ISO 14001 GUIDANCE

4.1 Environmental Policy

Principle 1

An organization should focus on what needs to be done. It should ensure commitment to EMS and define its policy.

General

The organization should begin where there is obvious benefit, for example, by focusing on regulatory compliance, by limiting sources of liability or by making more efficient use of materials. As the organization grows in experience, and its EMS starts to take shape, procedures, programmes and technologies can be put in place to further improve environmental performance. Then, as the EMS matures, environmental considerations can be integrated into all business decisions.

Top Management Commitment and Leadership

To ensure success, the first step in developing or improving an Environmental Management System is obtaining commitment from the top management of the organization to improving the environmental performance of the organization in managing its activities, products and services. The ongoing commitment and leadership of the top management is crucial.

Initial Environmental Review

The current position of an organization with regard to the environment can be established by means of an initial environmental review. The initial review can cover the following areas:

• identification of legislative and regulatory requirements;
• identification of environmental aspects, significant environmental impacts and liabilities;
• evaluation and documentation of significant environmental issues;
• evaluation of performance compared with relevant internal criteria, external standards, and regulations,
• codes of practice and sets of principles and guidelines;
• existing environmental management practices and procedures;
• identification of the policies and procedures dealing with procurement and contracting activities;
• feedback from the investigation of previous incidents of non-compliance;
• opportunities for competitive advantage;
• the views of interested parties; and,
• functions or activities of other organizational systems that can enable or impede its environmental performance.

In all cases, consideration should be given to the full range of operating conditions, including possible incidents and emergency situations.

The process and results of the initial environmental review should be documented and opportunities for EMS development should be identified.

Practical Help-Initial Environmental Review

An important first step is to develop the list of areas to be reviewed. This can include organization activities, specific operations or a specific site.

Some common techniques for conducting a review include:

• questionnaires
• interviews
• checklists
• direct inspection and measurement
• records review
• benchmarking organizations, including SMEs, can look to a number of outside sources such as:
  • the enforcement agency in relation to laws and permits
  • local or regional libraries or databases
  • other organizations for exchange of information
  • industry associations
  • larger customer organizations
  • manufacturers of machinery in use
  • business relations such as transporters and disposers of waste
  • professional help

Environmental Policy

An environmental policy establishes an overall sense of direction and sets the parameters of action for an organization. It sets the overall goal as to the level of environmental performance required of the organization against which all subsequent actions will be judged. A growing number of international organizations including government, industry associations and citizens' groups have developed guiding principles (see Appendix A). Such guiding principles have helped organizations define the overall scope of their commitment to the environment. They also help to give different organizations a common set of values. Based on these comprehensive principles, any organization can then develop its policy which can be as individual as the organization for which it is written. The responsibility for setting environmental policy rests with those with proprietary interest in the organization, or with their delegates (e.g.. a board of directors or another governing body). The organization's management is responsible for implementing the policy and for providing input to the formulation and modification of the policy.

An environmental policy should consider the following:

• the organization's mission, vision, core values and beliefs
• requirements of and communication with interested parties
• continual improvement
• guiding principles
• alignment with other organizational policies (e.g. Quality, Health Safety)
• specific local or regional conditions

Issues to be Considered in Environmental Policy

• Does the organization have an environmental policy?
• Does the policy reflect the organization's values and guiding principles?
• Has the environmental policy been approved by the Board of Directors or other governing body and has someone been identified and given the authority to oversee and implement the policy?
• Does the policy drive the setting of environmental objectives and targets?
• Does the policy guide the organization towards monitoring best available technology and management practices?
• Does the policy support continual improvement?
• Does the policy state the organization's commitment to monitor and meet or exceed the legal requirements and to consider the expectations of its interested parties?

Practical Help-Environmental Policy

All activities, products and services can give rise to impact on the environment. The environmental policy should recognize this. A detailed review of the guiding principles in Appendix A can help in drafting an appropriate policy. The issues addressed in the policy depend on the nature of the organization. In addition to compliance with environmental regulations, the policy can state commitments to:

• minimize the environmental impacts of new developments through the use of the integrated environmental management procedures and planning
• development of environmental performance evaluation procedures and associated indicators
• embody life cycle thinking
• design products in such a way as to minimize their environmental impacts in production use and disposal, prevent pollution, reduce waste and the consumption of resources (materials, fuel and energy) and commit to recovery and recycling, as opposed to disposal where feasible
• education and training
• technology transfer
• effective involvement of and communication with interested parties to work towards the achievement of sustainable development
• encourage the use of EMS by suppliers and contractors

4.2 PLANNING

Principle 2

An organization should formulate a plan to fulfill its environmental policy.

General

The environmental management system elements relating to planning include: identification of environmental aspects and evaluation of impacts; environmental policy; internal criteria; environmental objectives and targets, and environmental plans and management programmes.

Identification of Environmental Aspects and Evaluation of Associated Environmental Impacts

Before an organization can establish its policies and prioritize its objectives and targets, it should identify the environmental aspects and significant environmental impacts associated with its activities, products and services. The purpose of doing so is to ensure that the significant environmental impacts associated with these aspects are taken into account in seeing the environmental objectives. The identification of the environmental aspects is an ongoing process that determines the past, current and potential impact (positive or negative) of an organization's activities on the environment. This process also includes the identification of the potential regulatory, legal and business exposure affecting the organization. It can also include identification of impact on the health and safety of people and environmental risk assessment.

Issues to be Considered in Identification of Environmental Aspects and Evaluation of Environmental Impacts

• 1. Have potential environmental aspects of the organization's activities, products and services been identified?
• 2. Do the organization's activities, products or services create any change (positive or negative) to or in the environment?
• 3. Does the location of the organization require special environmental consideration?
• 4. Will any intended changes or additions to activities, products or services alter the environmental aspects and impacts?
• 5. How significant or severe are the potential environmental impacts should a process failure occur?
• 6. How frequently will the situation arise that could lead to the impact?
• 7. What are the significant environmental impacts identified; considering likelihood, severity, and frequency?

Practical Help-Identification of Environmental Aspects and Evaluation of Associated Environmental Impacts

This is a procedure that can be dealt with in four stages.

Step 1. Select an Activity or Process

The selected activity or process should be large enough for meaningful examination and small enough to be sufficiently understood.

Example: Product Design

Step 2. Identify Environmental Aspects of the Activity or Process

Identify as many environmental aspects as possible associated with the selected activity or process. Example: Product Design can have the following aspects:

• packaging
• raw materials
• processing energy
• etc.

Step 3. Identify Impacts

Identify as many actual and potential positive and negative environmental impacts as possible associated with each identified aspect. Example: Packaging can have the following impacts:

• increase or decrease of landfill space used
• increase or decrease of litter generated
• increase or decrease use of nonrenewable resources
• etc.

Step 4. Evaluate Significance of Impacts

The significance of each of the identified environmental impacts can be different for each organization. Quantification can aid judgment. Evaluation can be facilitated by considering:

• Environmental Concerns:
  • the scale of the impact
  • the severity of the impact
  • probability of occurrence
  • permanence of impact

• Business Concerns:
  • potential regulatory and legal exposure
  • difficulty of changing the impact
  • cost of changing the impact
  • effect of change on other activities and processes
  • concerns of interested parties
  • effect on the public image of the organization

Legal Requirements

The organization should establish and maintain procedures to identify, have access to and understand all legal and other requirements which are directly applicable to the environmental aspects of its activities, products and services.

Practical Help-Legal Requirements To maintain regulatory compliance an organization should identify and understand regulatory requirements applicable to its activities, products, and services. Regulations can exist in several forms.

• those specific to the activity (site operating permits)
• those specific to the organization's products and services
• those specific to the organization's industry
• general environmental laws
• authorizations, licenses and permits

Several sources can be used to identify environmental regulations and ongoing changes, including:

• all levels of government
• industry associations or groups
• commercial databases
• professional services

To facilitate keeping track of legal requirements, an organization can establish and maintain a list of all laws and regulations pertaining to its activities, products and services.

Internal Performance Criteria

Internal priorities and criteria should be developed and implemented where external standards do not meet the needs of the organization or are nonexistent. Internal criteria, together with external standards where they exist, define the performance required to fulfill the organization's policies, objectives and targets.

Practical Help-Internal Performance Criteria

A typical list of areas where an organization can have internal performance criteria might include:

• management systems
• employee responsibilities
• acquisition. property management and divestiture
• suppliers
• contractors
• product stewardship
• environmental communications
• regulatory relationships
• environmental incident response and preparedness
• environmental awareness and training
• environmental measurement and improvement
• process risk reduction
• pollution prevention and resource conservation
• capital projects
• process change hazardous material management waste
• management water management (e.g., waste, storm, ground)
• air quality management
• energy management
• transportation

Environmental Objectives and Targets

Objectives should be established to meet the organization's environmental policy. These objectives are the broad overall goals for environmental performance identified in the environmental policy. When establishing its objectives, an organization should also take into account the relevant findings from environmental reviews and the identified environmental aspects and associated environmental impacts.

These reviews should lead to the identification of specific, measurable environmental performance indicators. These indicators can be used to describe the organization's performance or to become the basis for objectives or targets.

Environmental targets can then be set to achieve these objectives within a specific dine frame. The targets should be specific and measurable.

Objectives and targets may apply broadly across an organization or more narrowly to site specific ones for individual activities. Appropriate levels of management should define the objectives and targets. Objectives and targets should be periodically reviewed and revised, and should take into consideration the views of interested parties.

Issues to be Considered in Environmental Objectives and Targets

• 1. Are the organization's environmental objectives and targets established:
  • within the context of the policy?
  • reflecting the environmental aspects and the significant environmental impacts?
  • in terms of specific, measurable indicators?
  • with the involvement of the people who are responsible for achieving them?
  • considering the views of interested parties?
• 2. Are objectives and targets regularity reviewed and revised to reflect desired improvements in environmental performance?

Practical Help-Objectives and Targets

Objectives can include commitments to:

• reduce waste and the depletion of resources
• reduce or eliminate the release of pollutants into the environment
• design products to minimize their environmental impact in production, use, and disposal
• control the environmental impact of raw material sourcing
• minimize the environmental impact of new developments
• promote environmental awareness among employees and the community

Progress towards an objective can generally be measured using environmental performance indicators such as:

• quantity of raw material or energy used
• quantity of emissions such as CO₂
• waste produced per quantity of finished product
• efficiency of material and energy use
• number of environmental incidents/accidents
• % waste recycled
• % recycled material used in packaging
• number of vehicle miles per unit of production
• specific pollutant concentrations, e.g. NODE, SO, CO, HC, Pb, CFCs

• An Integrated Example:
• Objective: Reduce energy required in manufacturing operations
• Indicator: Quantity of fuels and electricity per unit production
• Target: Achieve 10% reduction during 1995.

Environmental Management Plans and Programmes

Within the general planning of activities an organization should establish environmental management plans and programmes addressing schedules, resources and responsibilities for achieving the organization's environmental policy, objectives. and targets.

An environmental management plan provides the long term framework for the organization to improve environmental performance. Environmental management plans can be free standing or integrated into the organization's strategic plan.

Within the framework provided by the environmental management plan, an environmental management programme identifies specific action steps, schedules, resources and responsibilities required to achieve the stated targets, in order of their priority to the organization.

An environmental management plan should be dynamic and should be revised regularly to reflect changes in organizational objectives and targets. The environmental management programme can be divided into a series of more specific action plans to deal with individual processes, projects, products, services, sites or facilities within a site.

Issues to be Considered in Environmental Management Plans and Programmes

• 1. Does the organization have an environmental management planning process?
• 2. Does the environmental management planning process involve all responsible parties?
• 3. Is the environmental management plan linked to the policies and objectives of the organization?
• 4. Is there a process for periodic reviews of the plan?
• 5. Does the organization have a process for developing an environmental management programme?
• 6. Do these programmes address the issues of resources, responsibility, timing, and priority?
• 7. Is the environmental management programme fully integrated with the environmental policy and environmental management plan?
• 8. Is the environmental management programme monitored on an ongoing basis as part of the operational review process?

Practical Help-Environmental Management Plans and Programmes

A useful distinction can be made between an environmental management plan for the longer term and the shorter term environmental management programme of the organization.

Long term planning is useful in mapping out the application of the continual improvement of environmental performance, and forms the basis of future details of an environmental management programme.

A long term environmental management plan can include:

• a description of the current situation of the organization's environmental performance at the time the plan is released;
• a description of the proposed improvements of the organization's environmental performance over the planned period;
• consideration of technology requirements to implement the proposed improvements;
• awareness of internal and external factors influencing the proposed improvements (e.g., financial resources, capital projects, facility location, market needs/developments, legislative and regulatory developments, expectations of interested parties).

A short term environmental management programme can include:

• prioritization of environmental issues
• development of options for priority issue resolution
• a cost/benefit review of these options and selection of the preferred approach
• identification of responsibility for implementation
• provision for post-implementation review and assessment

Practical Help-Environmental Management Plans and Programmes

Example of Objectives and Targets Linked in Environmental Management Plans and Programmes

• Policy: To conserve natural resources.
• Objective: To minimize the use of water wherever technologically and commercially viable.
• Target: To reduce water consumption by 15% of present levels within one year. Such a target would in turn have to be translated into a number of action plans, including for example:
• Action Plan: Install equipment to recycle rinse water for Process A for reuse in Process B which does not require water of the same high quality.
• Person Responsible: John Waters
• Resources:
  • existing operations staff
  • new water recycling technology
  • 100K from capital budget
• Completion Date: November X. 19XX.

4.3 IMPLEMENTATION AND OPERATION

Principle 3

For effective implementation an organization should develop the capabilities and support mechanisms necessary to achieve its environmental policy, objectives and targets.

General

The capabilities and support required by the organization constantly evolve in response to changing requirements of interested parties, a dynamic business environment, and the process of continual improvement. To achieve its environmental objectives an organization should focus and align its people, systems, strategies, resources and structure.

For many organizations, implementing environmental management can be approached in stages and should be based on the level of awareness of requirements, aspects, expectations and benefits, and the availability of resources.

The organization can begin where there is obvious benefit: eliminating sources of liability and unnecessary cost, making more efficient use of materials, and reusing and recycling waste. As more knowledge is gained and resources become available advances can be made.

ENSURING CAPABILITY

Resources-Human, Physical, and Financial

The appropriate human, physical (e.g. facilities, equipment), and financial resources essential to the implementation of an organization's environmental policies and the achievement of its objectives should be defined and made available. In allocating resources, organizations can develop procedures to track the benefits as well as the costs of their activities, products and services, such as the cost of pollution control, wastes and disposal.

Issues to be Considered in Human, Physical, and Financial Resources

• 1. How does the organization identify and allocate the human, technical and financial resources necessary to meet its objectives and targets?
• 2. Does the organization have a process to evaluate the environmental resource requirements (human, technical, financial) associated with capital projects?
• 3. Are procedures developed to track the costs and benefits (Return On Investment) of environmental activities?

Practical Help-Human, Physical and Financial Resources

The resource base and the organizational structure of the SME can impose certain limitations on implementation. In order to manage these constraints the SME should, wherever possible, consider cooperative strategies with:

• larger client organizations to share technology and know how
• other SMEs on a supply chain or local basis to define and address common issues to share know how, to facilitate technical development, to use facilities jointly, to establish a way to study the EMS, to collectively engage consultants
• standardization organizations, SME associations, Chambers of Commerce, for training and awareness programmes
• universities and other research centers to support production and innovation.

EMS Alignment and Integration

To effectively manage environmental concerns the EMS elements should be designed or revised so that they are effectively aligned and integrated with existing management elements.

Management system elements that can require integration include:

• organization policies
• resource allocation
• operational controls and documentation
• information and support systems
• training and development
• organization and accountability structure
• reward and appraisal systems
• measuring and monitoring systems
• communication and reporting

Issues to be Considered in Organizational Alignment and Integration

• 1. Has the environmental management system been integrated into the overall business management process?
• 2. Is there a process to balance and resolve conflicts between environmental and other business objectives and priorities?

Accountability and Responsibility

Responsibility for the overall effectiveness of the EMS should be assigned to a senior person or function(s) with sufficient authority, competence. and resources.

Operational managers should clearly define the responsibilities of relevant personnel and be responsible and accountable for effective implementation of the EMS and environmental performance. Employees at all levels should be accountable, within the scope of their responsibilities. for environmental performance in support of the overall environmental management system.

Issues to be Considered in Accountability and Responsibility

• 1. Are the responsibilities and accountability of key personnel who manage, perform and verify work affecting the environment, defined and documented?
• 2. Do these personnel:
  • provide sufficient training, resources, and personnel for implementation?
  • initiate action to ensure compliance with environmental policy?
  • anticipate, identify, and record any environmental problems?
  • initiate, recommend, or provide solutions to those problems?
  • verify the implementation of such solutions?
  • control further activities until any environmental deficiency or unsatisfactory condition has been corrected?
  • know how to act in emergency situations?
  • understand the consequences of noncompliance?
  • understand the accountability that applies to them?
  • encourage voluntary action and initiatives?
  • have environmental responsibilities and performance recognized in their reward and recognition systems?

Practical Help-Accountability and Responsibility

To ensure effective development and implementation of an EMS, it is necessary to assign appropriate responsibilities and authorities. One possible approach for developing environmental responsibilities is indicated below. It should be recognized that companies and institutions have different organizational structures, and need to understand and define environmental responsibilities based upon their own work processes.

Sample Environmental Responsibilities--- Typical Person Responsible

• Establish Overall Direction--- President, CEO, Chief Environmental Mgr.
• Develop Environment policy--- President, CEO, Chief Environmental Mgr.
• Monitor overall EMS performance--- Chief Environmental Mgr., Environment Committee
• Assure regulatory compliance (external)--- Senior Operating Manager
• Ensure EMS compliance (internal)--- All Managers, Chief Environmental Mgr.
• Ensure continual improvement--- All Managers
• Identify customers' expectations--- Sales and Marketing Staff
• Identify suppliers expectations--- Purchasers, Buyers
• Develop/Maintain accounting procedures--- Finance/Accounting Managers
• Comply with defined procedures--- All Staff

Environmental Values and Motivation

A common set of environmental values should be developed and reinforced for the organization, taking into account views of interested parties.

Senior management has a key role in communicating values and motivating employees. It is the commitment of the individual people, in the context of shared values, that transforms an environmental management system from paperwork into an effective process.

All members of the organization should understand and be encouraged to accept the importance of achieving the environmental objectives and targets for which they are responsible and/or accountable. They in turn should encourage where necessary the other members of their organization to respond in a similar manner.

Motivation to continually improve can be enhanced when employees are recognized and rewarded for achieving environmental objectives and targets and encouraged to make suggestions that can lead to improved environmental performance.

Issues to be Considered in Environmental Values

• 1. Has management taken action to establish, reinforce. and communicate organizational environmental values?
• 2. To what extent do employees understand, accept, and share the environmental values of the organization?
• 3. To what extent do shared environmental values serve to motivate environmentally responsible action?
• 4. Do performance reviews and reward and recognition systems include environmental activities?

Knowledge, Skills and Training

The knowledge and skills necessary to achieve environmental objectives should be identified. These should be considered in personnel selection, recruitment, training, skills development and ongoing education.

Appropriate training relevant to the achievement of environmental policies, objectives and targets should be provided to all personnel within an organization. Employees should have an appropriate knowledge base, which includes training in the methods and skills required to perform their tasks in an efficient and competent fashion and knowledge of the impact their activities can have on the environment if performed incorrectly.

The organization should also ensure that contractors working at the site provide evidence that they have the requisite knowledge and skills to perform the work in an environmentally responsible manner.

Since the level and detail of training varies according to the task. education and training are needed to ensure that employees' knowledge of regulatory requirements, internal standards and the organization's policies and objectives is current.

Training programmes typically have the following elements:

• identification of employee training needs;
• development of a training plan to address defined needs;
• verification of conformance of training programmes to regulatory or organizational requirements;
• training of target employee groups; and,
• documentation of training received.

Getting Started in Knowledge, Skills, and Training

• 1. Does the organization identify environmental training needs?
• 2. Are the training needs of specific job functions analyzed?
• 3. Is a training programme developed and reviewed regularly?
• 4. Does this process include documentation and evaluation?

Practical Help-Knowledge, Skills and Training

The following types of environmental training can be provided:

Type of Training Audience Purpose

Raising awareness of Env. Issues----Senior Management
Raising awarness of Environmental Policy----All employees
Skills Enhancement----Employees with environmental  areas-operations
Compliance----Employees whose actions ensure regulatory and internal compliance 

SUPPORT ACTION

Communication and Reporting

Communication includes establishing processes and plans to report internally and externally on the environmental activities of the organization in order to:

• demonstrate management commitment to the environment;
• deal with concerns and questions about the environmental issues of the organization's activities, products, and services;
• raise awareness of the organization's environmental policies, objectives targets, and programmes; and
• inform internal or external interested parties about the organization's environmental management system and performance as appropriate.

Results from EMS monitoring audit and management review should be communicated to those within the organization who are responsible for improvement.

The provision of appropriate information to the organization's employees and other interested parties serves to motivate employees and encourage public understanding and acceptance of the organization's efforts to improve its environmental performance.

Issues to be Considered in Communication and Reporting

• 1. Is there a system for receiving and responding to concerns?
• 2. Is there a process for communicating the organization's environmental policy and performance?
• 3. Are the results from EMS audits and reviews communicated to all appropriate people in the organization?
• 4. Are internal communications adequate to support continual improvement around environmental issues?

Practical Help-Communication and Reporting

• a) Items that can be included in reports:
  • organization's profile;
  • environmental policy, objectives and targets;
  • environmental management processes (including interested party involvement and employee recognition);
  • environmental performance evaluation (including releases, resource conservation, compliance, product stewardship and risk);
  • opportunities for improvement, supplementary information, such as glossaries;
  • independent verification of the contents.
• b) Important things to remember for both internal and external environmental communication and reporting include:
  • two way communication should be encouraged;
  • information should be understandable and adequately explained;
  • information should be verifiable;
  • the organization should present an accurate picture of its performance;
  • information should be presented in a consistent form (e.g.,similar units of measurement to allow for comparison between one period and another).
• c) An organization can communicate environmental information in a variety of ways:
  • externally, through an annual report, regulatory submissions,
  • public government records, industry association publications, the media, and paid advertising
  • organization of open days, the publication of telephone numbers where complaints and questions can be directed;
  • internally, through bulletin board postings, internal newspapers, meetings and electronic mail messages.

EMS Documentation

Operational processes and procedures should be defined and appropriately documented and updated as necessary. The organization should clearly define the various types of documents which establish and specify effective operational procedures and control.

The existence of EMS documentation supports employee awareness of what is required to achieve the organization's environmental objectives and enables the evaluation of the system and environmental performance.

Often the key item of EMS documentation is an Environmental Management Manual. The nature of this can vary depending on the size and complexity of the organization. Where elements of the EMS are integrated with an organization's overall management system the environmental documentation should be integrated into existing documentation. For ease of use, the organization can consider organizing and maintaining a summary of the documentation to:

• collate the environmental policy, objectives. and targets;
• describe the means of achieving environmental objectives and targets;
• document the key roles, responsibilities and procedures;
• provide direction to related documentation and describe other aspects of the organization's management system where appropriate; and
• demonstrate that the environmental management system elements appropriate for the organization are implemented.

Such a summary document can serve as a permanent reference to the implementation and maintenance of the organization's environmental management system.

Issues to be Considered in EMS Documentation

• 1. Are environmental management procedures identified documented, and communicated?
• 2. Does the organization have a permanent reference to the existence, implementation and maintenance of the EMS?
• 3. Is EMS documentation integrated with existing documentation where appropriate?

Practical Help-EMS Documentation

All documentation should be dated (with dates of revision), readily identifiable, organized, and retained for a specified period.

The organization should ensure that:

• documents can be identified with the appropriate organization, division, function, activity, and/or contact person;
• documents are periodically reviewed, revised as necessary and approved by authorized personnel prior to issue;
• the current versions of relevant documents are available at all locations where operations essential to the effective functioning of the system are performed;
• obsolete documents are promptly removed from all points of issue and points of use.

EMS Records and Information Management

Records are the evidence of the ongoing operation of the EMS and should cover:

• legislative and regulatory requirements
• permits
• environmental aspects and impacts
• environmental training activity
• inspection, calibration and maintenance activity
• monitoring data
• details of non-conformance: incidents, complaints and followup action
• product identification: composition and property data
• supplier and contractor information
• environmental audits and reviews

A complex range of information can result. The effective management of these records is essential to the successful implementation of the EMS. The key features of good environmental information management include: means of identification, collection, indexing, filing, storage, maintenance, retrieval, retention and disposition of pertinent EMS documentation and records.

Issues to be Considered in EMS Records and Information Management

• 1. Does the organization have the environmental information it needs to manage effectively?
• 2. Does the organization have the capability to identify and track key indicators of performance and other data necessary to achieve its objectives?
• 3. Does the organization have a record /information management system that makes information available to the people who need it when they need it?

Operational Controls

Implementation is accomplished through the establishment and maintenance of operational procedures and controls to ensure that the level of environmental performance is consistent with the organization's policies, objectives, and targets.

Practical Help-Operational Controls

The organization should consider the different functions contributing to its significant impacts when developing operational controls and procedures, e.g.:

• R&D design and engineering
• storage of final products
• purchasing
• transport
• contractors
• marketing, advertising
• raw materials storage
• customer service
• production processes
• final disposal of product
• laboratories

Activities can be divided into three categories:

• activities to prevent pollution and conserve resources in new capital projects, process changes and resources management, property (acquisitions, divestitures, and property management), and new products and packaging;
• daily management activities to assure conformance to internal and external corporate requirements, to increase efficiency of these activities and to continuously improve performance;
• strategic management activities to anticipate and respond to changing environmental requirements.

Emergency Preparedness and Response

Emergency plans and procedures should be established to ensure that there will be an appropriate response to unexpected or accidental incidents.

The organization should define and maintain procedures for dealing with environmental incidents and potential emergency situations. The operating procedures and controls should include, where appropriate, consideration of:

• accidental emissions to atmosphere;
• accidental discharges to water and land; and
• specific environmental and ecosystem effects from accidental releases.

The procedures should take into account incidents arising, or likely to arise, as consequences of:

• abnormal operating conditions, and
• accidents and potential emergency situations.

Practical Help-Emergency Preparedness and Response

Emergency plans can include:

• emergency organization and responsibilities and, in particular, those who have overall authority:
• details of emergency services (e.g. fire department, spill cleanup services);
• an internal and external communication plan;
• actions taken in the event of different types of emergencies;
• information on hazardous materials, including each material's potential impact on the environment, and measures to be taken in the event of accidental release; and
• training plans and testing for effectiveness.

4.4 CHECKING AND CORRECTIVE ACTION

Principle 4

An organization should measure, monitor and evaluate its environmental performance.

General

Measuring, monitoring and evaluating are key activities of an environmental management system which ensure that the organization is performing in accordance with the stated environmental management programme.

Measuring and Monitoring (Ongoing Performance)

There should be a system in place for measuring and monitoring actual performance against the organization's environmental objectives and targets in the areas of management systems and environmental effectiveness of the operational processes. The results should be analyzed and used to determine areas of success and to identify activities requiring corrective action and improvement.

Appropriate processes should be in place to ensure the reliability of data, such as calibration of instruments, test equipment, and software and hardware sampling.

Identifying appropriate environmental performance indicators for the organization should be an ongoing process. Such indicators should be objective, verifiable, and reproducible. They should be relevant to the organization's activities, consistent with its environmental policy, practical, cost-effective, and technologically feasible.

Issues to be Considered in Measuring and Monitoring

• 1. Is environmental performance regularly monitored?
• 2. Have specific environmental performance indicators been established which relate to the organization's objectives and targets?
• 3. Are there control processes in place to regularly calibrate and sample measuring and monitoring equipment and systems?

Audits of the Environmental Management System

Audits of the Environmental Management System should be conducted on a periodic basis to determine whether the system conforms to planned arrangements and has been properly implemented and maintained. See ISO 14010 to 14012.

Audits of the EMS can be carried out by organization personnel, and/or by external parties selected by the organization. In any case, the person conducting the audit should be in a position to do so objectively and impartially and should be properly trained.

The frequency of audits should be guided by the nature of the operation in terms of its environmental aspects and potential impacts. Also, the results of previous audits should be considered in determining frequency.

The EMS audit report should be submitted in accordance with the audit plan.

4.5 MANAGEMENT REVIEW

Principle 5

An organization should review and continually improve its environmental management system, with the objective of improving its overall environmental performance.

General

A continual improvement process should be applied to an environmental management system to achieve overall improvement in environmental performance. Continual improvement starts with measuring and monitoring.

Review of the Environmental Management System

The organization's management should, at appropriate intervals, conduct a review of the Environmental Management System to ensure its continuing suitability and effectiveness.

The review of the EMS should be broad enough in scope to address the environmental dimensions of all activities, products, and services of the organization, including their impact on financial performance and possibly competitive position.

Review of the Environmental Management System should include:

• review of environmental objectives, targets and environmental performance;
• findings of the EMS audits;
• an evaluation of its effectiveness;
• an evaluation of the suitability of the environmental policy and the need for changes in the light of changing
  • legislation;
  • changing expectations and requirements of interested parties;
  • changes in the products or activities of the organization;
  • advances in science and technology;
  • lessons learned from environmental incidents;
  • market preferences;
  • reporting and communication.

Issues to be Considered in the Review of the EMS

• 1. Are there periodic reviews of the Environmental Management System?
• 2. Are the appropriate people involved in the review of the Environmental Management System and followup?

Corrective and Preventive Action

The findings, conclusions, and recommendations reached as a result of audits and reviews of the Environmental Management System should be documented and the necessary corrective and preventive actions identified Management should ensure that these corrective and preventive actions have been implemented and that there is systematic followup to ensure effectiveness.

Continual Improvement

The concept of continual improvement is embodied in the EMS. It is achieved by continually evaluating the current performance of activities, products, and services for the purpose of identifying overall EMS improvement opportunities (see figure 2).

The continual improvement process should:

• identify areas of opportunity for improvement of the environmental management system and/or environmental performance;
• determine the root cause or causes of non-conformances or deficiencies;
• develop and implement a plan of corrective and preventive action to address root causes;
• verify the effectiveness of the corrective and preventive actions;
• document any changes in procedures resulting from process improvement;
• make comparisons with objectives and largess.

Issues to be Considered in Corrective and Preventive Action and Continual Improvement

• 1. Does the organization have a process to identify areas for corrective and preventive action and improvement?
• 2. Does the organization verify that corrective and preventive actions and improvements are effective and timely?

To obtain ISO 14000 Consulting or ISO 14001 Gap Analysis or Audit, call John Wiemhoff at:  JRW Environmental Consulting, Inc.,   990 Ponderosa Lane, Barrington, IL  60010   Phone: (847) 705 7781                 e-mail: jwiemhoff@jrwenviro.com       Web Site: http//www.jrwenviro.com  

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