organisation has ISO9001, you should already have a system for managing qualityrecords. You may wish to consider integrating therequirements of both standards into one systems.
If the records are kept on a computer system, then adequatesoftware systems back up will need to be in place.
Common non-conformities
Some of the most common non-conformities linked torecords include:
• records in key areas that are used to support the EMS anddemonstrate compliance with the EMS are not identifiable,
• procedures and responsibilities are inadequately defined toensure that suitable records are made and retained tosupport the system,
• poor identification, traceability and retrievability of records,
• records retained are not legible and/or traceable.
Self-assessment questions
• Have you established a procedure for managingenvironmental records?
• Does this procedure cover the identification, storage,protection, maintenance and disposition of all appropriaterecords?
• Have you determined retention times for records?
• Do you have an effective storage and retrieval system toprotect against damage or loss of records?
4.5.5 Internal audit
Introduction
EMS audits play a fundamental role in establishing whetheryour system is operating according to the commitments ofyour policy and in accordance with specified requirements ofprocedures and instructions. In other words, has the theorybeen put into practice?
While they can be time-consuming, audits are critical to EMSeffectiveness. Systematic identification and reporting of EMSdeficiencies will allow you to continually improve the system,and ensure its cost-effectiveness.
ISO 14001 requirements
The organisation shall ensure that internal audits of theenvironmental management system are conducted atplanned intervals to:
a) determine whether the environmental managementsystem:
1) conforms to planned arrangements forenvironmental management including therequirements of the International Standard,
2) has been properly implemented and is maintained,
b) provide information on the results of audits tomanagement.
Audit programme(s) shall be planned, established,implemented and maintained by the organisation, takinginto consideration the environmental importance of theoperation(s) concerned and the results of previousaudits.
Audit procedure(s) shall be established, implementedand maintained that address:
- the responsibilities and requirements for planning andconducting audits, reporting results and retainingassociated records,
- the determination of audit criteria, scope, frequencyand methods.
Selection of auditors and conduct of audits shall ensureobjectivity and the impartiality of the audit process.
Interpretation
For your EMS audits to be effective you should plan andprepare an audit programme which shows the plannedintervals at which they will be conducted. This should givedetails on how to carry it out:
• scope the audit (i.e. what activities and elements of thesystem to cover) and audit criteria (the policies,procedures or requirements against which the audit is tobe conducted),
• establish an appropriate audit frequency,
• select appropriate auditors,
• report the results,
• maintain audit records.
It should also indicate appropriate authorities andresponsibilities for conducting audits and for reporting on theresults of audits to the management team.
Audit frequency
In determining the frequency of your EMS audits, some thingsto consider are:
• the nature of your operations,
• the significant environmental aspects/impacts (which youidentified earlier),
• the results of your monitoring programme,
• the results of previous audits.
As a general guide, all parts of the EMS should be audited at least once annually. You can audit the entire EMS at onetime or break it down into discrete elements for morefrequent audits.
Selecting an audit team
You will need to select a team of EMS auditors according totheir experience and training. EMS auditors should be trainedin auditing techniques and management system concepts.Familiarity with environmental regulations and aspects is alsoimportant.
If your company is registered under ISO 9000, consider usingyour internal QMS auditors as EMS procedural auditors.Although some additional training will be needed, many ofthe required skills are the same for both types of audits. Thisadditional training should include understanding of complexaspects, impacts and legislative requirements.
Hints for implementation
Your EMS audits should focus on objective evidence ofconformance. During the actual audit, try to resist evaluatingwhy a procedure was not followed. This step will come laterin the corrective and preventive actions. Auditors should beobjective and impartial and, if appropriate, be aided by atechnical expert. Their competence should allow yourorganisation to have confidence in the reliability of the resultsof the audit.
During the audit, discuss identified deficiencies with thepeople who work in the area. This will help the auditorsverify that their understanding is correct. It can also serve asrefresher training (on EMS requirements) for employees.
Before you start an audit, be sure to communicate the auditscope, schedule, and other pertinent information with thepeople in the affected area(s). This will help avoid confusionand will help the audit process.
ISO 19011:2002 Guidance on quality and environmentalmanagement system auditing provides further information in this area.
Common non-conformities
Potential non-conformities include:
• auditors are not sufficiently independent of the activityaudited and cannot demonstrate objectivity andimpartiality,
• responsibilities for performing audits are not clearly defined,
• audit programme is not sufficiently comprehensive tocover all areas of the EMS or activities from whichenvironmental impacts can arise,
• audit frequency is not based upon the environmentalimpact of activity,
• audit format or activity is not consistent with previous audits,
• audit reports are not completed within the original scopeof the audit,
• audit reports are not retained.
Self-assessment questions
• Have you established an audit procedure and programme?
• Do you undertake periodic EMS audits?
• Do your audits cover all activities and shifts?
• Does your audit programme determine audit frequency?
• Is the audit frequency related to the environmental impactof your activities, products and services?
• Have you selected and trained an objective and impartialEMS auditing team?
• Have you established a process to keep records of auditreports?
4.6 Management review
Introduction
In the same way that your car requires regular MoT checks,your EMS will also need to be reviewed to ensure that it isstill living up to the original commitments you set in theenvironmental policy. Management reviews play afundamental rôle in ensuring continual environmentalimprovement. They also ensure that the EMS is still effectivein meeting your business needs and is kept within budget.
ISO 14001 requirements
Top management shall review the organisation’s
environmental management system, at planned intervals,to ensure its continuing suitability, adequacy andeffectiveness. Reviews shall include assessingopportunities for improvement and the need forchanges to the environmental management system,including the environmental policy and environmentalobjectives and targets. Records of the managementreviews shall be retained.
Input to management reviews shall include:
a) results of internal audits and evaluations ofcompliance with legal requirements and otherrequirements to which the organisation subscribes,
b) communication(s) from external interested parties,including complaints,
c) the environmental performance of the organisation,
d) the extent to which objectives have been met,
e) status of corrective and preventive actions,
f) follow-up actions from previous management reviews,
g) changing circumstances, including developments inlegal and other requirements related environmentalaspects,
h) recommendations for improvement.
The outputs from management reviews shall include anydecisions and action related to possible changes toenvironment policy, objectives, targets and other elementsof the environmental management system, consistent withthe commitment to continual improvement.
Interpretation
With all the information you have now collected, from
audits and monitoring exercises, you will be able to reviewthe effectiveness of your EMS, especially in delivering thecommitments of your environmental policy. As the topmanagement team defined this policy, they are ideally placedto review the effectiveness of the EMS.
In the light of the information presented, the managementteam should address the possible need for changes to thepolicy, objectives and targets and EMS. The results of themanagement review meeting should be documented inminutes.
Hints for implementation
The term “management review” often gives people theimpression of a very senior and formalised boardroom orcommittee meeting. However, it need not be any of thesethings; it is simply a mechanism to ensure that the EMS iskept in good working order.
There are generally two types of people who should beinvolved in the management review process. Those whohave the right information about the EMS (for example theenvironmental management representative) and those whocan make decisions (such as the managing director).
When deciding the frequency of management reviews,consider what currently works for your company. Theyshould take place at ‘planned intervals’; the interval should be determined by your organisation. For ISO 9000 purposes,management reviews are typically held once or twice peryear. You may wish to integrate the two meetings if yourorganisation has a quality management system or keep them separate.
No matter what approach you take, make sure thatsomeone takes notes on what issues were discussed, whatdecisions were arrived at, and what actions were allocatedwith time-scales. Management reviews should bedocumented and the records stored as defined by the EMS.
The management review should assess how changingcircumstances might influence the suitability, effectiveness oradequacy of your EMS. Changing circumstances may beinternal to your organisation (e.g. new materials or changes in products or services) or may be external factors (such asnew regulations or new customers) or both.
Once you have documented the action items arising fromyour management review, be sure that someone follows-up.Progress on these items should be tracked.
Potential Management Review Discussions Items
• The suitability, adequacy and effectiveness of theenvironmental policy.
• A review of the significant environmental aspects andmodifications since the last review.
• Environmental performance of your organisation.
• A review of the relevant legislation and complianceevaluation and modifications since the last review.
• Extent to which objectives and targets are met.
• The results of monitoring and measurements fromsignificant environmental aspects.
• The overall suitability, adequacy and effectiveness of theEMS.
• The status (and number) of non-conformity reports andcorrective and preventive actions.
• The results of any EMS audits conducted since the lastreview meeting, with details of non-conformities raised.
• The suitability, adequacy and effectiveness of trainingefforts.
• A review of major communications and the adequacy ofresponses to such internal and external communications.
• Views of interested parties.
• Changes in your activities, products and services.
• Advances in technologies that are applicable to yourorganisation.
• Any emergency situations that may have arisen and thelessons learned from the actions taken in thesecircumstances.
• The results of any action items from the previous reviewmeeting.
• The adequacy and effectiveness of the system overall.
The management review should lead to certain outputs andwill include any decisions that you have taken and actionsgiven during the process. These could be related to thesystems continuing suitability, whether it is functioningeffectively and you believe it is adequate to meet the aims,intentions and commitments that you have made in yourpolicy. It may also include any changes that have taken placeto the resources available for maintaining your EMS such ashuman and financial resources. You may have also placedactions on employees relating to changes to your policy,objectives, targets or perhaps other areas of themanagement system such as your emergency preparednessprocedures.
You will need to keep records of the management review.These usually take the form of agenda, minutes, lists ofattendees, memos recording actions and decisions made orany other documentation that provides evidence of thereview and the decision and actions taken.
Common non-conformities
Potential non-conformities include:
• the frequency of management reviews is not clearlystipulated by the organisation,
• the agenda of the management review does not include anexamination of the effectiveness of the EMS in deliveringthe environmental policy, objectives, targets and otherelements of the EMS,
• information gathered to review the EMS is insufficient,
• failure to document and follow up actions and decisionsagreed action at the management review,
• records of the management review are insufficient, e.g.minutes are not detailed.
Self-assessment questions
• Does your management team at regular intervals reviewthe adequacy of your EMS?
• Do your procedures cover requirements for ensuringadequate information is provided?
• Are the results and actions of such reviews documented inminutes?
Registration of environmentalmanagement systems
Benefits of registration
The benefits of having your environmental managementsystem independently assessed and registered are two-fold.The internal benefits are that your management disciplinesand procedures are independently and periodically checkedand verified as being effective, whilst externally therecognition of ISO 14001, EMAS or Acorn/BS 8555 canenhance the image and credibility of your company tocustomers, investors, shareholders and regulators, to namebut a few.
NQA's philosophy is to develop a practical and professionalrelationship with its clients that adds value. Our aim is towork in partnership with you at all stages of the registrationprocess and ensure that you maximise the benefits ofoperating an environmental management system andultimately to obtain and maintain registration. At NQA, webelieve that certification and inspection bodies have a keyrole to play in ensuring that registered environmentalmanagement systems deliver meaningful results.
We built our reputation on providing a value-for-money, non-bureaucratic service to all sectors of business. We aim toprovide an assessment service which probes the underlyingbasis of why you do what you do. This process-basedassessment of the system should provide examples of continualimprovement upon which your organisation can build.
The focus of environmental audits or inspections shouldensure that achievement criteria have been met. However,our audit and inspection programmes also focus on ensuringthat the resources committed to achieving the standard isbeing expended in an effective manner that truly benefits theemployees, the environment, the organisation and the localcommunity in which your organisation operates. This isaccomplished through close examination of the factors that
give rise to continual environmental performanceimprovement to help your organisation meet regulatoryrequirements and deliver meaningful reductions therebyimproving its environmental performance as a whole.
The enquiry stage
During this stage your organisation may make enquires ofseveral certification bodies. The first question must be:
“Are you accredited for my scope of activity?”
It is vitally important to the credibility of your registrationthat the body you choose is competent in your industry andis able to award an accredited certificate.
NQA has full UKAS accreditation for the 39 EAC codes forISO 14001 (EMS) under ISO/IEC Guide 66 GeneralRequirements for bodies operating assessment/registration ofenvironmental management systems.
Secondary questions will relate to time-scales, availability oftechnical advice and, of course, cost.
Some certification bodies, like NQA will visit the client, ifrequested, to discuss the scope of registration, the size andcomplexity of the organisation and to answer any questionsthe client may have.
Application
When you have chosen a certification body to carry out theregistration a formal application is made. On receipt of theapplication an initial visit by an assessor, with your appropriateindustry expertise will be arranged.
Assessment to ISO 14001
The ISO 14001 assessment is made up of two formal audits,an initial assessment followed by a main assessment later, toevaluate the implementation of the system in practice.
Each assessment has a standard format:
• an opening meeting, at which the lead assessor introducesany colleagues, confirms the scope of registration and theassessment programme,
• the assessment, when the assessor(s) tour the premisesinterviewing employees, examining documentary evidenceand/or witnessing tasks being performed. It is at this stagethat any deviation from written procedures or ISO 14001requirements will be noted by the assessor. These non-conformities will be discussed with you;
• a closing meeting where the assessor will present a reporton the assessment and will summarise any agreed non-conformities.
Initial assessment
• Your NQA assessor will contact you to arrange a visit toperform an initial assessment of your environmentalmanagement system. This visit will be used to gain anunderstanding of your EMS as it relates to yourenvironmental aspects and impacts, policy and objectives.It will also review your organisations preparedness for themain assessment, agree the details and derive a plan forthe main assessment.
In particular, NQA assessors will focus on the following at this stage:
• ensuring the documented management system meets therequirements of the individual clauses of the standard andaccurately reflects and describes the operation of theorganisation’s products, activities and services as it relatesto the EMS,
• that the documented EMS includes a logical and consistentprocess for the analysis of your environmental aspects andimpacts and which of these are considered significant,
• ensuring a system for the identification of applicable legaland other requirements, and how compliance is to bedemonstrated is in place,
• that the appropriate environmental licences are in place,
• the means by which continual improvement is to berealised.
Main assessment
On successful completion of any actions arising from theinitial assessment, the main assessment will be arranged.
At the main assessment, the NQA assessor will be looking,amongst other elements, for the following:
• that non-conformities raised at the initial assessment havebeen addressed and closed,
• to confirm that the EMS complies with all therequirements of the standard and that there are noinconsistencies,
• to determine whether the system is designed to achieveand is achieving performance improvement, regulatorycompliance and that evaluation of compliance is takingplace,
• to determine that the organisation adheres to its ownpolicies, objectives and procedures,
• to ensure that the internal audits are effective in evaluatingthe system,
• all significant aspects and impacts are included in the EMS,
• that objectives and targets have been met and theappropriate performance data and measurement criteria isavailable,
On completion of the assessment, the assessor will inform you of his or her recommendation including any non-conformities and observations and the report will beforwarded to NQA for final review.
Depending on the nature of the non-conformity, the assessorwill recommend either registration or not. If the assessor hasfound a major non-conformity, that is the complete lack of orthe breakdown of a procedure that addresses a requirementof ISO 14001, he is unable to recommend registration andwill be required to make a further visit to ensure that thenon-conformity has been addressed.
Certificate issue
NQA will issue your Certificate of Registration followingconfirmation of an assessor’s positive recommendation forregistration. Achieving registration of your EMS demonstratesto customers, shareholders and the community at large thatyour organisation is committed to conduct activities incompliance with environmental legislation that you aim toprevent pollution and continually improve yourenvironmental performance.
Surveillance
Your registration will be maintained through a programme ofregular, periodic surveillance visits that will take place to aplanned surveillance schedule. Your first surveillance visit willtake place approximately six months after registration andthen, usually, on an annual basis.
Triennial review
Every three years a triennial review is undertaken to evaluatefully the continued compliance of the EMS. The purpose ofthis overview is to review the results of the surveillanceprogramme and to make a recommendation regarding re-issue of certification. This activity will be integrated with anormal surveillance visit and, hence, no additional costs willbe involved.
EMAS
EMAS calls for maintenance of an effective EMS via a systemwhich ensures that a policy is available, that objectives,targets and programmes are set to improve environmentalperformance and continuous improvement as a whole.
EMAS verification, validation and registration
This is the registration scheme, or the equivalent of certification,carried out by a third party independent verifier such asNQA. Initially, an effective and functional EMS that meets therequirements of ISO 14001 must be established and maintained.After this, the steps to verification and registration are:
• Preparation of an environmental statement - yourenvironmental statement must be written clearly, usinglanguage that the general public will understand.
• Verification - once your statement has been prepared, anindependent verifier must ensure that it gives an accuraterepresentation of your organisation and its activities and itfulfils the requirements of EMAS.
• Validation - once the independent verifier is satisfied thatyour statement and EMS meet the requirements, bearingin mind that changes may have been required; they willvalidate the environmental statement by authorising it witha signature and date.
• Application - once validated, your environmentalstatement and details of your site are forwarded to thecompetent body responsible for the regulation of EMAS inan EU member state. In the UK, this is the Institute ofEnvironmental Management and Assessment (IEMA).
• Registration - IEMA will then register acceptance of thevalidated statement and provides your organisation with aregistration number. Your organisation can then use theEMAS logo on the statement and corporate literature. (Asdescribed in Annex IV of the Regulation).
The EMAS Register contains the details of all organisationsthat have met the requirements of the EMAS Regulation andare currently registered. The register provides the address,contact phone and fax numbers where copies of theenvironmental statement can be obtained, date firstregistered, and a code for the activities undertaken by theorganisation, and the scope of registration.
NQA is accredited by UKAS as a verifier for EMAS.
BS 8555/Acorn Scheme
BS 8555 provides guidance for organisations who are seekingto implement a formal environmental management system.The standard focuses on environmental performance controland is broken down into six manageable phases. Thesephases can be tackled incrementally at a pace that suits your organisation. Completing all the phases could lead yourorganisation to being in a position to be assessed against ISO 14001 or EMAS.
You can become registered to any phase within the AcornScheme up to and including phase 5. Beyond phase 5organisations should seek EMAS or ISO 14001 registration.
Inspection
To become registered to the Acorn Scheme, NQA willinspect your organisation’s environmental managementsystem to ensure it meets all the appropriate stage profileachievement criteria specified at each stage in each phase ofBS 8555.
In order to facilitate the achievements at phases 2 and above, allprevious phases must be inspected and will have to have beencompleted. Therefore, by default these achievement criteria atthe lower phases will be incorporated in the inspection.
In addition, BS 8555 incorporates environmental performanceindicators and further evidence is required to satisfy theseelements of BS 8555 over and above the links with ISO 14001.
The inspection will identify on an Acorn inspection reportwhere one or more of the achievement criteria of the stageprofiles have not been met. In these circumstances this willbe categorised as a non-compliance and your organisation isgiven up to 3 months to meet the criteria. Dependent uponthe nature of the non-conformity, your organisation mayeither provide a corrective action plan to NQA to be closedout remotely or an assessor may need to close the non-conformity at a supplementary ‘special visit’. If the correctiveaction can not be completed and closed out within 3 monthsof the initial inspection then a full re-inspection of your EMS willneed to take place.
Observations may also be made by your assessor regardingyour organisations environmental performance and theenvironmental performance indicators and yourperformance relating to these issues.
Certificate Issue
When the report and the corrective action have beendeemed adequate, your Certificate of Registration to theAcorn Scheme will be issued by NQA. This certificate willonly be valid for ONE CALENDAR YEAR. A new certificatewill be issued every year following a re-inspection.
An Acorn/BS 8555 certificate CAN NOT be issued if yourorganisation is not in compliance with environmental lawsand regulations.
Re-inspection/up-grade
Re-inspection will take place on a twelve-monthly basis tomaintain the registration. The re-inspection will ensure thatyour organisation continues to meet the achievement criteriaat the appropriate phase(s) of BS 8555 or you haveprogressed to another phase.
IEMA will maintain a register of organisations that haveundergone inspection against BS 8555 and achievedregistration to the Acorn Scheme.
Your route to environmental management systemswith NQA
Companies registered with NQA for their environmentalmanagement systems have seen significant reductions inenvironmental impacts, costs, energy use and, in many cases,have become ‘preferred suppliers’, giving them an edge overtheir competitors. Through EMS assessment with NQA,commercial gain as well as environmental benefits can beachieved.
If you would like NQA to provide your organisationwith a quotation for ISO 14001, EMAS or Acornregistration then please contact NQA on 08000 52 2424 or e-mail us at [email protected], visit the website at www.nqa.com
Reference List
Environmental Management Systems – Self Help Workbook(Issue 2 June 2001) NQA Training and Development
BS EN 19011:2002 – Guidelines for quality and/orenvironmental management systems auditing
BS EN 14001:2004 – Environmental management systems –Requirements with guidance for use
BS EN 14004:2004 – Environmental management systems –General guidelines on principles, systems and supporttechniques
Other sources of information
British Standards Institute (BSI)
Copies of standards can be ordered from BSI at:
389 Chiswick High Road, London W4 4ALTel: 020 8996 9000 www.bsi-global.com
Business Links
Business Links are a network of government-supportedorganisations, which aim to support and advise new andexisting businesses in their local areas. This advice can includeenvironmental and health and safety management. You canfind out details about your local business links office by calling(0845) 600 9 006 or go to www.businesslink.gov.uk
Envirowise
Envirowise aims to provide on-going environmental guidanceand support to UK businesses. They produce a wide varietyof publications which can be ordered free by telephoning(0800) 585794 or e-mail [email protected] or viathe Website at www.environwise.gov.uk
Envirowise also provide a free telephone support service.This helpline service can often answer your environmentaland energy questions immediately. The helpline can also helpby giving up to two hours of advice on any question, or byguiding your company to other organisations that can help,for example Business Links or the Environment Agency.
Smaller companies (employing fewer than 250 staff) can alsobenefit from the discretionary free 'counselling' servicearranged through the helpline. An environmental/energyprofessional will visit your site and give confidential advice,free of charge, on priorities for waste minimisation, cleanertechnology or, perhaps, help you with a specificenvironmental or energy problem.
The Environment Agency
As well as enforcing statutory legislation in England andWales, the Environment Agency also aims to encourageimproved environmental performance by providing guidanceand assistance on legislation, water pollution and wasteminimisation. Coupled with this, the Environment Agencyproduces a range of free leaflets and videos, which could beused as part of your environmental training andcommunication programme.
In addition, the EA website includes access to NetRegs. Thisis a Web-based tool for organisations to find out more aboutthe environmental legislation that is applicable to them.
Environment Agency General Enquiry Line 0845 9333 111Environment Agency Emergency Hotline 0800 80 70 60 www.environment-agency.gov.uk
The Scottish Environmental Protection Agency
The equivalent body to The Environment Agency in Scotlandwww.sepa.org.uk
The Environment and Heritage Service
The EHS are the equivalent body to the EnvironmentAgency and SEPA in Northern Ireland. www.ehsi.gov.uk
The Environmental Protection Agency
This body protects and improves the natural environment inThe Republic of Ireland, carrying out a similar function to theEnvironment Agency.www.epa.ie
The Institute of Environmental Management& Assessment
The Institute of Environmental Management & Assessment(IEMA) was formed in September 1999, following the mergerof the Institute of Environmental Management, theEnvironmental Auditor's Registration Association, andInstitute of Environmental Assessment. The Institute is nowthe leading UK membership organisation dedicated to thepromotion of sustainable development and to theprofessional development of individuals involved inenvironmental management and assessment, whether theybe in business, government, consultancy or the regulators.
IEMA is also the UK competent body for EMAS. EMAS is theEuropean Eco-Management and Audit Scheme, a voluntaryinitiative to encourage businesses to improve theirenvironmental performance. The Competent Body isresponsible for administering the scheme and maintaining aregister of organisations that are participating.
IEMA also hold a register of organisations issued with acertificate for the IEMA Acorn Scheme. The register containsthe contact details of the organisation, the phase level it hasachieved and the industry sector.
Copies of BS 8555 are available to purchase from the IEMAwebsite: www.iema.net/shop
IEMA
St Nicholas House70 NewportLincolnLN1 3DPUKTel: 01522 540069Fax: 01522 540090www.iema.net
The Stationary Office (TSO)
Since July 1999 all new acts are published on the Internet, onthe Her Majesty’s Stationery Office Web pages. The sitecontains the full text of all public and local acts of the UKParliament, the explanatory notes to public acts, statutoryinstruments and draft statutory instruments. You can viewthis information on the web site www.hmso.gov.uk
Groundwork
Groundwork is a federation of trusts in England, Wales andNorthern Ireland. Each of the trusts work with partners suchas local authorities, regional agencies, the Government andbusinesses to improve the quality of the local environment.Groundwork host a series of events and many have anenvironmental business service which can offer consultancyand training on environmental issues. To find out more, go towww.groundwork.org.uk
AcknowledgementsCatherine Golds David WinterburnMichael Crawford
