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NQA EMS Handbook


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handbook for ISO 14001

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NQA EMS Handbook

  1. 1. Managing yourenvironmentalfootprint guide to implementing an environmental management system t: 08000 522 424 e: w:
  2. 2. ContentsIntroduction to environmental management systems (EMS) 2Benefits of implementing an EMS 5Correspondance with other standards 6How to use this guide 8Definitions 9Principles of ISO 14001 12Initial Environmental Review 14Environmental management system elements 174.1 - General requirements 174.2 - Environmental policy 184.3 - Planning 224.4 - Implementation and operation 384.5 - Checking 534.6 - Management review 62Registration to environmental management systems 65Reference list 70 1
  3. 3. Introduction to EnvironmentalManagement SystemsThe concept of environmental management within business world. This eventually led to calls for an internationally-has evolved rapidly in recent years and pressure is being recognised standard. The International Organisation forplaced upon organisations more and more to mitigate any Standardisation (ISO) responded to these demands byadverse impact that their business may have on the setting up a working group to develop a new set ofenvironment, when this is further enforced by stringent environmental standards (the ISO 14000 series), which couldenvironmental legislation, it makes it increasingly difficult to be implemented by all types of organisations, regardless ofignore such issues. their activity or location.In a climate of increased media and public scrutiny, organisations The European Commission also responded to the increasedof all sizes are now looking to formal management systems as a interest in environmental management systems by developingframework for improving performance. the Eco-Management and Audit Scheme (EMAS), for manufacturing companies within the European Union.The concept of environmental management systems (EMS)has spread across the world and through all sectors. ISO 14001Many early environmental management systems were In 1996, the first of the international EMS standards (ISOdeveloped alongside quality management and took on 14001 and ISO 14004) were published. These standards laidmany of the characteristic elements of the quality standard, down specifications and guidance for the development of anISO 9001. However, these systems were often developed environmental management system, which could be audited‘in-house’ and did not independently demonstrate that and certified by independent certification bodies. Theseorganisations were doing what they stated in their policy standards eventually superseded BS 7750 in the UK.statements. This led to the creation of some of the firststandardised environmental systems. The adoption of the international environmental management system (EMS) standard ISO 14001 can be a complementaryHowever, it was not until 1992 that a nationally-recognised device for adhering to the extensive environmental legislativeand universally-applicable standard was produced. This was requirements and bring benefits to businesses, which include apublished by the British Standards Institute and entitled profitable difference to the bottom line.BS 7750 Specification for Environmental ManagementSystems. It also took a quality systems approach to On 15th November 2004, the revision process of ISOenvironmental management and was centred on the Deming 14001:1996 was completed and ISO 14001:2004 wasCycle - plan, do, check and act. The standard also allowed, published. The changes to the standard were aimed atfor the first time, external and independent assessment of making it more user friendly and to clarify some of thethe system to ensure organisations met the requirements requirements. It also brings it into line with some of theof the standard. clauses with ISO 9001:2000.As the world’s first environmental management standard, ISO 14004:2004 Environmental Management Systems –BS 7750 raised considerable interest in the United Kingdom, General guidelines on principles, systems and supportbut more importantly, in many other countries around the techniques was also published on 15th November 2004.2
  4. 4. ISO 14001 is now the most widely-used environmental and risks rather than a full EMS based on ISO 14001,management standard in the world. The ISO Survey recognition through the IEMA Acorn Scheme at Phase 3 willreported that, as of December 2005, there were over 6,055 give customers and the public confidence that theorganisations certified in the UK and an estimated 11,162 1 organisation are focused on controlling their environmentalworldwide in 138 countries. These figures are set to increase risks including ensuring compliance with legal requirementsas many more companies realise the considerable benefits and developing objectives and targets but will not place anthat can be gained from taking a more systematic approach unnecessary burden on the environmental improvement. The different phases are:BS 8555/ Acorn Phase 1 – Commitment and establishing the baseline,In 2003, a new environmental management system standardwas published. BS 8555 enables environmental management Phase 2 – Identifying and ensuring compliance with legal andsystems (EMS) to be accessible to all and the IEMA Acorn other requirements,Scheme allows recognition for implementation and operationat certain phases. BS 8555 provides guidance on how to Phase 3 – Developing objectives, targets and programmes,tackle environmental performance evaluation andimprovement, it makes EMS simple and easy. BS 8555 is titled Phase 4 – Implementation and operation of the EMS,Environmental management systems – Guide to the phasedimplementation of an environmental management system Phase 5 – Checking, audit and review,including the use of environmental performance evaluation. Phase 6 – Environmental Management SystemIt seeks to provide guidance for all organisations who are acknowledgement.seeking to implement a formal environmental managementsystem, for example ISO 14001 or the EU Eco-Management The main benefits of this incremental approach is that itand Audit Scheme (EMAS). BS 8555 makes particular offers flexibility and the implementation and registrationreference to small and medium sized enterprises (SMEs) and can proceed at a rate that takes into account the manyoutlines a phased implementation process for EMS. other pressures and demands that will be facing an organisation.The standard focuses on environmental performance controland is broken down into six manageable phases. These The Institute of Environmental Management and Assessmentphases can be tackled incrementally at a pace that suits the (IEMA) Acorn Scheme has been developed to provide aorganisation. Each phase is then broken down into a series of means of recognising those organisations that evaluate andmanageable stage profiles. Following through all the phases improve their environmental management and performancecould lead an organisation to being in a position to be through the phased approach. The scheme allows suchassessed against ISO 14001 or EMAS. organisations to gain recognition for their environmental achievements along the way. The scheme requires theIt is ideal for small to medium sized organisations with a low participants to implement a management system to meet theto moderate risk to the environment. In such cases, it may achievement criteria and stage profiles of the phases of BS 8555.not be necessary to move through all the phases. If an A system of independent inspection has been established toorganisation requires control of their environmental impacts provide this recognition; such organisations are called Acorn 3
  5. 5. Inspection Bodies and are accredited by the United Kingdom Assessment (IEMA) carries out this function as theAccreditation Service (UKAS). ‘Competent Body.Many large organisations have started to require their The general aim of EMAS is to ensure that the Europeansuppliers to demonstrate good environmental management. Community develops policies and implements actions toAcorn Scheme recognition could be used as a tool promote sustainable development and environmentalby an organisation to demonstrate this. Acorn/BS 8555 can issues. Amongst other matters, this includes organisationsalso be used to help to develop relationships with external managing the environmental impacts of their products,parties such as suppliers, regulators and the general public. activities and services by adopting a proactive approachThe phased approach is flexible and provides direction at with regard to:each stage. • preventing, reducing and eliminating pollution at source,This route to environmental management also gives early where possible,indications of its effectiveness as it measures environmentalperformance from day one. By charting progress, it is • ensuring sound management and resources,easier for the management of an organisation to visualise andto plan resources and costs. It also allows for greater • using cleaner technologies, where available.employee involvement and can increase staff morale. BS 8555also requires commitment to realistic timescales for EMAS is transparent and a reliable environmental managementenvironmental improvements. tool. It calls for maintenance of an effective EMS that meets the requirements of ISO 14001 via a system which ensures that aAn organisation can become registered to any phase within policy is available, that objectives, targets and programmes arethe Acorn Scheme up to and including level 5. Beyond level set to improve environmental performance and to ensure5, organisations should seek EMAS or ISO 14001 registration. continuous improvement as a whole.To become registered to the Acorn Scheme, NQA willinspect the organisations environmental management system EMAS could be used by your organisation to exploit newagainst the stage profiles within the relevant phases of opportunities and market places using your validatedBS 8555 to ensure the achievement criteria laid down in environmental statement. EMAS demonstrates that you areBS 8555 have been met. serious about reducing your environmental impact and improving environmental performance.EMAS – Eco-Management and Audit Scheme Differences between EMAS and ISO 14001The origins of EMAS lie in European Council Regulation1836/93, which allowed voluntary participation by industrial Although similar in content, ISO 14001 is an internationalcompany sectors in a Community Eco-Management and standard, whilst EMAS is a European standard. There are aAudit Scheme (EMAS). This regulation was replaced number of subtle differences between the two standardsby 761/2001 which now allows participation in the scheme outlined ALL organisations. The regulation requires EU MemberStates to form administrative structures for the scheme. • EMAS requires an initial environmental review orIn the UK, the Institute of Environmental Management and preparatory review.4
  6. 6. • EMAS requires preparation of a detailed public statement • enhancing your market image or opening up new markets, that must be verified by a third party to ensure that it accurately reflects the information portrayed. This must • meeting customer criteria for approved supplier lists, be verified every three years and an interim statement produced annually, verified, and submitted to IEMA. • reducing raw material and utility costs through improved process efficiency,• EMAS requires that an open dialogue be established between the public and other interested parties. It • reducing the risk of environmental incidents occurring and also requires that employees be involved in the process; minimising their impact, this is aimed at continually improving environmental performance. • improving staff morale through involvement in environmental improvement initiatives.• EMAS states that organisations must ‘provide for compliance with all relevant requirements regarding the The economic benefits of an EMS have been demonstrated environment. Breaches of legislation and regulations may in case studies of organisations of all sizes and activities. result in EMAS registration being withdrawn. This may therefore be one of the key selling points if you need to convince your management team of the valueBenefits of implementing an environmental of implementing an EMS. It is well worth documentingmanagement system (EMS) and communicating the cost savings that you identify as it will help to demonstrate the on-going value of goodThere are many reasons for organisations to decide to environmental practice.implement an environmental management system - not least,the reduced risk of failing to comply with legislation. Other ISO 14001 and correspondence withmajor benefits include reducing waste and increasing other standardsefficiency, an improved working environment and minimisingthe impact of the organisation on the local environment. The ISO 14000 series of standards encompasses a variety of standards and guidance documents on environmentalAn EMS requires you to take a systematic view of your management issues including topics such as guidelines forenvironmental impacts and prioritise your actions. This allows environmental performance evaluation (ISO 14031) and lifeyou to focus time and resources towards the most significant cycle assessment (ISO 14040, ISO 14041, ISO 14042 andimpacts and set realistic action plans for their improvement. ISO 14043).Taking this approach can lead to several benefits for yourorganisation including: A full and current list of the ISO 14000 series can be obtained directly from ISO at• creating a framework for continual environmental improvement, The first standards in the ISO 14000 family were published in 1996. These were ISO 14001 and ISO 14004, which deal with• assuring customers and the public of your commitment environmental management systems. to meeting environmental responsibilities,• improving relations with regulators, 5
  7. 7. ISO 14001 is the core management system standard which environmental management and health and safetyspecifies the requirements for the formulation and management is much stronger and almost all of the OHSASmaintenance of an environmental management system. 18001 clauses are similar to ISO 14001. The potential for integration of these two systems is obvious.The standard specifies the requirements for an EMS toenable an organisation to develop and implement a policyand objectives that take into account legal and otherrequirements and information about the significant aspectsof the organisation.This standard is supported by ISO 14004 which providesguidelines on the elements of an environmental managementsystem and its implementation, and discusses principalissues 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 StandardsThe 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 between6
  8. 8. Similarities Between the ThreeMajor Management System StandardsClause OHSAS 18001:2007 Clause ISO 14001:2004 Clause ISO 9001:20004.1 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 related to the product4.3.3 Objectives and programme(s) 4.3.3 Objectives, targets and programme(s) 5.4.1 Quality objectives 5.4.2 Quality management system planning 8.5.1 Continual improvement4.4.1 Resources, roles, responsibility, 4.4.1 Resources, roles, responsibility, authority 5.1 Management commitment accountability and authority 5.5.1 Responsibility and authority 5.5.2 Management representative 6 Resource management 6.1 Provision of resource 6.2 Human resources 6.2.1 General 6.3 Infrastructure 6.4 Work environment4.4.2 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 realisation 7.2 Customer related process 7.2.1 Determination of requirements related to the product 7.2.2 Review of requirements related to the product 7.3 Design and development 7.3.1 Design and development planning 7.3.2 Design and development inputs 7.3.3 Design and development outputs 7.3.4 Design and development review 7.3.5 Design and development verification 7.3.6 Design and development validation 7.3.7 Control of design and development changes 7.4 Purchasing 7.4.1 Purchasing process 7.4.2 Purchasing information 7.4.3 Verification of purchase product 7.5 Product and service provision 7.5.1 Control of production and service provision 7.5.3 Identification and traceability 7.5.4 Customer property 7.5.5 Preservation of product 7.5.2 Validation of processes for production and4.4.7 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 General 8.2 Monitoring and measuring 8.2.1 Customer satisfaction 8.2.3 Monitoring and measurement of processes 8.2.4 Monitoring and measurement of product 8.4 Analysis of data4.5.2 Evaluation of compliance 4.5.2 Evaluation of compliance 8.2.3 Monitoring and measurement of processes 8.2.4 Monitoring and measurement of product4.5.3 Incident investigation, nonconformity, corrective and preventive action4.5.3.1 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 data 8.5.2 Corrective action 8.5.3 Preventative action4.5.4 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 General 5.6.2 Review input 5.6.3 Review output 8.5.1 Continual improvement 7
  9. 9. How to Use This GuideThis guide is primarily focused on those people who are Each clause contains one or more self-assessment questionsabout to implement an environmental management system (SAQ’s). These can be used to either gauge the extent toin their organisation. As such, it is set out in a practical style which you already meet the requirements of the standard orallowing the reader to use it as a DIY guide. The resulting to measure your progress as you work through yourenvironmental management system not only should meet the implementation programme. The more questions you canrequirements of ISO 14001 but, also the underlying intention answer yes to, the further you have progressed toward fullof the standard. implementation. If you can answer yes to all the self- assessment questions, you are probably ready for registrationThe guidance will be helpful to organisations of all sizes and to ISO 14001. If not, work through this book or contact NQAstructures. This publication will also be of particular interest at the address 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 the NQArequirements of the standard. Read in conjunction with the Warwick Housestandard, the reader will be able to understand the meaning Houghton Hall Parkof each clause, what each requirement expects them to do Houghton Regisand, following the guidance, get on and do it! Dunstable LU5 5ZXAn interpretation and guidance to the intention of eachclause has been provided. It must be remembered that this is E-mail: ems@nqa.coman interpretation only and the standard itself should be Website: www.nqa.comreferred to. Sales Hotline: 08000 52 24 248
  10. 10. DefinitionsAudit client Audit scopeOrganisation or person requesting an audit. Extent and boundaries of an audit.Note: the audit client may be the auditee or any other Note: the audit scope generally includes a description of organisation which has the regulatory or contractual the physical locations, organisational units, activities right to request an audit. and processes, as well as the time period covered.Audit conclusion Audit teamOutcome of an audit, provided by the audit team after One or more auditors conducting an audit (supported ifconsideration of the audit objectives and all audit findings. needed by technical experts).Audit criteria Note 1: one auditor of the audit team is appointed as theSet of policies, procedures or requirements. audit team leader.Note: audit criteria are used as a reference against which Note 2: the audit team may include auditors-in-training. audit evidence is compared. AuditeeAudit evidence Organisation being audited.Records, statements of fact or other information, which arerelevant to the audit criteria and verifiable. Auditor Person with competence to conduct an audit.Note: audit evidence may be qualitative or quantitative. CompetenceAudit findings Demonstrated personal attributes and demonstrated abilityResults of the evaluation of the collected audit evidence to apply knowledge and skills.against the audit criteria. Continual improvementNote: audit findings can indicate either conformity or Recurring process of enhancing the environmental non-conformity with audit criteria or opportunities management system in order to achieve improvements in for improvement. overall environmental performance consistent with the organisation’s environmental policy.Audit planDescription of the activities and arrangements for an audit. Correction Action taken to eliminate a detected non-conformity.Audit programmeSet of one or more audits planned for a specific time frame Corrective actionand directed towards a specific purpose. Action to eliminate the cause of a detected non-conformity.Note: an audit programme includes all activities necessary for planning, organising and conducting the audits. 9
  11. 11. Document Environmental performance Information and its supporting media. Measurable results of an organisation’s management of its environmental aspects. Note: the medium can be paper, magnetic, electronic or optical computer disk, photograph or master Environmental performance indicator - EPI sample, or a combination thereof. Specific expression that provides information about an organisation’s environmental performance. Environment Surroundings in which an organisation operates including air, Environmental policy water, land, natural resources, flora, fauna, people, and their Overall intentions and direction of an organisation related to interaction. its environmental performance as formally expressed by top management. Environmental aspect Element of an organisations activities or products or services Note: the environmental policy provides a framework for that can interact with the environment. action and for the setting of environmental objectives and environmental targets. Note: a significant environmental aspect has or can have a significant environmental impact. Environmental target Detailed performance requirement, applicable to the Environmental impact organisation or parts thereof, that arises from the Any change to the environment, whether adverse or environmental objectives and that needs to be set and met beneficial, wholly or partially resulting from an organisation’s in order to achieve those objectives. environmental aspects. Interested party Environmental management system - EMS Person or group concerned with or affected by the Part of an organisation’s management system used to environmental performance of an organisation. develop and implement its environmental policy and manage its environmental aspects. Internal audit Systematic, independent and documented process for Note 1: a management system is a set of interrelated obtaining audit evidence and evaluating it objectively to elements used to establish policy and objectives and determine the extent to which the environmental to achieve those objectives. management system audit criteria set by the organisation are fulfilled. Note 2: a management system includes organisation structure, planning activities, responsibilities, Note: in many cases, particularly in smaller organisations, practices, procedures, processes and resources. independence can be demonstrated by the freedom from responsibility for the activity being audited. Environmental objective Overall environmental goal, consistent with environmental policy that an organisation sets itself to achieve.10
  12. 12. Management Performance Indicator - MPI ProcedureEnvironmental Performance Indicator that provides Specified way to carry out an activity or process.information about the management efforts to influence anorganisation’s environmental performance. Note: procedures can be documented or not.Non-conformity RecordNon-fulfilment of a requirement. Document stating results achieved or providing evidence of activities performed.Operational Performance Indicator - OPIEnvironmental Performance Indicator that provides Stakeholderinformation about the environmental performance of an See ‘interested party’.organisation’s operations. Technical expertOrganisation Person who provides specific knowledge or expertise to theCompany, corporation, firm, enterprise, authority or audit team.institution, or part or combination thereof, whetherincorporated or not, public or private, that has its own Note 1: specific knowledge or expertise is that which relatesfunctions and administration. to the organisation, the process or activity to be audited, or language or culture.Note: for organisations operating more than one operating unit, a single operating unit may be Note 2: a technical expert does not act as an auditor in the defined as an organisation. audit team.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 reduction or elimination, process, product or service changes, efficient use of resources, material, energy substitution, reuse, recovery, recycling, reclamation and treatment. 11
  13. 13. • Legal and other requirements: as one of the three core Principles of ISO 14001 commitments of the environmental policy, your system should be structured to deliver legislative compliance. To The next section explains the five principles on which ISO achieve this, procedures should be established to identify 14001 is based, and analyses each of the elements which and ensure access to relevant laws and regulations and organisations are required to implement. Whilst this guide is other requirements to which your organisation subscribes primarily focused on ISO 14001, many of the elements are that relate to your environmental aspects. You must identify common to other environmental systems and, in particular, how these requirements apply to your environmental aspects. EMAS and BS 8555. The ISO 14001 model follows five basic principles to which • Objectives, targets and programme: with an organisations developing an environmental management understanding of the significant environmental issues and system should subscribe. These include: legal implications of your activities, the next step is to set goals for improvement. These objectives and targets Policy should also consider your environmental policy, your Ensure commitment to the EMS and establish an commitments to the prevention of pollution, compliance environmental policy. with legal and other requirements and continual improvement. They should also take into account views • Environmental policy: the environmental policy acts as the of interested parties (stakeholders) and other business, foundation for the entire EMS and, as such, the structure financial, operational and technical factors. The objectives of the system should be designed to deliver its aspirations. and targets that you set should be measurable where In short, the policy should be a documented statement of practicable. To ensure that policy commitments, objectives how the organisation is committed to the protection of and targets are carried out, realistic and achievable action the environment, prevention of pollution, legislative plans or programmes should be established which include compliance and continual improvement. the means and time frames by which your objectives and targets are to be achieved. Planning Formulate a plan to deliver the environmental policy. Implementation and operation Develop the capabilities and support mechanisms necessary • Environmental aspects: once the policy has been to achieve the policy and objectives, targets and programme. established, your organisation should identify and evaluate the environmental implications of its activities, products • Resources, roles, responsibility and authority: all and services, to allow you to determine their significance management initiatives require an organisational structure and make informed decisions on how they can be - environmental management is no exception. Resources, controlled or improved. You must take into account all roles and responsibilities and authority, relevant to the EMS, the environmental aspects that you can control and those should be defined, documented and communicated in you can influence and take into account planned or new order to facilitate effective environmental management. A developments, or new or modified activities, products and specific management representative should be appointed services. You must document and keep this information by top management. They will ensure that the EMS is up to date and ensure that the significant environmental established, maintained and implemented in accordance aspects are taken into account when you establish and with ISO 14001 and that they report to top management implement your EMS and when you maintain it. on the performance of the EMS for review including recommendations for improvement.12
  14. 14. • Competence, training and awareness: to ensure that the documents, ensuring the location and revision of documents requirements of the policy and the EMS are carried out as and their removal and retention once obsolete. specified, you must ensure that any persons performing tasks for the organisation or even on behalf of it that have • Operational control: you will need to identify and plan those the potential to cause a significant environmental impact operations that are associated with your significant aspects (in are competent. This competence should be based on the line with your policy, objectives and targets they should be appropriate education, training and experience of these planned and managed under specified conditions). You can individuals. You need to keep records so that you can do this by procedures to control situations, laying down demonstrate this competence. You need to identify operating criteria and having procedures related to your training needs and establish an appropriate training significant aspects and communicating them to suppliers and programme and keep records of training that has been contractors. performed. You need to make sure that people working for or on behalf of your organisation are aware of: • Emergency preparedness and response: despite best-laid plans, accidents and emergency situations can still occur. • the importance of the environmental policy and To prevent and mitigate the environmental implications the requirements of the EMS, of such situations, procedures should be established to identify and respond to accident and emergency situations. • the significant aspects and the potential impacts These must be periodically reviewed and tested. associated with what they do and the benefits of improving their performance, Checking Monitoring and measuring environmental performance. • the part they play in meeting conformity with the EMS, • Monitoring and measurement: to check the effectiveness of the system and to ensure that it is still on track you should • the potential consequences of them departing monitor and measure key activities that have significant impacts from the procedures associated with the EMS. upon the environment. You also need to ensure that any equipment that you use is calibrated and retain records to• Communication: procedures should be established to demonstrate this. record and respond to internal and external communications on environmental issues. • Evaluation of compliance: you must periodically review compliance with legislation and other requirements to• Documentation: standard and consistent application of the which your organisation subscribes. This is to ensure that system must be applied. This should be achieved through the you are consistent with your commitment to compliance. establishment and maintenance of information describing the You need to establish a procedure to do this for both core elements of the system and their interaction and legal requirements and other requirements to which provide direction to other related documents. you subscribe and keep records of the results of these periodic evaluations.• Control of documents: all documents required by the EMS need to be controlled. A procedure should be established to • Non-conformity, corrective and preventive action: ensure that all documents within the system are effectively a procedure should be established, implemented managed. This should include requirements for approving and maintained for taking corrective and preventive documents before they are issued, reviewing and updating action. You need to identify and correct the non-conformity 13
  15. 15. at the earliest opportunity, investigate and determine their cause and take action to prevent the problem recurring. Initial Environmental • Control of records: records should be kept to provide Review evidence that the system is working satisfactorily. Such records should be legible, identifiable and traceable to the Introduction activity involved. There should also be a procedure for the Although it is not a mandatory requirement of ISO 14001, identification, storage, production, retrieval, retention and many organisations find it useful to undertake an Initial disposal of these records. environmental review before they develop their system. This review is often presented in the form of a written • Internal audit: once the system is in place, it is vital report, which examines a broad spectrum of environmental to ensure that the theoretical intentions of procedures performance criteria and sets out recommendations for and instructions are being implemented in practice. improvement. ISO14004 gives guidance on the potential To do this, regular and systematic audits should be issues to be addressed and indicates that it could provide a conducted to verify that your EMS is operating as intended. good foundation for the development of an environmental An audit programme needs to be set and followed. Auditors policy and EMS. that perform this task must be objective and impartial. It must be remembered, however, that this review is a Management Review one off “snap-shot” of your environmental performance. Review and continually improve the EMS with the objective of Later on in the implementation programme, you will improving its overall environmental performance. undertake a more systematic and detailed assessment of your company’s environmental performance and legislative • Management review: at regular intervals, your management compliance, which will be continuously reviewed and team should review the EMS to assess its continuing suitability, updated as circumstances change. adequacy and effectiveness. This will allow them to address possible changes to the policy, objectives and targets, and the The initial environmental review does however, provide a EMS as a whole, in light of changing circumstances and the good starting point for a strategic review of your company’s commitment to continual improvement. Certain inputs should environmental performance and attitudes toward be made to this review process including (but not limited to) environmental issues. The report can also act as a results of internal audits, evaluation of legal compliance, benchmark. So in the future you will be able to look back communications from interested parties, environmental and know how far you have progressed. performance and corrective and preventive actions. ISO14004 suggests the following criteria can be used in In essence, the EMS should be viewed as a basic management the initial review to assess the current environmental framework, which enables companies to coordinate and drive performance: environmental improvements. It should be continually monitored and reviewed to ensure that it is responsive to • identification of applicable legal requirements and other internal and external environmental factors affecting the requirements to which the organisation subscribes, company, (e.g. changes in legislation). Each person in the organisation should be aware of their role within the EMS and • identification of environmental aspects, including those accept personal responsibility for environmental improvements associated with normal operating conditions, abnormal and conformances with the policy and procedures. conditions including start-up and shut down, and14
  16. 16. emergency situations and accidents: o noise, o energy management, • this should include all of your activities, products and o emergency impacts. services so as to determine those that have or may • Site plan, have significant environmental impacts and liabilities. • Site drainage, • Any environmental history:• examination of existing environmental management o previous contaminative uses, practices and procedures, including those associated with o previous incidents, procurement and contracting activities, o previous breaches of environmental laws. • Views of interested parties:• evaluation of previous emergency situations and accidents. o regulators, o public,The review can also include additional considerations, such as: o customers, o suppliers.• an evaluation of performance compared with applicable • Other activities that may enable or impede environmental internal criteria, external standards, regulations, codes of protection or performance, practice and sets of principles and guidelines, • Previous complaints.• opportunities for competitive advantage, including cost Whom reduction opportunities, Some ideas of whom may be involved in the initial review are as follows:• the views of interested parties, and, • those working for the organisation that are to be involved• other organisational systems that can enable or impede in the EMS, environmental performance. o operations manager, o environmental/H & S manager,Any evidence collected should be objective. o supervisors, o other staff in key areas where their actions mayWhat to Consider have an impact, e.g. production.The following are some of the areas that organisations chose • Key information providers such as maintenance consider during their environmental initial review. This listis by no means exhaustive. How to conduct the initial review The following methods might be used to conduct your initial• Main activities, products and services at the site. review:• Identify potential aspects and impacts: o emissions to air, • interviews, o releases to water, • evaluation of internal and external communications, o land, complaints, etc, o waste management, • gathering information, o raw materials and natural resources, o checklists for each operation identify: o planning conditions, • emissions, o visual impact, • resources, 15
  17. 17. • personnel, businesses understand their environmental obligations), • existing procedures, • water and sewerage undertakers – drainage, • level of training and competence, • trade or industry associations, o Eco-maps: • larger client organisations, • baseline assessment, • manufacturers of equipment in use, • what is the problem? • professional help can also be sought from environmental • what is the quality of the data? consultancy firms. • what is the source of the data? • what are the facts, figures and environmental Summary indicators? A good initial review is a strong foundation for a good EMS, • what are the timeframes and targets? it gets people involved in the process and be thorough in • possible action and who should take it? what you do. Use checklists and eco-maps to make records o process flowcharts, but, ensure that you only collate useful information. o site walkabout: Remember, this will be the baseline for establishing your • familiarity with aspects and impacts, EMS. • housekeeping, • identify relevant operations, Further guidance is available in ISO 14004:2004. o inspection. Typical outputs The initial review should be recorded and reviewed. By documenting this process it can be used as a baseline for future reference and can be used to help to plan implementation 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 help Smaller organisations may also be able to consult a number of 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 set up by the UKs environmental regulators to help small16
  18. 18. Environmental management system elementsAs discussed earlier, ISO 14001 is based on the ‘Plan, Do, Clause 4.1 - General requirementsCheck, Act’ pioneered by the American quality expertW. Edwards Deming in the 1950s. This simple, but effective,structure is still used today to ensure that the environmental Introductionaspects and impacts within the organisation are systematicallyidentified, assessed, controlled and monitored and that they This is the standard’s intention, this clause establishes theare continually improved. basic commitment of the organisation to document and sustain an environmental management system. The system must include a clearly mapped out organisational structure and documentation covering planning activities, responsibilities, practices, procedures and processes for achieving the requirements of the standard. Resources must also be provided for developing, implementing achieving, reviewing and maintaining the environmental policy. Continual improvement ISO 14001 requirements The organisation shall establish, document, implement, maintain and continually improve an environmental Environmental management system in accordance with the Management policy review requirements of this International Standard and determine how it will fulfil these requirements. Planning The organisation shall define and document the scope of Checking Implementation its environmental management system. and operation Interpretation You need to evaluate and document how your EMS fulfils the requirements of ISO 14001. This could be done as part of the internal audit or as part of the management review. Either way, this must be traceable and demonstrate how you meet the requirements. Environmental management system model (Source BS EN ISO 14001:2004) 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 will define your EMS and what activities, operations, services and products are within it. 17
  19. 19. You must document your scope; one way of doing this is to include it in your environmental policy. c) includes a commitment to comply with applicable legal requirements and with other requirements to If you are going to seek registration of your ISO 14001 which the organisation subscribes which relate to its system with an accredited certification body, such as NQA, environmental aspects, then your scope must agree with accreditation rules. This means that you cannot ‘ring fence’ the scope of your EMS d) provides a framework for setting and reviewing to exclude difficult areas or areas that are part of your site. environmental objectives and targets, 4.2 Environmental policy e) is documented, implemented and maintained, Introduction f) is communicated to all persons working for or on behalf of the organisation, and Having decided to develop an environmental management system, the next most critical step is to set out what you g) is available to the public. wish it to deliver. Establishing an environmental policy can simply and effectively state these aspirations and, moreover, Interpretation communicate such commitments to your stakeholders. This is especially important for many smaller organisations as they In most management systems it is often the responsibility are under increasing pressure from major clients to develop of the top management team to produce a policy. This is also ISO 14001. Sending this policy to customers can form part of true for ISO 14001, and requires companies to define an a marketing strategy and also assure clients that you have environmental policy that is appropriate to the nature and embarked upon the road to ISO 14001 certification. scale of its operations. An environmental policy should act as your management’s The environmental policy should be developed and signed by declaration that environmental protection is a priority. It the top management of your organisation. It is also a good should also serve as a unifying vision showing environmental idea for other senior managers to sign it, as their support will concern by the entire company. As such, the policy is be essential to the effectiveness of the EMS. Without this probably the most important document in the entire system. visible declaration, it is unlikely that the rest of the company will give any credence to the system. ISO 14001 requirements The policy should be consistent with the scope of the EMS Top management shall define the organisation’s and not imply a wider or indeed a narrower or different environmental policy and ensure that, within the defined scope than this. It must also cover all of the activities, scope of its environmental management system, it; products and services within that scope. a) is appropriate to the nature, scale and environmental Your policy should contain three core commitments, impacts of its activities, products and services, including a commitment to continual improvement. This doesn’t mean that you must improve in all areas at once, but b) includes a commitment to continual improvement that the policy should drive your overall efforts to continually and prevention of pollution, improve your organisation’s environmental performance.18
  20. 20. Since it serves as the framework for your EMS, it is workers. As well as communicating internally, the policyworthwhile considering the structure and content of the should also be made available to members of the public andpolicy. The statement should be more than just flowing prose other interested parties (stakeholders). This does not meanand golden platitudes. Instead, it should set out clear that you have to actively send out copies of your policy,commitments and act as a springboard when setting although some organisations may choose to do so. However,environmental objectives and targets. In short, your policy if you receive an inquiry from an interested party then youmust be brought to life in your plans and actions. should be able to provide a copy.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 workingfor or on behalf of the organisation. This should includecontractors, subcontractors, temporary staff and remote The 3 Core Policy Commitments of ISO 14001 Definitions Continual improvement Recurring process of enhancing the environmental management system in order to achieve improvements in overall environmental performance consistent with the organisation’s environmental policy. (ISO 14001:2004) Prevention of pollution Use of processes, practice, techniques, products, services or energy to avoid, reduce or control (separately or in combination) the creation, emission or discharge of any type of pollutant or waste, in order to reduce adverse environmental impacts. (ISO 14001:2004) Legal compliance 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 your environmental aspects, not just ‘environmental’ requirements, you will need to consider other requirements such as safety regulations that may relate to your environmental aspects. 19
  21. 21. Hints for implementation At this stage, it is best to collate all the ideas presented at the meeting, possibly on a flip chart. Don’t worry about the Most organisations have some form of environmental policy, exact wording of the policy yet, this will come later when you even if it is not in a written form. For example, it is likely that review and draft out the policy. your company is committed to understanding and complying with all applicable legislation. In addition, most wish to avoid It is important to keep your policy simple and understandable damage to the environment. However, only a few so try to answer the following questions during the brain organisations have actually established a written policy. storming session: Your first step when developing the policy should be to • what are we trying to achieve through the environmental establish what principles or commitments to which your management system? organisation currently subscribes. This can best be achieved by gathering a team together and brainstorming ideas. • what adverse environmental impacts do we want to Consider carefully who to invite onto this team. Input from a address? wide range of people in your company, including management should increase commitment and ownership. • what positive environmental attributes do we wish to promote in the policy? Communicating the Policy Commitments of ISO 14001 Internally Externally • Posting it around the site on notice boards and in • Sales and marketing literature. reception. • Business cards. • Letters, memos. • Newspaper advertisements. • Including it with paycheques. • Annual reports. • Training sessions especially induction training for new staff and contractors. • Public library. • Staff meetings or briefings. • Local community meetings and open days. • Intranet web pages/e-mail. • Visitor badges. • Staff magazines. • Internet web pages/e-mail. • With visitors’ book for temporary staff and • External site notice boards. contractors.20
  22. 22. • who do we wish to proactively communicate with, commandments set in stone. regarding our environmental policy? Common non-conformities• how can we best communicate the policy to our selected audience? Some of the most common non-conformities found during the certification process include:• how can we best communicate the policy within the company? • the policy is not developed by “top management”,• will we do what we said we would? • the use of a corporate policy where a site policy is more appropriate,• shall we develop a stand-alone document or integrate it with health and safety, quality, or other company policies? • the policy is not consistent with the scope,• how will we review the implementation of our • commitment to continual improvement and prevention of environmental commitments? pollution is not clearly defined or missed out altogether,Once you have answered all of these questions, sketch out a • there is no commitment to compliance with applicabledraft statement, taking into consideration the requirements legal requirements,of the standard. Try to keep it clear, concise and above allunderstandable, and if possible keep it to one side of A4-size • no mechanisms for revising policy,writing paper. • the systems records do not support policy commitments,Next, circulate the draft statement among the developmentteam to ensure they are happy with the wording and the • communication with persons working on behalf of thecommitments given. You need to ensure that your top organisation is inadequate or not carried out, particularlymanager or management team sign the document and are in relation to contractors and subcontractors.committed to implement its aspirations. Self-assessment questionsRemember, your policy should be appropriate to theenvironmental implications of your activities, products and • Have you developed a written policy statement?services. So it is worthwhile reviewing the policy after youhave completed a more detailed evaluation of your • Is it appropriate to the nature and scale of yourenvironmental aspects which is described in later sections. operations?Your policy may also need to be modified later following the • Does it address the three key policy commitments?Management Review. As your organisation and itsenvironmental performance changes, so too, will your policy. • Has it been effectively communicated internally andThe policy should be seen as a living document which drives externally?the system and grows with it as it matures and not as a set of 21
  23. 23. 4.3 Planning ISO 14001 requirements The organisation shall establish, implement and maintain 4.3.1 Environmental aspects a procedure(s) a) to identify the environmental aspects of its activities, Introduction products and services within the defined scope of the environmental management system that it can control Before you set about improving environmental performance, and those that it can influence taking into account you must firstly ask yourself the following questions: planned or new developments, or new or modified “What do we need to do?” activities, products and services, and, “What do we need to do first?” b) to determine those aspects that have or could have At this stage of the project it will not be easy to answer significant impact(s) on the environment (i.e. significant these questions, but it does help to illustrate the importance environmental aspects). of evaluating your environmental performance and prioritising your actions so that the most important issues are The organisation shall document this information and tackled first. This is especially true if you have limited financial keep it up to date. and human resources. The organisation shall ensure that the significant Evaluating how your organisation interacts with the environmental aspects are taken into account in environment forms the first step in the planning of your EMS. establishing, implementing and maintaining its It allows you to identify, evaluate and understand how your environmental management system. activities or elements of your activities (aspects) effect the environment. In addition, it allows you to use this information to make informed decisions on the most important or Interpretation significant issues, so that you can focus resources toward controlling and improving them. One of the most fundamental requirements of ISO 14001 is the establishment of a documented procedure for identifying Identifying significant environmental aspects is therefore one the environmental implications of the activities, products, of the most critical elements of the EMS, but it can be one of processes and services of your organisation. the most challenging. Decisions you make in this area can affect many other system elements (such as setting objectives The elements of your organisations activities, products, and targets, establishing operational controls, and defining processes and services that can interact with the monitoring needs). Careful planning and conduct of this environment are called “aspects”. Examples of aspects could activity will pay dividends in later stages. be a discharge or an emission or perhaps the consumption of a material. The term “aspects” includes those components of activities that “cause” environmental impacts (such as the discharge of hazardous materials into a stream).22
  24. 24. “Impacts” are the change or alteration in the environment as The distinction between aspects and impacts has beena consequence of particular environmental aspects (for created to allow managers to focus their attention andexample, fish killed as a result of the discharge). Impacts can resources toward controlling and managing thosealso be beneficial to the environment such as improved elements of their activities that create the impact in thewater quality as a result of a treatment process. first place. Examples of Relationships between Aspects and Impacts Aspects Potential impacts Emissions to Site run-off, spillage of oils, Deterioration of water quality; water/sewer chemicals, etc. Potential contamination of surface/foul water drainage systems and controlled waters; degradation of aquatic habitat and drinking water supply. Emissions to Fumes and emissions from Deterioration of air quality. atmosphere paint spraying, vehicles, Negative impact on local air quality, climate manufacturing processes, etc. change, low-level ozone depletion. Waste Hazardous and non- Inadvertent disposal could result in pollution generation hazardous waste from of soil and controlled waters, and inadequate production activities; paper, containment/storage could lead to nuisance wood metals, empty and odour problems. containers, etc. Where waste is sent to landfill, this could lead to leachate polluting land and water courses, resource depletion. Electricity use Resource depletion. Air pollution, climate change. Use of re- cycled paper Conservation of natural resources. 23
  25. 25. In theory, the potential environmental impacts arising from that you document these considerations. These should then your aspects could go on forever. It would be unreasonable, be fed into your system. however, to expect businesses to address them all, especially where they have no control over the aspect. To overcome Hints for implementation this, the standard gives organisations an amount of leeway to draw the boundary of their EMS around those aspects Identifying and evaluating your environmental aspects may over which it may have control and those it can have an seem like an enormous task. Nevertheless, if you break the influence over. process down into logical steps it can be made much simpler. ISO 14004 gives practical guidance on identifying and Your company will not be expected to manage aspects outside understanding environmental aspects. its sphere of influence. For example, whilst your company probably has control over the quantity of chemicals it uses, it is As an organisation, you should collect both quantitative and unlikely that it can control the way they are manufactured. qualitative data on the characteristics of your activities, products and services. This would include the inputs When evaluating whether or not you can influence the and outputs into your organisation such as materials, aspects associated with an activity, product or a service you energy, the technology that you use, your location and should consider the legal and contractual authority, policies, your facilities. local or regional issues that may have an effect and any obligations or responsibilities that you may have towards Remember to look at all activities, products, processes and interested parties. services of your organisation, not just the must obvious ones. Think about: You should also consider the implications of situations such as the purchase of materials, for example chemicals or products • production activities, containing hazardous materials. • design and development, • procurement, Once you have identified the environmental aspects of • material and waste storage, your activities, products and services, you should determine • research, which aspects could have “significant” impacts on the • packaging, environment. These environmental aspects should be • transport and distribution, considered when setting your environmental objectives • use and end of life, and operational controls. • maintenance, • office activities, It is important that once you have conducted an assessment • warehousing. of your environmental aspects, that this information is kept up-to-date. In particular, the standard refers to new and Whilst the need to examine your on-site operations planned developments, new and modified activities, products might seem obvious, you should also consider the and services. potential impacts of what you do off-site (such as servicing equipment at customer premises). Similarly, the You will need to consider your significant aspects when you environmental aspects of the materials, suppliers, and plan to change activities or develop completely new contractors you use may be less obvious, but should still processes, activities and services. You should also make sure be considered.24
  26. 26. To understand your environmental aspects, it helps to There are many readily available sources of information tounderstand the processes by which you generate products help you perform your assessment. For instance, tradeand services. A flow chart of your major processes might associations, regulatory agencies, your customers andhelp you understand the inputs and outputs of your suppliers might provide useful information to support yourprocesses and how materials are used (see diagram). assessment.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. INPUTS utilities (water, electricity and gas) INPUTS raw materials and natural resources PROCESS Finished Product OUTPUTS OUTPUTS discharges (air, land, water) noise, odour and other community issues 25
  27. 27. Potential Environmental Aspects under Normal Operating Conditions Air Gas emissions (e.g. volatile organic compounds, CO2, SO2, NOx CO, odours, etc.) Particulates (e.g. dusts and smuts) Water Water 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 Use Energy (e.g. consumption of electricity, fuels, gas, oils and coal) Process raw materials Auxiliary materials (e.g. lubricating oils) Packaging materials Water consumption (e.g. extracted water or mains water) Fuels for transport Storage and handling of materials Wastes Hazardous Non-hazardous Storage and handling of wastes Disposal of waste Nuisance Noise Vibration Traffic and parking Visual appearance/house keeping Other Wildlife Biodiversity Cultural heritage (listed building, etc.) Environmental performance and practices of contractors and suppliers26
  28. 28. It is vital to remember that processes do not always interact For each of the environmental aspects you have outlined inwith the environment constantly or continuously or both. the previous step you should identify as many actual andThis is especially true for emergency or accidental conditions potential, positive and negative, environmental impacts aswhere the impact might be acute and severe. It is vital, possible. Also identify the part of the environment that willtherefore, to consider the impacts of operations during be affected and how. For your identified aspects also includenormal and abnormal conditions. Any reasonably foreseeable any direct and indirect impacts.emergency situations must also be considered. Remember to look at the characteristics of the location of your organisation. This might affect the impact of your activities, products and services such as local weather Potential environmental aspects under conditions, the local water table conditions, flooding and the abnormal and emergency conditions soil type of your location(s). Also think about the length of time which these changes may occur, for example, the Abnormal changes in the site after a sustained period of rain may Start-up continue to cause problems such as flooding and excess site run-off even after the rain ceases. Shutdown Part load operations Don’t forget to also look at new or planned developments, Change of product or operation or new or modified activities, products and services. Partial failure The following information would also assist: Maintenance Vandalism • cause and effect relationships that exist between the Visitors (e.g. customers or school parties) different elements of your products, activities and services, Spillages Raw material shortages • potential or actual changes to the environment, Contractor issues • any concerns of stakeholders with respect to the Supplier issues environment, Emergency conditions • aspects identified in regulations and permits, other Loss of power, water or fuel supply standards or by industry associations, etc. Loss of containment After your company has identified the environmental aspects Fire and impacts of its operations, the next step is to evaluate Explosion their environmental significance. This has two objectives; Overload of process firstly, to ensure that the issues that have the greatest impact Storm and other natural disasters on the environment are clearly prioritised and addressed: secondly, it enables you to identify and evaluate current control mechanisms and decide what further steps may be needed to deal with the significant aspects. 27