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Strategic EnvironmentalManagement

Continual Improvement

GAP ANALYSIS – MGMT COMMITMENT – DEFINE PROGRAM INTENT

ASPECTS – IMPACTS – REGULATORY ISSUES – INTERNAL PERF. CRITERIA – ENV. MGMGT. PROGRAM

RESPONSIBILITY/ACCOUNTABILITY – STAFF, PHYSICAL & $ CAPABILITIES – EMS INTEGRATION

OPERATIONAL CONTROL – COMMUNICATION/REPORTING/DOCUMENTATION – PERFORMANCE INDICES

PROBLEM REPORTS – MANAGEMENT REVIEW – PROBLEM RESOLUTION

PROCESS IMPROVEMENTS – COST SAVINGS – ENHANCED IMAGE

YOUR ORGANIZATION ISO 14001 Guidance ManualPlanning

Checking and Corrective

Action

Management Review

Implementation and OperationEnvironmental

Policy

i 10 March, 1998

Table of Contents

ABOUT THE AUTHOR ......................................................................................................................... V

INTRODUCTION....................................................................................................................................6

PURPOSE AND USE OF THIS MANUAL .........................................................................................................6WHO SHOULD READ THIS MANUAL .............................................................................................................6ORGANIZATION OF THIS MANUAL ................................................................................................................8ISO 14001 OVERVIEW .............................................................................................................................8PROGRAM INTENT.....................................................................................................................................9INTEGRATION WITH EXISTING PROCEDURES ...............................................................................................10WHAT PART OF YOUR OPERATION IS COVERED? .......................................................................................11HOW TO USE THIS MANUAL ......................................................................................................................13

INITIAL REVIEW OR GAP ANALYSIS ................................................................................................15

DESCRIPTION AND PURPOSE ...................................................................................................................15PROCEDURE ..........................................................................................................................................15TIPS ......................................................................................................................................................17

ENVIRONMENTAL POLICY DEVELOPMENT ....................................................................................18

ISO 14001 4.2 ENVIRONMENTAL POLICY.................................................................................................18DESCRIPTION .........................................................................................................................................18PURPOSE...............................................................................................................................................19PROCEDURE ..........................................................................................................................................20TIPS ......................................................................................................................................................20MORE POLICY TIPS .................................................................................................................................21

ENVIRONMENTAL ASPECTS.............................................................................................................22

ISO 14001 4.3.1 ENVIRONMENTAL ASPECTS ...........................................................................................22DESCRIPTION .........................................................................................................................................22PURPOSE...............................................................................................................................................24PROCEDURE TO IDENTIFY ASPECTS ..........................................................................................................24ASPECTS TIPS........................................................................................................................................25LEGAL AND OTHER REQUIREMENTS ..........................................................................................................28ISO 14001 4.3.2 LEGAL AND OTHER REQUIREMENTS ...............................................................................28DESCRIPTION .........................................................................................................................................28PURPOSE...............................................................................................................................................28SETTING THE LEGAL FRAMEWORK FOR YOUR EMS ...................................................................................28TIPS ......................................................................................................................................................29

OBJECTIVES AND TARGETS ............................................................................................................30

ISO 14001 4.3.3 ...................................................................................................................................30DESCRIPTION .........................................................................................................................................30PURPOSE...............................................................................................................................................31



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PROCEDURE ..........................................................................................................................................31TIPS ......................................................................................................................................................34

ENVIRONMENTAL MANAGEMENT PROGRAM(S)............................................................................36

ISO 14001 4.3.4 ...................................................................................................................................36DESCRIPTION .........................................................................................................................................36PURPOSE...............................................................................................................................................37PROCEDURE ..........................................................................................................................................37TIPS ......................................................................................................................................................38

STRUCTURE AND RESPONSIBILITY ................................................................................................39

STRUCTURE AND RESPONSIBILITY ............................................................................................................39DESCRIPTION .........................................................................................................................................39PURPOSE...............................................................................................................................................40PROCEDURE ..........................................................................................................................................40TIPS ......................................................................................................................................................45

TRAINING, AWARENESS AND COMPETENCE .................................................................................47


COMMUNICATION ..............................................................................................................................52

ISO 14001 4.4.3 ...................................................................................................................................52DESCRIPTION .........................................................................................................................................52PURPOSE...............................................................................................................................................53OPENING THE INFORMATION LINES ...........................................................................................................53PROCEDURE ..........................................................................................................................................53TIPS ......................................................................................................................................................57

ENVIRONMENTAL MANAGEMENT SYSTEM DOCUMENTATION ....................................................58


DOCUMENT CONTROL......................................................................................................................61

ISO 14001 4.4.5 ...................................................................................................................................61DESCRIPTION .........................................................................................................................................61PURPOSE...............................................................................................................................................61PROCEDURE ..........................................................................................................................................62

OPERATIONAL CONTROL.................................................................................................................63



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EMERGENCY PREPAREDNESS AND RESPONSE ...........................................................................69


MONITORING AND MEASUREMENT.................................................................................................71


TIPS ..............................................................................................................................................73

NONCONFORMANCE AND CORRECTIVE AND PREVENTIVE ACTION ..........................................74


RECORDS ...........................................................................................................................................78


ENVIRONMENTAL MANAGEMENT SYSTEM AUDIT.........................................................................81


MANAGEMENT REVIEW ....................................................................................................................85


IMPLEMENTATION.............................................................................................................................89



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INTEGRATION .........................................................................................................................................90

THE REGISTRATION PROCESS........................................................................................................93

WHAT GETS REGISTERED?......................................................................................................................93“ACCREDITATION”, “CERTIFICATION”, AND “REGISTRATION”.......................................................................93REGISTRARS AND REGISTRATION.............................................................................................................94SELF CERTIFICATION /SELF DECLARATION ................................................................................................95.................................................................................................................................................................



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About the Author

Raymond Martin heads the Environmental Management System Development program for amajor corporation. Dr. Martin brings with him fifteen years of experience in the areas ofenvironmental engineering, chemical manufacturing, regulatory compliance, operations andbusiness management, and law. He has been senior design engineer and senior site safetyand health officer on numerous UMTRA and Superfund sites, as well as many RCRA sites inthe private sector. Dr. Martin received his doctorate in environmental engineering, with a focuson environmental management system development and implementation, and is completinghis MBA. He is actively involved in developing ISO 14001 EMS programs for many of theworld’s largest service and manufacturing organizations including Toyota, Con Edison, PhilipsElectronics and many more. Dr. Martin has developed and implemented landmark EPA modelprograms in project design, and has taught practices and procedures at the University ofArizona College of Law.

Dr. Martin is a member of the American Society for Testing and Materials (ASTM) TechnicalAdvisory Group to ISO. As such, he has participated in the development of the ISO 14000EMS standards. He is also the ISO 14000 Technical Director for the Certification Board ofNQA, one of the world’s largest ISO Registrars. His in-depth knowledge as a result of theseprofessional relationships makes him one of the premier program developers and auditors inthe industry.

Dr. Martin has published extensively on ISO 14000 and many other environmentalmanagement issues in books and professional journals, focusing on systems design,implementation and decision-making criteria. That exposure allowed him to be selected by theNational Center for Environmental Decision-making Research to write this ISO 14000Guidance Manual.

Dr. Martin has recently given presentations on ISO 14001 and other environmentalmanagement issues at the World Environmental Congress, the University of Tennessee, OakRidge National Laboratory, the Environmental Auditing Roundtable, and MIT’s Technologyand Policy Program. Dr. Martin was selected to develop a survey and chair a conferenceconcerning EPA’s Self Policing Policy where EPA, in an historic move, requested input fromthe private sector on the direction of their implementation of the Policy.

Dr. Martin can be reached at (212) 460-4983; 504 Tallwoods Ln., Greenbrook, NJ 08812



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Introduction

Purpose and Use of This Manual

This manual has been developed and organized to assist allinterested organizations in the development of anEnvironmental Management System (EMS) that is consistentwith the ISO 14001 Standard, achieves EMS Registration, andimproves the overall environmental performance of theorganization. Because each organization is different, NCEDRhas tried to create a document that is specific enough to givethe tools needed to set up and implement an EMS, but generalenough to allow the flexibility for addressing uniquecharacteristics.

The various sections of the manual describe each element ofthe ISO 14001 standard and provide step-by-step procedures,sample documents or templates, and tips for developing andimplementing an EMS that is appropriate to the organizationand its operations. Please remember that this is a guidancedocument and not a rigid instruction manual. All of the ISOelements must be addressed in your program and meet theISO requirements, but you will notice there is much flexibilityallowed in meeting the requirements. There are someprocedures that should be followed “to the letter”. Theseprocedures should be self evident, but for your convenience,each one of these pertinent procedures will be identifiedappropriately.

Who Should Read This Manual

Internal EMS program developers should use this manual. It isdesigned to supply guidance regarding the intent of an ISO14001 EMS. The form and procedural contents of the EMS arevery specific, and any attempt to generalize those items wouldlead to an EMS that will not effectively “fit” the organization.

If the basic form the EMS should have is questioned, yourorganization may need support to effectively generate andimplement an EMS. Please utilize this document as tool and aresource in developing your EMS, but seek expert advice asnecessary. The development of an ISO 14001 EMS is acomplex and critical process.

Management Representative

External Assistance

Internal Solution

PLANT ACTION TEAM

External Consultant

Guideline

Reviews

Checklists

Helpdesk

Information

Records

Priorities

Action Plan

Plant Environmental Coordinator

Problem Owners

Plant Quality Manager

Tailor-Made Solutions



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Organization of this Manual

Planning


Action

Management Review


Policy

Most environmental management systems are built on the“Plan, Do, Check, Act” model. In the ISO 14001 EMSStandard, these steps have been expanded to encompassseventeen elements. These seventeen elements are groupedinto five phases that are similar to “plan, do, check, act”. Thephases are called Environmental Policy, Planning,Implementation and Operation, Checking and CorrectiveAction, and Management Review.

This manual is organized in the same manner as the ISO14001 program elements. For each element of ISO 14001 youwill find the text of the actual ISO 14001 standard, step-by-step procedures, tips for developing and implementing theEMS; and sample documents or templates that can be used asis or customized to the organization.

The diagram at left will be used throughout this manual to helpyou identify the phase being discussed. Look for thehighlighted phase at the top of each page.

ISO 14001 Overview

Following is an outline of the ISO 14001 EMS Standard:

Scope

Normative references

Definitions

Environmental Management System Requirements

General Requirements

Environmental Policy

Planning

Environmental aspects

Legal and other requirements

Objectives and targets

Environmental management program(s)

Implementation and Operation



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Structure and responsibility

Training, awareness and competence

Communication

Environmental management system documentation

Document control

Operational control

Emergency preparedness and response

Checking and corrective action

Monitoring and measurement

Nonconformance and corrective and preventive action

Records

Environmental management system audit

Management Review

Program Intent

The intent of an ISO 14001 environmental management system (EMS) is to develop asystematic management approach to the environmental concerns of the organization. Theexpected outcome of this approach is continual improvement in environmental management.

By setting an environmental policy, then making the environmental concerns of the firm clear(Aspects) and defining what will be done to control them (Objectives and Targets), planning isaccomplished. Then, by establishing organizational structure, personnel responsibilities,competency and training, implementation begins. Communication practices, documentationcontrol and procedural documents, operational control and emergency preparedness definethe operation portion of the program. These items are usually included in an EMS Manual,which documents a program to accomplish the Objectives and Targets set above. Theorganization’s methods for measuring and monitoring its environmental impacts is alsoincluded in the Manual, along with practices for identifying nonconformance and forimplementing corrective and preventive actions. These, along with routine systems audits andrecord keeping constitute the EMS checking and corrective action program. And finally, theprogram has a routine management review of its activities. The words in bold above describethe general sections of an ISO 14001 EMS.



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Integration with Existing procedures

Much of what an organization must do in an ISO 14001 EMS is probably already being done.No organization can operate without some environmental programs in place. These programsmay need modification to comply with the ISO 14001 standard, but they serve as a goodstarting point to begin construction of an ISO compliant EMS. In fact, a good way to look atyour EMS Manual is to view it as a road map. It will tell people where to find programs theorganization uses to handle environmental concerns such as: wastewater systems operationalmanuals, air permit operating requirements, hazardous wastes handling procedures, materialspurchasing requirements, and so forth.

A well-conceived ISO 14001 EMS will use existing environmental programs and proceduresas a foundation. It will also include the business management practices of the companywherever possible. An example of this would be tying environmental impacts of raw materialspurchases into an existing procedure to review raw materials specifications for engineeringrequirements and consistency. Many firms already have such procedures in place.

Other types of program integration may include integrating cost accounting practices withenvironmental operational practices. Many organizations cannot actually determine wheretheir environmental dollars go. As a result, they cannot identify opportunities for financialimprovement in environmental practices. Without such information, the environmentalmanagement of an organization is difficult. If management cannot see any cost benefit inenvironmental decision making, the managers usually take the least costly option. Activity-based costing allows a more comprehensive understanding of how environmental expensesare accrued by process and product rather than by facility or region. Then process control andproduct design can be reviewed to see if costs associated with their environmental impactscan be minimized. This is a good example of what ISO 14001 hopes to accomplish--goodfinancial management leading to better environmental control.



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What Part of Your Operation is Covered?

Many facilities have multiple operating units at one location. It is not uncommon to have aresearch and development office at a production facility. The production facility may want toachieve ISO 14001 conformance, but not the R&D offices. As long as an auditor can clearlysee the separation of these two activities, both physically and administratively, there shouldbe little cause for concern.

The example above can be used to illustrate another point. If a large manufacturing facilityhad an R&D office on-site, there might be two distinct functional units that share physicalresources but are separate cost centers. In some cases, units will actually pay each other foroffice space, utilities and janitorial service although they are part of the same corporation. Inthis case, separation for purposes of ISO 14001 program development and implementation isnot difficult. Activities should be separate enough, however, to be clear to an outsider. If R&Dengineers are constantly venturing out onto the production line and making changes inpractices and procedures, it may appear to an auditor that they are a portion of theoperational group for the facility. Separation of functional groups might be harder to argue.

An example of separation that may NOT be acceptable is separation of the purchasingfunction from the rest of an operation. Since purchasing is tied at almost every managementlevel in an operation, this would seem unreasonable to most auditors, and could generate aconcern in evaluating an ISO 14001 EMS program.

The EMS-Pyramid-

1

3

4

GAP ANALYSIS Management Commitment

4.1 Environmental Policy

4.3.6: Operational Control

4.5: Management Reviews

4.4.4: System Audits

4.4.3: Management Records

4.4.2: Non-Compliance

4.4.1: Monitoring & Measuring

4.3.5: Document Control

4.3.4: Manual & Documentation

4.3.2: Training & Awareness

4.3.1: Structure & Responsibility

4.2.1: Environmental

Aspects

4.2..4: Environmental

Program

4.2.3: Targets

& Objectives

4.2.2: Legal Etc.

Requirements

5

2

Initial Review



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How to use this Manual

This Guidance Manual is designed for the development of an ISO 14001 environmentalmanagement system. The outline of the Manual is in the order that it should be used. Theintroduction and scope should be read first. Sections are designed to follow the actual ISO14001 Standard in layout. The process begins with an Initial review (not required by thestandard, but essential for program development) and then embraces Policy, Aspects,Objectives and Targets, etc… in the order they appear in ISO 14001.

Each section has the same format:

• The subclause of the ISO 14001 Standard is quoted word for word. This should bereviewed to make sure the user understands Standard expectations.

• Definition: This section describes what the subclause of ISO really means.• Purpose: This section describes what the subclause of ISO hopes to achieve in the

program.• Procedure: This section describes how you should build your program to comply with the

subclause, what things you should consider, and how you will integrate the proceduresinto what you already do.

• Tips: Tips are just that… tips on things you should think about in reference to this sectionand reminders about what types of line items need to be included in the procedure anddocumentation.

This manual has been written by experienced ISO 14001 program developers. Take the timeto read an entire section, and then think it over before you write. It is recommended that youread a section over one day, and spend some time thinking about before writing the next. Forsome sections, such as operational control, it may take many days to generate the documentsand implement the practices. You may want to review the Manual section on operationalcontrol every few days during that phase to remind yourself of what you are trying toaccomplish.

Reminder: This is a complex process. Once you have gone through the exercise of definingyour environmental aspects and impacts and how you will manage them, you will recognizeopportunities not visible previously, and be able to modify practices to better fit the overallcontext of your operation. By rushing through the developmental process, you will havemissed these opportunities which are the core of ISO 14001. Make sure you spend timethinking about each section before proceeding.

Project Course:-Environmental Management System

Effective Change Procedure

Steps According to PrioritiesMonitoring

PHASE I: Management Commitment

PHASE II : Initial Review (Gap Analysis)

PHASE III : Improvement Plan (in steps)

Policy

Planning

Implementation

Review

External Audit & Certification

ENV. MGMT. MANUAL:

Departmental Approach

EMS Audit

Management Review

PHASE IV: Implementation

Monitoring

2

3

4

2

1

3

4

5

5

PHASE V:



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Initial Review or Gap Analysis

Description and Purpose

A fundamental concept of the ISO 14001 EMS Standard iscontinual improvement of environmental performance. Beforeyou can plan for improvement, you must first determine thecurrent state of the organization's environmental programs.

The initial review or gap analysis is, in itself, a microcosm of awell-organized approach to the entire ISO 14001 EMSdevelopment process. Each specification of the standard mustbe reviewed, including policy, legal requirements, training,objectives and targets, operational control systems, documentcontrol, auditing, management review, and corrective action.

The review should take into account the culture, products,marketing strategies, and other specifics of the organization. Inall cases, consideration should be given to the full range ofoperating conditions, including possible incidents andemergency situations that may be encountered.

The ability of suppliers and subcontractors to comply with theOrganization’s EMS program and applicable regulatoryrequirements should also be evaluated. It is stronglyrecommended that the initial review consider energy use,financial accounting, and information systems so that theseissues may be integrated into the EMS program.

Procedure To effectively begin the Initial Review, several things musthappen. First, Management should issue a company-wideannouncement of intent and endorsement. This should includeestimates of the time required to complete the Initial Review,and time required to complete the entire project. Second, theproject leader should be identified and vested with ampleauthority for completion of the project.

The Initial Review is a review of all pertinent documents, fromwhich an accurate plan is designed for the EMS Gap Analysis.All information from the review, including deviation fromregulatory requirements and adverse impacts on theenvironment, should be identified along with policies,programs, procedures, training and work instructions, and



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operational controls.

A portion of the project team should begin to assemble aregistry of appropriate regulations identified during the InitialReview. All pertinent national, state, local and self-subscribedrequirements should be assembled. They should be comparedwith identified environmental impacts.

An Initial Review is also important in ensuring that EMS designis compatible with all current organizational managementstructures and operations wherever possible. This is especiallyimportant where the EMS interfaces with the site's existinghealth and safety, accounting, computer systems, purchasing,energy utilization and other management programs. The focuswill be to achieve operational efficiencies that ensureenvironmental improvements and maximize cost reductions.Initial Review outputs will be:

• An EMS Gap Analysis Design that details where existingenvironmental management procedures must be furtherinvestigated to determine conformance with the Standard.

• A review of the site's overall environmental managementstrengths/weaknesses.

• A schedule of events for the Gap Analysis.

Gap Analysis

The gap analysis allows for a quick but comprehensiveassessment of the facility’s existing environmentalmanagement practices and procedures, and compares themwith the requirements of the Standard. To perform the GapAnalysis, a standard template tailored for that specific purposeis used. The template is a questionnaire with a three wayscoring system, which develops a final rating of the currentprograms of the site as they compare with the sections of theStandard. The score from this questionnaire and investigativetemplate identifies which areas of the EMS might be enhancedto improve environmental performance and comply with theStandard.

Based on the results of the Gap Analysis, the project schedule



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and design may require modifications. Modification shouldprecede further systems development. Using the results of theGap Analysis, the EMS developmental process can now begin.This may involve modifying existing procedures, adaptingother business procedures such as those designed for healthand safety, accounting, or risk management to environmentalutilization. At certain points, new procedures will be required.

Prior to embarking on EMS development, always rememberthat the more flexible your EMS is, the easier it will be toimplement and the more flexible it will be in the future.

Tips Ø The following can be sources of valuable information:

• Equipment manufacturers

• Suppliers and vendors such as waste disposalcompanies

• Government agencies

• Databases

• Community/Civic groups

• Environmental advocacy groups

Remember to evaluate current performance against relevantinternal criteria, such as organization practices and guidelinesin addition to external standards and regulations.

Consider benchmarking against other organizations orindustry associations.



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Environmental Policy Development

ISO 14001 4.2Environmental Policy

“Top management shall define the organization’senvironmental policy and ensure that it:

a) is appropriate to the nature, scale and environmentalimpacts of its activities, products or services;

b) includes a commitment to continual improvement andprevention of pollution;

c) includes a commitment to comply with relevantenvironmental legislation and regulations, and with otherrequirements to which the organization subscribes;

d) provides the framework for setting and reviewingenvironmental objectives and targets;

e) is documented, implemented and maintained andcommunicated to all employees;

f) is available to the public.”

Description The establishment of an Environmental Policy mandated bytop management, and verified by them during ManagementReview, is the first requirement of the Standard. The Policysets the tone for the establishment of EMS principles. ThePolicy directs corporate goals, corporate responsibilities, andthe establishment of corporate performance milestonesagainst which the management system must be judged. Topmanagement is held responsible for the initiation of Policy andfor providing direction for others who may be tasked with thedevelopment of the final Policy itself. The Policy shouldaccount for the following:

• Reflect the moral and ethical basis for the organization’sactions.

• Account for regulatory/self-imposed requirements.



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• Stress commitment to continual improvement.

• Provide coordination to other organizational policies.

• Provide attachments to requirements, internal and external.

• Be germane to the operation’s products and services asthey impact the environment.

• Be clear, concise, and implemented at all levels ofoperations.

• Be publicly available.

• Strive toward prevention of and continual reduction ofadverse environmental effects, thus supporting sustainabledevelopment.

• Set and allow for publication of environmental objectivesand targets, improvement plans and management reviews.

• Satisfy the requirements of concerned third parties such asinsurance companies, banks, shareholders, etc…

• Be updated and checked routinely.

Purpose The Environmental Policy sets the stage for all of the otherelements of the Organization’s Environmental ManagementSystem (EMS). The policy establishes goals for environmentalperformance against which the effectiveness of themanagement system will be judged. It should provide aunifying vision for the organization. Because the policystatement can have a significant impact on the Organization’simage, it should be clear and verifiable.

Remember To:Ø Consider all significant

products/services andactivities in Policydetermination.

Ø Develop a Policy inwriting.

Ø Effectively communicatethe Policy.

Ø Include wordingcovering three keyareas:

• compliance with lawsand regulations;

• pollution prevention;

• continualimprovement.



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Procedure 1) Top management is responsible for setting environmentalpolicy. The policy must meet the requirements of ISO14001 4.2 as stated above

2) Everyone in the organization should understand theenvironmental policy and what is expected of them in orderto achieve the objectives and targets established later on.

Tips Ø Make the policy simple.

Ø The policy should relate to the products and servicesoffered by the organization. The gap analysis may offerhelp in defining policy by ensuring the policy reflects allaspects identified.

Ø In addition to top management, involving other parts of theorganization in policy development will help to buildownership and support.

Ø Policy may be integrated into other documents such as ahealth and safety manual, a quality manual, etc…

Ø Explain, communicate, and verify that employeesunderstand the firm’s environmental policy.

Ø Offer the environmental policy for review externally.



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More Policy Tips

EnvironmentalPolicy

CO

MP

LIA

NC

E

IMP

RO

VE

ME

NT

PR

EV

EN

TIO

N

Ø Consider addressing the following issues in the policy:

• Sustainable development and/or product life cyclethinking.

• Minimization of adverse environmental impacts fromnew developments by integrating environmentalmanagement practices and procedures in the designphase.

• Minimization of pollution, waste, and resourceconsumption at all levels in the organization, andcommitment to recovery, recycling, and reuse.

• Sharing of environmental expertise with others.

• Encouragement of EMS practices insuppliers/contractors.

Ø Routinely review the policy and update it as necessary.



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Environmental Aspects

ISO 14001 4.3.1Environmental Aspects

“The organization shall establish and maintain (a) procedure(s)to identify the environmental aspects of its activities, products,or services that it can control and over which it can beexpected to have an influence, in order to determine thosewhich have or can have significant impacts on theenvironment. The organization shall ensure that the aspectsrelated to these significant impacts are considered in setting itsenvironmental objectives.

The organization shall keep this information up-to-date.”

Description Environmental aspects are those elements of anorganization’s activities, products, services or physicalresources which may have potentially beneficial or harmfuleffects on the environment. These may include discharges andemissions, raw materials and energy use, waste recycling,noise, dust, and visual pollution.

An environmental impact is the change that takes place fromthe occurrence of any given aspect. The relationship betweenthe two is causal: an impact is the pollution that would result ifan environmental aspect were not properly managed orcontrolled.

Aspects include technical concerns such as potential process,storage, transfer, transportation, utilities, and product impacts.Impacts include emissions to air, water, hazardous waste, soiland groundwater, energy use, material use, cosmetic andnuisance concerns. Aspects are reviewed at the level of thesite, plant, department, installation and process. Complaintsfrom third parties should be included in the development of alist of aspects.

Some of the aspects will not be regulatory requirements. As anexample, waste production and energy consumption, althoughnot regulated by set reductions or targets by government, arestill aspects.

Environmental Aspect:

“Element of anorganization’s

activities, products, orservices that caninteract with theenvironment.”

Environmental Impact:

“Any change to theenvironment, whetheradverse or beneficial,

wholly or partiallyresulting from an

organization’s activitiesproducts, or services.”



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There are two kinds of aspects: those that are a direct result offacility operations, and those that are indirect results of facilityoperations. An example of the two:

Direct Aspect: Raw material use in car manufacture, such assteel use.

Indirect Aspects: Raw material production by a supplier, suchas mining and smelting in the production of the steel a plantuses. Since a firm has some influence over suppliers with thepower of its purchases, these are aspects that should bethought about. Note that you DO NOT have to set anymeasurable performance targets or objectives for theoperations of your suppliers or subcontractors. But think aboutthem.

Aspects can be identified in four easy steps:

1. Activities are first reviewed in process increments smallenough to be examined for impacts, but large enough toget the job done in a reasonable time.

2. All environmental aspects of the procedures or processare identified.

3. All potential and actual environmental impacts from theseaspects: positive impacts, negative impacts and potentialimpacts, are identified and associated with an aspect.

4. The aspects are judged for their significance. Ameasurement system is developed to separate thoseaspects which are Significant (and thus will require“Targets and Objectives” and “Operational Control” underthe ISO 14001 Standard) and those that are not. Since aRegistrar auditor must review the procedures for thisstep, it is suggested that it be written down andquantified.



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Purpose Aspects identification is important, since it is from thisidentification of the potential to impact the environment thatthe rest of the system is built. Remember that direct aspectsinclude those that are clearly evident to the facility, likehazardous waste generation, air emissions, waster discharges,etc. Indirect aspects include the activities of raw materialssuppliers and end-users not directly related to theorganization, but in some manner under their control. Byidentifying these various aspects, they can then be properlymanaged. This is the basic intent of the entire ISO 14000process, so good identification of your aspects is essential.

To ease in implementation of an EMS initially, indirect aspectssuch as the impacts from suppliers may be identified butrelegated to the status of general Objectives rather thanspecific Targets until the system matures. This will beaddressed in a later chapter.

Identification of aspects is a continual process under any EMSsystem. The aspects identification process includes all past,present and future impacts that an organization’s activitieshave had, are having, and will have on the environment.Included in this process, aside from the identification ofregulatory requirements, should be an effort to identify thepotential legal, financial, and business risks associated with allactivities. By beginning to identify the other business concernsassociated with your aspects, they will become easier tomanage and the EMS will begin to integrate itself into othermanagement systems.

Procedure to Identify Aspects

Questions to ask to assess and list Aspects, both direct andindirect, are detailed in the following steps:

1. How do the organization’s activities, products andservices impact the environment?

2. Are these impacts adverse?

3. Are procedures in place for the identification and control

Factors to Consider:

• ecological effects• human health impacts• catastrophic effects• resource depletion• scale, severity & duration

of impacts• probability of occurrence• cost of changing• other business effects



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of adverse environmental impacts for new or alteredproducts and services?

4. Is the facility in a location where there are specialenvironmental concerns that must be addressed?

5. Will any severe injurious environmental impacts occur inthe event of a process failure or human error?

6. What is the likelihood of such an emergency situation?

7. How will the firm rate their significant environmentalaspects while considering impacts, likelihood, severityand potential frequency?

8. What would be the scope of the identified environmentalimpacts?

Aspects evaluation should include all phases of operationsfrom the design phase to R&D, marketing, outsourcing,purchasing, production, hazardous waste and solid wastemanagement, product packaging, distribution, sales andutilization of the finished product. Disposal by the end-usercould also be considered.

Aspects Tips Ø Be sure to include environmental impacts NOT governedby regulations in the determination of aspects. The legalrequirements for compliance are a good start, but not thewhole picture. Also look at resource depletion, energy use,visual impacts, etc…

Once environmental Aspects have been determined, andthose that are Significant have been identified, then theObjectives and Targets can be outlined. Some of the Aspectsmay be given general Objectives of indeterminate duration dueto time, technology, or financial constraints. These simplebusiness decisions should be a portion of the aspectdetermination process. You may want to document thisdecision process and its results.

Keep in mind that some aspects will be POSITIVE. Rememberto list them as well, since you might want to communicate themto third parties as a portion of the ISO 14001 EMS



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Communication under Section 4.4.3 of the standard.

Look at the services used and supplied by the firm as well asproducts manufactured. Off-site servicing of equipment is apotential aspect; the actions of subcontractors and suppliersare as well.

Take special care to ensure that the delineation of SignificantAspects can be defended. Just make sure that the mechanismfor making that determination is clear, well documented, andproduces results that are sensible. As an example, if acompany did not identify that a fleet of 100 heavy highwaytrucks traveling through a small and scenic hamlet in vacationcountry was an aspect, let alone a Significant one, this may beunacceptable.

The determination of Aspects, and the declaration of thosethat are Significant, is the basis on which the rest of EMSdevelopment rests.

Requirements

customers

legislation

permits

banks/insurance

complaints

corporate, andPolicy guidelines

Technical

process

storage

transfer

transport

utilities

product

Environmental

air

water

waste

soil and groundwater

energy consumption

nuisance

external safety

product

Level

site/plant

department

installation/equipment

subcontractor/supplier

Environmental Aspects:-Things to Consider



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Legal and Other Requirements

ISO 14001 4.3.2Legal and Other Requirements

“The organization shall establish and maintain a procedure toidentify and have access to legal and other requirements towhich the organization subscribes, that are applicable to theenvironmental aspects of its activities, products or services.”

Description A procedure to identify legal requirements of the organizationshould be established and maintained. This includes all lawsand other self-imposed requirements to which the organizationadheres. These requirements can be partially established byreviewing the previously completed aspects and impacts.Considerations here include asking how the organizationidentifies, tracks and accesses legal requirements? How arechanges in these requirements tracked? How are employeesand others, such as subcontractors and suppliers, informed ofany changes in legal requirements?

Purpose

Setting the Legal Framework for Your EMS

The purpose of identifying and maintaining access to legalrequirements is self-evident: If one doesn’t know what laws areapplicable, how can one be sure if the facility is in complianceor not?

Also, it is important to identify other self-imposed requirementsthat the organization follows. These may include items such asmanagement system performance criteria, client-suppliedrequirements, insurance company requirements, lendinginstitution requirements and other such internal and externalrequirements not demanded by law.

The purpose of identifying these items is to ensure that alloperations take into account not only the law, but also theother self-imposed and non-legal practices. Many legal andcontractual violations are a direct result of lack of awarenessgenerated by lack of knowledge.



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Tips Ø The organization should include all requirements pertinentto its aspects and impacts in the development of its Legaland Other Requirements list, including:

• Site specific requirements such as operating permits(CAAA Title V).

• Product/service-based requirements (TSCA, etc.)

• Industry specific requirements (Responsible Care, QS9000, etc.)

• All applicable environmental laws (40 CFR 261 et seq.).

• Any other requirements based in authorizations,agreements, contracts, and permits (environmentalindemnification, etc.).

Ø The process of identifying, registering, and evaluatinglegislative, regulatory, and policy requirements pertinent tothe environmental aspects of operations begins with theinitial review. In the review, all legislative requirementsshould be identified. Maintenance of these requirements isachieved by staying current with any legislative andregulatory changes.



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Objectives and targets

ISO 14001 4.3.3 “The organization shall establish and maintain documentedenvironmental objectives and targets, at each relevant functionand level within the organization.

When establishing and reviewing its objectives, anorganization shall consider the legal and other requirements,its significant environmental aspects, its technological optionsand its financial, operational and business requirements, andthe views of interested parties.

The objectives and targets shall be consistent with theenvironmental policy, including the commitment to preventionof pollution.”

Description Objectives and Targets are where you shift from identifyingyour environmental aspects and impacts to developing a planto improve them. Objectives and targets are established tomeet the goals of the organization’s environmental Policy.Objectives and targets are developed from the results ofenvironmental Aspects development. They must be developedwithin the scope of the environmental Policy, and shouldquantify the organization’s commitment to environmentalimprovement with time. They must, since the firm operates in aclosed economic system, consider the financial, operationaland business limitations of the organization.

Typically, environmental Objectives are overridingconsiderations such as the development of better employeeeducation and training, improved communication with otherinterested parties, EMS development and registration.Environmental Targets are traditionally specific items like thereduction of energy utilization 10% in a year, or the reductionin hazardous waste generation 3% over three years. Targetsare more closely related to measurable events and might bedirectly identified as cost reducing. Objectives are morephilosophical and general.

Objectives andTargets:

Are they documented atrelevant functions and levelsin the organization?

Are they consistent with thePolicy, and do they have thethree commitments required inthe Policy (go back and check!)

Are they consistent with thebusiness plan?

Can you track and monitorthem?



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Purpose Apart from beginning to identify environmental Objectives andTargets, an initial review should also begin to identifyenvironmental opportunities for the firm. In fact, the structureof the initial review should include this as one of its primaryobjectives. To that end, Objectives and Targets should be setwhere improvements will be most likely to reduce risks to theorganization and the environment, reduce liabilities, and arerationalized by a cost benefit analysis.

When setting the Targets and Objectives, the organizationshould consider the establishment of measurableenvironmental performance indicators that can besubsequently used as the basis for an environmentalperformance evaluation system which will provide informationto management about the functioning of the ISO 14001 EMS.This will be an excellent basis for a “Management Review”,when coupled with audit reports and financial performancedata. To effectively determine actual performance under sucha system, environmental Targets should be established withspecific time constraints and measurable performanceparameters.

Procedure Objectives are set to establish overall, and often long-term,concerns of the organization about their environmentalperformance. Numerous objectives may be set which may ormay not have specific; measurable targets associated witheach of them. For any non-significant aspects identified earlier,just an overall, long-term objective may be established.

An Objective may be to see all suppliers and subcontractorsdevelop their own EMS. This Objective could be supported bya simple statement that:

1. the organization recognizes its financial “control” oversuppliers, but feels that they cannot abuse that control bydemanding their suppliers develop an EMS

2. the organization will therefore merely request that theirsuppliers consider developing an EMS of their own.

In this way, the ISO 14001 view (see Annex “A”, of ISO 14001)



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that financial control does actually amount to “control” underthe Standard, is addressed without making any demands. Thebig difference is that the firm is asking suppliers to consider anEMS, not telling them.

For each significant aspect identified, the organization may setan objective as well as a measurable target associated withthat objective, with perhaps some operational controlassociated with it.

Example:

An objective of the organization may be to have theirprocesses reduce raw materials consumption and energy use.

A target associated with that objective could be set by theorganization by stating that they will reduce electricalconsumption by 8% over the next three years in specificprocesses. As you can see, the target is measurable, but theobjective doesn’t have to be.

Targets and Objectives may include some or all of thefollowing concerns:

• Reduction of waste generation,

• Resource depletion,

• Pollution prevention,

• Environmental product design parameters,

• Environmental impacts of suppliers and subcontractorsactivities.

Some performance indicators that firms use in their Targetsand Objectives include:

1. Quantities of raw materials/energy per unit production

2. Quantity of emissions/releases/wastes overall and per unitof production



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3. Number of environmental incidents/violations

4. Quantity of recycled materials used in packaging andproduction

5. Potential for the recycling of the firm’s products

6. Vehicular use per unit of production

7. Environmental operational costs per unit production/ perviolation or incident

8. Environmental restoration projects or other positiveenvironmental programs

Another consideration is that targets should be set at severallevels of the firm. For example, purchasing might set a targetto buy 75% of all paper products from recyclable sources.Janitorial services may hope to reduce the use of solventbased cleaning products by 25% over a year. The Board ofDirectors might hope to establish a program where allsuppliers and subcontractors are certified to an EMS Standardby the end of this century.

Most operational Targets should be identified at thedepartment level, by the department managers, and beincluded within the framework of the annualbudgetary/planning process already in place at virtually everycorporation worldwide. Department managers may wish to getassistance from the Management Representative (MR) for thistask, like seeking assistance from the Comptroller fordevelopment of budgetary figures.

An evaluation and modification of environmental Objectivesand Targets is carried out annually by an update of theenvironmental aspects. Objectives and Targets should bereviewed as a portion of departmental performance reviews.The results of these reviews should be included in theinformation supplied to management for the ManagementReview required in any EMS program. Decisions should bemade concerning the scope and intent of the original targetsand objectives, as well as the performance indicators about



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how the targets and objectives were met.

TipsØ Operational staff best sets objectives and targets. Since

they will be ultimately responsible for performance, theyshould be included in the decision-making process whendeveloping Objectives and Targets.

Ø Objectives should be consistent with the Policy. ThePollution Prevention, Compliance, and ContinualImprovement philosophy of the Policy should drive them.

Ø Make Objectives flexible. Make a statement of the resultsdesired, and allow staff members to define the “How”portion wherever possible.

Ø Make Objectives simple, at first. Then build on them.

Ø Make Objectives understood to all members of theorganization.

Ø Make realistic Objectives and Targets.

REMINDER: Don’t forget the opportunities existing for yoursuppliers and subcontractors to assist you in conformance tothe Standard.

Examples of areas where an organization can have internalperformance 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■ prevention of pollution and resource conservation■ capital projects■ process change■ hazardous materials management■ waste management■ water management (e.g., waste, storm, ground)■ air quality management■ energy management■ transportation

Internal Performance CriteriaPractical Help



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Environmental management program(s)

ISO 14001 4.3.4 “The organization shall establish and maintain (a)programme(s) and procedures for periodic environmentalmanagement systems audits to be carried out, in order to

• determine whether or not the environmental managementsystem

1. conforms to planned arrangements forenvironmental management including therequirements of this International Standard; and

2. has been properly implemented and maintained;and

• provide information on the results of audits tomanagement.

The organization’s audit programme, including any schedule,shall be based on the environmental importance of the activityconcerned and the results of previous audits. In order to becomprehensive, the audit procedures shall cover the auditscope, frequency and methodologies, as well as theresponsibilities and requirements for conducting audits andreporting results.”

Description Up to now, this guide has focused on laying the foundationsthat the EMS will be developed on, and identifying the Targetsand Objectives of the EMS. To ensure that these Targets andObjectives are accomplished, an Environmental ManagementProgram (EMP) is designed.

Once the organization establishes its environmental Objectivesand Targets, then planning begins to develop a Program forachieving them. This Program should be integrated into theexisting environmental management practices at theorganization wherever possible, and should be tied into thestrategic plan of the organization as well. Issues such asscheduling, resource allocation, and responsibilities should beincluded in the Program to allow for the successful

What is the EMP?

An action plan about how theorganization will meet the Objectivesand Targets of the EMS.

Lists responsibilities, methods, andtime frames for completion.

Incorporates environmental issuesinto the greater businessmanagement arena.

Is communicated and tracked

internally.



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achievement of the Objectives and Targets.

Purpose The Program develops specific, prioritized actions dealing withprocesses, products, services, projects, and facilities thatrelate to already established environmental SignificantAspects, Objectives and Targets. The EMP should alwaysreflect the organization’s environmental Policy. The actionsmust be included in the documentation of the Program so thatcrucial operational practices and responsibilities are reviewed,revised, and redeployed regularly.

Procedure The Environmental Management Program should beintegrated with existing organizational structures such asfinancial management, purchasing, legal, operational, andmanagement information systems. It is essential thatenvironmental management have equal representation at thebusiness management level relative to other groups within theorganization. This would include input into issues such asaccess to capital, choices in technology, productionprocedures, employee training, and emergency protocols.

There will be instances where existing management structuresare not adequate to achieve the Targets and Objectives set forthe EMS. In that case, new structures must be developed.These new structures are best developed with input from thoseresponsible for the function area in question, such as thedepartment head or foreman of a process. The ManagementRepresentative, EMS developmental expert and otheroperational staff members for the practice being consideredmay be included in this structural development.

Projects may be initiated as a result of EMP developmentalactivities that invest in new products, processes, andequipment. These would be expected where the investmentsare aimed at the reduction of environmental effects, eitherdirect or indirect, to allow for a higher level of performance, orfor cost reduction. Again, this would have been investigatedand identified during the Initial Review, and set as Targets.

Environmental Management Program (EMP) monitoring isprimarily the responsibility of the department manager for eachspecific activity. They should routinely report to senior



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management the status of any and all environmental programsand projects under their control. This will allow integration ofenvironmental issues into the scope of management concernsat the senior level.

The EMP does not need to be contained in one document. A“road map” to other documents will fully comply with theStandard. Just keep in mind that those documents mustinclude the roles and responsibilities, processes andschedules that the Standard requires of the EMP. The EMPshould be integrated into other business planning whereveropportunities present themselves and appear to beeconomically or strategically beneficial to the organization.

Tips Ø Utilize employee input wherever possible.

Ø Communicate the expectations of the EMS and EMP,along with the responsibilities to those individuals who canaffect environmental aspects.

Ø Construct the EMP based on current programs andmanagement structures wherever possible, assuming thatexisting programs are sound and financially efficient.

Ø Include health and safety programs if so desired.

Ø Continually reevaluate the organization's action planswhen changes occur in procedures or facilities.

Ø Keep the EMP simple.

Ø By coordinating the EMP with other managementprograms, cost savings can be effected.



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Structure and responsibility

Structure and Responsibility

“Roles, responsibilities and authorities shall be defined,documented and communicated in order to facilitate effectiveenvironmental management.

Management shall provide resources essential to theimplementation and control of the environmental managementsystem. Resources shall include human resources andspecialized skills, technology and financial resources.

The organization’s top management shall appoint (a) specificmanagement representative(s) who, irrespective of otherresponsibilities, shall have defined roles, responsibilities andauthority for

a) ensuring that environmental management systemrequirements are established, implemented and maintainedin accordance with this international standard;

b) reporting on the performance of the environmentalmanagement system to top management for review as abasis for improvement of the environmental managementsystem.”

Description For an EMS to be effective, individual roles and responsibilitiesmust clearly be defined as they relate to the achievement ofenvironmental Objectives and Targets, and the overalloperation of the EMS. Top management must supply thenecessary resources, both financial and staff, to ensure thatthe EMS is effectively implemented. They are also responsiblefor appointing a Management Representative (MR) to overseethe operation of the EMS.

Organizational structure should be defined in writing. Anorganizational chart will be helpful for illustrating many of theenvironmental responsibilities that must be addressed.



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Specifically, key personnel should be clearly identified in theorganizational structure such as:

• Management Representative (MR)

• Director EH&S (or that person responsible for executivedecisions of an environmental nature)

• Facilities Manager

• Plant Environmental Coordinator (EC)

• Purchasing Agent(s)

• Production Manager(s)

• R&D Manager

Purpose All employees of the organization should clearly understandtheir environmental roles and responsibilities, as well asunderstand the importance of the environmental Targets andObjectives that they can affect. Top management defines anddocuments the responsibilities, authorities andinterrelationships of all key environmental personnel. The keyroles that effect environmental performance should beincluded in the employee’s job description where possible, andare included in that employee’s performance evaluation.

The key roles and responsibilities may be documented byHuman Resources in a consistent format that includes theperson’s name, title, organizational responsibilities, date of thedocument, key environmental tasks, authority, and interrelationwith other key task personnel. This document will be useful forinternal communication, training, and documentation later inthe EMS development process.

Procedure Organization employees should develop a draft version of theirpersonal environmental responsibilities and tasks, and theseshould be compared with management’s views to see if there

Responsibilities

ü Are they defined forenvironmental management?

ü Are the roles communicated?

ü Are adequate resourcesallocated?

ü Is a managementrepresentative appointed?

ü Do the roles integrate EMSinto other businessmanagement functions wherepracticable?



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are differences. Identified weaknesses should be corrected.This is also a good chance to review individual perspectives ofthe current management structure and organizationalresponsibilities. Many times, improvements of a procedural orstructural nature can be gained through this process.

To ensure effective development and implementation of an EMS, it isnecessary to assign appropriate responsibilities and authorities.-Itshould be recognized that companies and institutions have differentorganizational structures, and need to understand and define environ-mental responsibilities based up on their own work processes.

ENVIRONMENTAL RESPONSIBILITIES PERSON(S)-RESPONSIBLE

Establish Overall Direction President, CEO, Board of Directors

Develop Environmental Policy President, Chief Executive Officer,Chief Environment Manager

Develop Environmental Objectives Relevant ManagersTargets and Programs

Monitor Overall EMS Performance Chief Environmental Manager,Environmental Committee

Assure Regulatory Senior Operating ManagerCompliance (Eternal)

Ensure EMS Compliance All Managers, Chief Environment(Internal) Manager

Ensure Continual Improvement All Managers

Identify Customers Expectations Sales and Marketing Staff

Identify Suppliers Expectations Purchasers, Buyers

Develop and Maintain Finance/Accounting ManagersAccounting Procedures

Comply with Defined Procedures All Staff

Accountability and ResponsibilityPractical Help



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The Management Representative (MR)

The Management Representative is one of the essentialelements of a successful program. As such, the roles andresponsibilities of this position should receive specialconsideration. The MR is essential for the homogeneity of theimplementation process and for the continual improvement ofthe system once it has been established. The MR should be amember of the facilities management team. They should haveoverall responsibility for compliance with the requirements ofthe EMS, and should be charged with ensuring that changes inregulations and the firm’s environmental effects are monitoredand the system modified to meet them.

In larger operations (>5000 employees), one single personmay not effectively handle the task of MR. So, the appointmentof Environmental Assistants (EA) at the department level maybe considered. Support for an EA includes adequate trainingas well as the allocation of adequate time to accomplishassigned EMS tasks apart from the EA's regular workschedule.

Staff Roles and Responsibilities

The specific responsibilities of the MR and EC do not absolveline management from compliance responsibilities forregulations and operational requirements of the EMS. Forexample, line managers may be delegated the responsibility todetail operating procedures which operations staff must follow.

A flow chart of roles and responsibilities may be used. Thiscan simplify the process of structural review and re-thinking.As an additional tool, an environmental responsibility matrixcould be included in the flow chart to effectively communicatethe environmental responsibilities to all employees.

As the standard mentions in several places, structure andresponsibility should be set up to involve all relevant functionsand all levels throughout the organization. This section doesnot require a procedure but does require the following itemsfor effective environmental management on a large scale.



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Requirement Action1. Roles defined

2. Roles documented

3. Roles communicated

4. Responsibilities defined

5. Responsibilities documented

6. Responsibilities communicated

Develop EMS organizational structure

Document organizational chart

Route to all relevant employees

Define all EMS position responsibilities

Document utilizing spreadsheet or list

Route to all relevant employees

There is also a requirement on a smaller scale but for an important individual.

Requirement Action1. Top management appoints a specific

MRSteering committee appoints thecandidate and documents decision

2. The MR must have their role,responsibility, and authority defined,documented, and communicated to:

A. Ensure the EMS is established,implemented, and maintained

Develop separate document showing thisindividual's role, responsibility, andauthority and route to all employees

B. Report on the performance of theEMS to Top Management every sixmonths to evaluate performanceand improvement areas.

Include the report schedule withIndividual's and Top Management’sAnnual Plan

It is important that a documented performance report be developed andpresented to Top Management prior to the certification audit.



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Tips Ø Make the structure as flexible as possible, while ensuringthat it is comprehensive.

Ø Communicate the MR's roles and responsibilities toeveryone in a clear and concise manner. Communicateroles and responsibilities in writing to individualsassociated with significant aspects!

President

Director of R&D

Director of Quality VP Sales

Design Engineer

Director of Environmental

Affairs

Director of Manufacturing

New Product Planning

Sales Manager

Sr. Sales Engineer

Director of Regulatory

Affairs

Regulatory Compliance Specialist/

Auditor

Regulatory Training Specialist

Operations Manager

Maintenance Technician

Facilities Engineering

Environmental Management

Rep

Safety Officer

Safety Technician

Industrial Hygientist

Laboratory Technician

Manager Hazardous

Wastes

Environmental Engineer

Manager Occup.

Health & Safety

Equipment Calibration

ISO 9000 Auditor

Sales Engineer

Senior Manufacturing

Engineer

Manufacturing Engineer

Manufacturing Technician

Administrative Assistant

Manufacturing Assembly Personnel

Environmental Technician

EMS Auditor

Environmental Functional Organization Chart



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Training, awareness and competence

ISO 14001 4.4.2 “The organization shall identify training needs. It shall requirethat all personnel, whose work may create a significant impacton the environment, have received appropriate training.

It shall establish and maintain procedures to make itsemployees or members at each relevant function and levelaware of

a) the importance of conformance with the environmentalpolicy and procedures and with the requirements of theenvironmental management system;

b) the significant environmental impacts, actual or potential, oftheir work activities and the environmental benefits ofimproved personal performance;

c) their roles and responsibilities in achieving conformancewith the environmental policy and procedures and with therequirements of the environmental management system,including emergency preparedness and responserequirements;

d) the potential consequences of departure from specificoperating procedures.

Personnel performing the tasks which can cause significantenvironmental impacts shall be competent on the basis ofappropriate education, training and/or experience.”



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Description Management has an essential role in developingorganizational awareness and motivation by explainingenvironmental Policy and demonstrating commitment to it. Thiscommitment of individuals and resources to the goals outlinedin the environmental Policy, Targets and Objectives is theevent that brings the EMS to life.

Training is important for two reasons:

1. Employee action might have an impact on theenvironment.

2. Employees are a useful resource for generating ideasabout establishing operational control for a process,defining environmental aspects, or defining structuralresponsibilities.

Purpose The basic intent of training is to explain the importance of theEMS to staff, and to explain their responsibilities for EMSoperations. In order for responsibilities to be effectivelyunderstood, adequate training is essential. A training systemshould also include training for executives to ensure that theyunderstand the EMS, know their responsibilities and have theknowledge to carry those responsibilities out.

Procedure Staff members are trained in their specific environmentalresponsibilities that are directly related to Significant Aspects,Targets and Objectives in the EMS. If they do not havesignificant roles, then they should receive awareness trainingon EMS content and purpose. New hires and re-assigned staffmembers are given appropriate training on the specific aspectsof their new position, the equipment they will be expected tooperate, its impacts on the environment and expectedmethods of operation.

Employees will need to be kept abreast of regulatory changes

When to Train:• New Employee Hire

• Change in JobDescription

• Corrective Action notesfailure to followinstructions

• New or AlteredProcedures/Process

• Changed EMS Aspects/Objectives/Targets

• New Regulations (local,state or federal)

• Unacceptable JobPerformance



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that impact their job performance. Training modules formanagement and operations staff should be developed toensure this continuing education. Where in-house training isnot adequate, out-sourced training should be utilized.Subcontractors and others with any impact on the EMS shouldreceive training consistent with their impact on the system.

The MR should be responsible for the establishment of trainingrequirements of each operational unit within the facility, as wellas investigating the possible sources for that training. Trainingshould include communication of the following:

◊ Requirements of the system, the importance of regulatorycompliance, and the importance of compliance withenvironmental policy.

◊ The potential negative environmental effects of theemployee’s work. The positive effects of improvedperformance on their part.

◊ Their responsibilities in achieving compliance with thepolicies, regulations and EMS requirements.

◊ Consequences of failure to comply with the above.

Training requirements should be more detailed for thoseindividuals that are responsible for verification ofenvironmental performance, either regulatory complianceverification or EMS conformance verification. These trainingrequirements and records should be maintained as a portion ofthe documentation of the EMS. Apart from formal trainingsessions, other methods of training may be used:

• routine departmental meetings,

• existing safety meetings (more prevalent than specificenvironmental meetings),

• flyers, leaflets, bulletin board presentations,

• subscriptions to environmental magazines, legalnewsletters, and other environmental literature,



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• local, community, or state environmental conferences.

Tips Ø Don’t start from scratch in training programs… there mayalready be a wealth of training given to employees forestablishing environmental responsibilities. Investigate anduse it. On-the-job instruction should be included, but clearlydocumented where required.

Ø Plan training around existing meetings as much as possibleto save on additional expense.

Ø Include environmental responsibilities in new employeetraining and orientation.

Ø Seriously consider the training and qualificationsrequirements for the environmental management staff andtrainers.

Ø Consider EMS skills during recruiting and new employeeselection.

Ø Clearly establish competency for various key tasks. Thesecompetencies should clearly align themselves withsignificant environmental aspects.

Ø Asking employees how they perform certain tasks canassess competency. This could be integrated into the initialreview/gap analysis section of the EMS developmentprocess, since it will be required for the establishment ofoperational control.

Ø Supplement competency with training aids whereverpossible and practical.

TYPE OF TRAINING AUDIENCE PURPOSE

Training, Skills, CompetencyPractical Help

To gain commitment andalignment of theorganization’s environmentalpolicy.

To gain commitment to theenvironmental policy,objectives and targets andto instill a sense of individualresponsibility

Improve performance inspecific areas—operations, R&D, engineering

Ensure regulatory andinternal requirements fortraining are met.

Senior Manage-ment

All Employees

Employees withenvironmentalresponsibilities

Employeeswhose actionscan affectcompliance

Raising awarenessof the strategicimportance of environ-mental management

Raising generalenvironmentalawareness

Skills Enhancement

Compliance



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Communication

ISO 14001 4.4.3 “With regard to its environmental aspects and environmentalmanagement system, the organization shall establish andmaintain procedures for:

a) internal communication between the various levels andfunctions of the organization;

b) receiving, documenting and responding to relevantcommunication from external interested parties.

The organization shall consider processes for externalcommunication on its significant environmental aspects andrecord its decision.”

Description Effective communications can help an organization motivatestaff, tell them what actions they should be taking regardingthe environment, verify roles and procedures, monitorenvironmental performance, and act to identify potential forimprovement. Improvement opportunities are often anoverlooked portion of internal communication. Employeesuggestions are extremely effective in improving proceduresand products. Communications require top-to-bottom flow ofinformation as well as bottom-to-top.

Communication with external parties is also important forcomprehensive management of a firm’s environmentalaspects. Often, through good external communications,problems with regulatory agencies and Non-GovernmentalOrganizations (NGO’s) can be avoided. Communication fromthese sources may help in setting Aspects, Objectives andTargets.



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Purpose

Opening the Information Lines

Communication in an EMS includes the communication ofinternal and external environmental information tomanagement, and the communication from management toothers of their intentions regarding environmental impacts.Communication should include procedures for internalreporting as well as external reporting on environmentalactivities of the organization. This communication is designedto:

• Demonstrate management’s commitment to theenvironment;

• Make others aware of the organization’s environmentalpolicy and commitment to environmental responsibility;

• Address concerns about the organization’s environmentalactivities by external parties; and

• Announce the organization’s strategic environmentalmanagement approach.

• Establish a line of communication that clearly definesemergency responsibilities.

Lines of communication are especially crucial whenemergencies arise and concerned parties ask questionsrelating to environmental risk. The release of contradictory orconfusing information will create an atmosphere of mistrustand fear. Communication should be clear enough to leave noroom for misinterpretation. The intent of communication tooutside interests is to avoid misinformation.

Procedure Once the organization has implemented an EMS, thencommunication should extend from the initial corporateissuance of an environmental report to other, “softer” forms ofcommunication such as open houses for interested parties,routine press releases concerning environmental activities,direct environmental performance reports to the press.

Consider communicationstrategies for:• neighbors

• community groups

• other interest groups

• local officials

• regulatory agencies

• emergency responders



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Consider the following in this effort:

• Are there processes established for receiving andresponding to internal and external interested partiesconcerns relative to the environment?

• How is the organization’s environmental policy andperformance communicated (internal and external), andare the results of environmental audits and other self-critical analyses included in this communication?

• Will internal environmental communication be adequate tofoster continual environmental improvement?

When communicating, there are many specific items that maybe important to communicate:

• Environmental policy and corporate profile;

• Established targets and objectives;

• Measurable environmental performance evaluation such aswaste reduction figures, recycling efforts, energy savings,etc;

• Identified environmental opportunities; and/or

• Independent verification of communicated results.

The facility top management, the MR or the facilities’ publicrelations officer should be the only ones to release informationto third parties about environmental matters. Be as open tothird party inquiries as possible, acknowledge the existence ofproblems where they arise, communicate about them, and tryto involve responsible third parties in the solution process.Direct and honest communication increases the knowledgeand understanding of external parties and lays the foundationfor mutual trust and acceptance. Environmental performancemay still be closely scrutinized, but the external party may viewfrom a factual position rather than an emotional one.

It is important to note that this section refers only to thecommunication that is related to the environmental aspects



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and the environmental management system (EMS). To fulfillthis element of the standard, both internal and externalcommunication must be addressed. Internal communication isthat communication within the organization or facility directlyrelated to the environmental aspects or the EMS. The standardrequires communication at all relevant levels and functionswithin the organization. External communication iscommunication between the organization and an interestedparty outside the facility (e.g. EPA, environmentalorganizations, adjacent facilities or residents). The followingwill be required to fulfill this element:

A. Procedures:

1. Procedure for Internal Communication on EnvironmentalMatters

2. Procedure for External Communication on EnvironmentalMatters

B. Records (Examples)

• Received Internal Environmental Communicationdocuments

• Responses to Internal / External EnvironmentalCommunication documents

• Proof of Policy Communication

• Suggestions related to environmental issues

• EMS document distribution sign off sheets

• Emergency Response Communication record

• Internal / External audit reports



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Scope:

All internal communication directly related to the EnvironmentalAspects and the Environmental Management System.

Objectives:

Establish and maintain communication to:

1. Raise awareness of the organization's environmentalpolicy, objectives and targets, and environmentalmanagement system.

2. Receive, document, and respond to environmentalquestions, concerns and suggestions that come fromemployees.

Responsibilities:

It is the responsibility of environmental affairs to communicateenvironmental information to all effected and interestedinternal parties. It is also the responsibility of environmentalaffairs to receive, document and respond to all environmentalquestions, concerns and suggestions from employees.

Procedure:

Communication From Environmental Affairs to FacilityPersonnel

Environmental Affairs places a routing list on eachenvironmental document relating to the EMS and sends acontrolled copy and a receipt slip to the pre-designatedindividual or area.

The individual or area representative initials or signs thereceipt slip and sends it back to Environmental Affairs.



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Tips Ø How proactive does the organization want to be incommunicating their environmental activities? Use thisanswer to develop the degree of depth in the EMScommunication systems.

Ø When explaining what an employee should do regardingenvironmental concerns, an explanation of why thoseactivities are important should be included. This actionhelps to develop a sense of purpose regarding employeejob activities, no matter how simple or complex they are.

Ø Keep communication simple.



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Environmental Management System Documentation

ISO 14001 4.4.4 “The organization shall establish and maintain (a)programme(s) for achieving its objectives and targets. It shallinclude:

A. designation of responsibility for achieving objectives andtargets at each relevant function and level of theorganization;

B. the means and time frame by which they are to beachieved.

If a project relates to new developments and new or modifiedactivities, products or services, programme(s) shall beamended where relevant to ensure that environmentalmanagement applies to such projects.”

Description Up to now, this guide has focused on laying the foundationsthe EMS will be developed on, and identifying the Targets andObjectives of the EMS. To ensure that these Targets andObjectives are accomplished, an Environmental ManagementProgram (EMP) is designed.

Once the organization establishes its environmental Objectivesand Targets, then planning begins to develop a Program forachieving them. This Program should be integrated into theexisting environmental management practices at theorganization wherever possible, and should be tied into thestrategic plan of the organization as well. Issues such asscheduling, resource allocation, and responsibilities should beincluded in the Program to allow for the successfulachievement of the Objectives and Targets.

Purpose The Program develops specific actions, in order of priority,dealing with processes, products, services, projects, facilitiesthat relate to the already established environmental SignificantAspects, Objectives and Targets. The EMP should always



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reflect the organization’s environmental Policy. The actionsmust be included in the documentation of the Program so thatcrucial operational practices and responsibilities are reviewed,revised, and redeployed regularly.

Procedure The Environmental Management Program should be designedinto the existing organizational structures such as financialmanagement, purchasing, legal, operational, and managementinformation systems structures. This is essential ifenvironmental management is to become an integral portion ofoverall general business management.

There will be instances where existing management structuresare not adequate to achieve the Targets and Objectives set forthe EMS. In this instance, new organizational structures mustbe developed. These new structures are best developed withinput from those responsible for the activities in question, suchas the departmental head or foreman of a process. TheManagement Representative, EMS developmental expert andother operational staff members for the practice beingconsidered might be included in this structural development.

Projects may be initiated as a result of EMP development thatinvest in new products, processes, and equipment. Thesewould be expected where investments are aimed at thereduction of environmental impacts, either direct or indirect,higher level of performance, or cost reduction. Project targetsmay be set from efforts in investigation and identificationduring the Initial Review.

Environmental Management Program (EMP) monitoring isprimarily the responsibility of the department manager.Managers should routinely report to senior management thestatus of any and all environmental programs and projectsunder their control. This communication effort allowsintegration of those environmental concerns into the scope ofmanagement concerns at a senior level.

The EMP does not need to be contained in one document. A“road map” to other documents fully complies with theStandard. Just keep in mind that documents must include the



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roles and responsibilities, processes and schedules that theStandard requires of the EMP. The EMP should be integratedinto other business planning as much as is practical.

Tips Ø Utilize employee input wherever possible.

Ø Communicate the expectations of the EMS and EMP,along with responsibilities to those individuals who need toknow.

Ø Construct the EMP based on current programs andmanagement structures wherever possible.

Ø Continually reevaluate the action plans when changesoccur in procedures or facilities.

Ø Keep the EMP simple.

Ø By coordinating the EMP with other managementprograms, cost savings can be effected.



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Document control

ISO 14001 4.4.5 “The organization shall establish and maintain information, inpaper and electronic form, to

a) describe the core elements of the management systemand their interaction;

b) provide direction to related documentation.”

Description Documenting an EMS can be as simple or as complex as theorganization decides. EMS documents can and should beintegrated with other management documents whereverpossible. Cross-references with health and safety manuals andquality manuals are examples of this. Existing Proceduresmanuals may have environmentally related information inthem.

Operational processes and procedures should be defined,documented and updated, especially those that establishoperational control over significant environmental aspects.

The single-manual approach generally does not work forcomplete EMS documentation. Rather, the EMS Manual is aroad map to other associated documents. The EMS Manualshould describe what the EMS consists of, where other relateddocuments are located, and where records of performancecan be found. It should be a “one-stop-shopping” outline of allother sources of EMS paperwork.

Purpose Employees should have all relevant environmentally significantprocedures and practices identified in a single source. AnEnvironmental Manual should do this. Those who require itsinformation should know the manual's location. The Manual isa directory to the location and utilization of other existingprograms the organization devoted resources to developing.



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Procedure Documentation is not required for every procedure or workprocess. Worker experience, skill, qualifications, standardagency techniques, or manufacturer’s operating instructionsare all adequate alternatives. Also, flow charts or other non-textual forms of documentation may be more effective than thepublication of a “book” of instructions. Documentation shouldbe sufficient to define the facility EMS.

While documenting the procedures required under the EMS,practices that add no value to the process may be identified.These can be eliminated. And by attempting inter-departmental and cross-disciplinary documentation, thepossibility exists of identifying similar procedures betweendepartments that can be combined. To effectively achieve thissort of streamlining, a cross-departmental team approach isbest, coupled with an external third party. This interdisciplinaryapproach will weed out bottlenecks, redundancies, redundantreviews and reports.

Working instructions MUST be clear and concise. Each step inthe instructions should be numbered, the procedures shouldbe given sequentially, and language should be used that theend user will easily understand. Illustrations may be usedwhere words are not clear.

All required tools, supplies, safety equipment and teamsupport should be explained at the beginning of theinstructions for any task. Measures of performance for a taskshould be clearly delineated, and the responsibilities forverification made clear. Criteria for acceptance, non-conformityresolution, and corrective actions should also be clear.

Suggested elements ofdocument control:• issue/revision date

• effective date

• approval (i.e., signature)

• revision number

• document number (orother identifier)

• copy number

• cross-references

Key Question:Is everyone working with

the same set of documents?



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Operational control

ISO 14001 4.4.6 “The organization shall identify those operations and activitiesassociated with the identified significant environmental aspectsin line with its policy, objectives and targets. The organizationshall plan these activities, including maintenance, in order toensure that they are carried out under specified conditions by

a) establishing and maintaining documented procedures tocover situations where their absence could lead todeviations from the environmental policy and the objectivesand targets;

b) stipulating operating criteria in the procedures;

establishing and maintaining procedures related to theidentifiable significant environmental aspects of goods andservices used by the organization and communicating relevantprocedures and requirements to suppliers and contractors.”

Description Operational control over all activities significantly affecting theenvironment is a requirement of the ISO 14001 Standard. Toassure this, operating methods and procedures must bewritten down for these activities. This provides consistencywhen staff changes occur, and clearly identifies to staffmembers what their job responsibilities are.

Specific documented instructions must be developed forthose activities where absence of instructions might result in anon-conformance or a high risk of environmental impact. Inthose cases, written instructions must clearly and succinctlyprovide operating procedures, performance verification criteriaand any corrective activities required in the event of a non-conformance. Master lists should be developed to control theexistence, location and ownership of each procedure. Thesemaster lists may become bridge documents for thedevelopment of “operational control” as indicated in theStandard.

What to do:Develop procedures (written)for controlling key activitiesand operations that areassociated with SignificantAspects.

Ensure employees are trainedon these procedures.

Ensure that these procedurescover all normal and abnormaloperating conditions, includingemergencies.



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Purpose Implementation of the EMS begins with the establishment ofOperational Controls to verify that an organization’s Policy,Targets, and Objectives are achieved. Training, Proceduresand Instructions are all-inclusive components of thisOperational Control. Operational Controls can be of threebasic types:

1. Those activities assigned to prevent pollution or conserveresources. Process re-engineering, capital project design,and new product development are a few examples.

2. Compliance management activities designed to ensureadherence to regulations, or internal operationalrequirements to ensure efficiently meeting regulations.

3. Strategic Environmental Management activities designed toidentify environmental opportunities, to anticipate change,and to respond to emergent trends.



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Procedure Operational control can be broken down into two plans: atechnical control plan and a management control plan. Theseplans describe technical and management controls identifiedduring the initial review/gap analysis. They delineateresponsibilities and authorities for those controls and mentionmilestones and deliverables in the planning of improvements.They may include budgets for internal capabilities, externalsupport requirements, and actual expenditures for capitalequipment. The plans can also quantify expected cost benefitsderived from the improvements.

Employees who actually work with procedures should developnew instructions, and modify existing ones. Preparation ofdocumentation to establish EMS Operational Control isdelegated to departmental work groups under the direction ofthe department manager. The department should reviewenvironmental requirements and effects within their area ofoperation as defined in the Aspects, Objectives and Targets.This activity is usually accomplished by the project team.

Integration of operational procedures designed forenvironmental stewardship with other management systemsfurther illustrates the commitment of the organization toenvironmental improvement. This integration may beconsidered in some of the following areas: quality systems,safety procedures, logistics, and financial decisionmaking.EMS Operational Control procedures require a “Do-Check-Correct” approach. To accomplish this, the following steps maybe utilized:

1. Establish the Operational Control requirements for theactivity in question.

2. Identify the specific portion of the procedure that must bemonitored, and document the methodology of processcontrol.

3. Review the monitoring results from (2) above against therequirements of (1) above.

Examples of Activitiesand Operations that MightRequire OperationalControls:• management/disposal

of wastes

• approval of newchemicals

• storage & handling ofraw materials andchemicals

• wastewater treatment

• operation of paint line

• operating of platingsystem

• management ofcontractors

Policy

Identificationof Significant

Impacts

OperationalControls

Objectives &Targets



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Procedures vs. Instructions

ISO defines procedures and instructions as:

“A procedure is a prescribed series of actions involvingseveral people. The actions are to be executed in apredetermined sequence. Within the sequence, any points ofchoice are clearly indicated. A procedure always deals with thefollowing matters:

◊ What needs to be done?

◊ Who will have to do it?

◊ When will it have to be done?

An instruction can be described as a prescribed series ofactions to be executed by one single employee in adetermined sequence; any points of choice are clearlyindicated. The difference with a procedure is that severalemployees are involved with the latter.”

In many cases, a generic procedure will be adequate tocomply with the ISO 14001 Standard, as well as the concept ofEMS. But, if it is determined that a specific written OperationalControl procedure is required, the team approach will beeffective. Again, it may be found that a procedure required inone department already exists in another, or that there aremutually redundant procedures in two departments. Thisdiscovery may allow for the elimination of redundantprocedures and consolidation of common departmental controlprocedures.

The MR or other general management representative mayauthor general procedures. Specific departmental proceduresshould be written by the department supervisor and the staffmembers responsible for the activity, or at least edited bythem.



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Tips Ø Use existing procedures wherever possible. MostSignificant aspects may already have a procedure written.Simply verify that it is used and that it is accurate.

Ø When employee education and experience (forprofessionals involved in highly technical research, forexample) determines employee competency, it is lesscritical to write out instructions. This should not be the solecriterion for establishing operational control. Whencomplex and critical procedures are in question, seniortechnical staff should also have written procedures at theirdisposal.

Ø Once operational controls are established, consider whatmaintenance and calibration activities will be required forthose procedures. Instructions for these activities may bewritten down in compliance permit applications andequipment manuals.

Ø Use flow diagrams to ensure understanding of the processinvolved.

Ø Break down each procedure by steps.

Ø Be consistent.

Ø Review procedures with those performing the work toensure they are correct and to obtain ideas forimprovement (you should also talk with them prior todeveloping the procedure).

Procedures may include those for subcontractors andsuppliers if they have an impact on the organization’ssignificant aspects.

Set of Requirements

Monitoring Verification

Process

Corrective Actions

ingoing stream outgoing stream

Operational Control



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Emergency preparedness and response

ISO 14001 4.4.7 “The organization shall establish and maintain procedures toidentify potential for and respond to accidents and emergencysituations, and for preventing and mitigating the environmentalimpacts that may be associated with them.

The organization shall review and revise, where necessary, itsemergency preparedness and response procedures, inparticular, after the occurrence of accidents or emergencysituations.

The organization shall also periodically test such procedureswhere practicable.”

Description Emergency preparation and procedures should be establishedto respond to unplanned events. Procedures should definecontrol mechanisms, operational requirements and othercontrols during these events. Emergencies, as defined by anEMS, include releases to the environment of all types, naturaldisasters that might lead to releases, and process hazards thatmight become emergencies.

Emergency preparations for most facilities are usually basedupon human health considerations, as they should be. Thereis a good possibility that health and safety programs havebeen established which may comply with the standard. Theyshould also include procedures for mitigation of material lossor other financial damages resulting from emergencies.

Purpose The philosophy behind emergency preparations is to preplanemergency actions to mitigate, reduce, and/or eliminate theenvironmental health and safety impacts that can carry hugefinancial implications. This investment is generally recoveredthe first time a serious incident occurs but is also difficult toquantify. Insurance costs may also be negotiated on the basisof enhanced preparedness.

Review:

Are all key procedures reviewedfor emergency preparation?

Did you develop procedures formanaging these potentialities?

Are personnel trained adequatelyand is the correct emergencyequipment where it should be?

Is there a process to review theemergency system after a drill orincident?



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Procedure Planning for emergencies should include:

• an emergency assessment process,

• preventive measures,

• organizational responsibilities,

• listing key personnel,

• defining emergency services and their capabilities,

• communication plans,

• actions to take in the event of emergencies,

• hazardous material information, training, planning andpracticing in the event of a release.

It should be noted that for some emergency situations, it wouldbe worthwhile to consider the purchase of hazard mitigationequipment, and opening preliminary communication toemergency medical centers. As an example, EPCRA(Emergency Planning and Community Right to Know Act of1986) mandates this activity for facilities with sufficientinventories of hazardous chemicals.

Emergency drills and plans can be handled in similar fashionto those for fire emergencies. They may be combined into thesame plan but should be addressed in separate sections of theplan. Finally, one question should be routinely asked: “Doeseveryone know what to do in an emergency, and have thelocal responders been told what could potentially happen?”

Useful Information:

• Material safety data sheets• Plant drawings• Process flow diagrams• Piping and instrumentation

diagrams• Design codes and

standards• Specifications on safety

systems (alarms,sprinklers, etc.)



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Monitoring and measurement

ISO 14001 4.5.1 “The organization shall establish and maintain documentedprocedures to monitor and measure, on a regular basis, thekey characteristics of its operations and activities that canhave a significant impact on the environment. This shallinclude the recording of information to track performance,relevant operational controls and conformance with theorganization’s environmental objectives and targets.

Monitoring equipment shall be calibrated and maintained andrecords of this process shall be retained according to theorganization’s procedures.

The organization shall establish and maintain a documentedprocedure for periodically evaluating compliance with relevantenvironmental legislation and regulations.”

Description Measuring and monitoring are performed to see if the EMSTargets and Objectives are being met. The EnvironmentalManagement Program establishes Operational Controlperformance criteria that must be verified. The EMS shouldinclude procedures for this measuring and monitoring. Theresults of this self-critical analysis should be reviewed andused as indicators of the system’s success and reliability, aswell as identifying those areas in need of Corrective Action orimprovement.

Purpose Identifying the performance indicators an organization will useto monitor the EMS should be an integral part of processengineering, product design, and standard operatingprocedures. They should be included in work instructionsdeveloped in previous sections.

This section of the EMS outlines expectations that thosemeasurements are quantified and collated into some useableform for management review. Since these will be verificationmeasurements that will be used to make capital decisions,

Did you:• Identify key process

characteristics and how you willmonitor them?

• Develop a process to reviewcompliance with regulations(audits?).

• Determine how to measure theperformance relative to theObjectives and Targets?



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they must be accurate and reproducible. They must berelevant to the scope of a firm’s Activities and Policy, betechnologically feasible and cost-effective, and use non-destructive sampling techniques.

Procedure When performing measuring and monitoring it is essential to:

• Identify and document the measurements that will beperformed, and specify the allowable range.

• Identify the time, place and persons performing themeasurements.

• Maintain quality control procedures for verificationprocedures.

• Ensure corrective actions and countermeasures are inplace if the measurement is found to be in excess ofallowable parameters.

• Procedures for calibration and routine maintenance ofequipment utilized should be documented.

This information should, at least in abbreviated form, beincluded in the Management Review found in subsequentsections of this Guidance Manual.

“If you can’t measure it, you can’t manage it.”

- Peter Drucker

Which operations andactivities can have

significant environmentalimpacts?

What are the keycharacteristics of these

operations and activities?

How do we measure thesecharacteristics?



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Tips Ø Keep monitoring requirements limited to KEY processcharacteristics.

Ø The best systems will combine elements of both Processand Outcome measurements.

Ø Make sure equipment is maintained and calibratedroutinely.

Ø Ensure that regulatory compliance is included in themeasuring and monitoring programs for the EMS.

Ø Ensure that the measuring and monitoring will verifyconformance with the Policy, Targets and Objectives of theEMS.

Ø Focus on those things that you can control!

Ø Make sure you have the resources to implement theprogram as defined.

Ø Make measuring and monitoring reports applicable to theoperational staff and meaningful for management.

Ø Make sure that the difference between environmentalperformance evaluations (EPE) and audits are clear.

Ø Consider economic studies to determine cost of effortversus economic return on investment. Some activitieswon't or can't justify their implementation (cost ineffective).

Audits vs. EPE

Audits: Periodic Independent Verify conformance A sampling of data

EPE: Continual Frequent Operations responsibility Assess process performance



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Nonconformance and corrective and preventive action

ISO 14001 4.5.2 “The organization shall establish and maintain procedures fordefining responsibility and authority for handling andinvestigating nonconformance, taking corrective action tomitigate any impacts caused and for initiating and completingcorrective and preventive action.

Any corrective or preventive action taken to eliminate thecauses of actual and potential nonconformances shall beappropriate to the magnitude of problems and commensuratewith the environmental impact encountered.

The organization shall implement and record any changes inthe documented procedures resulting from corrective andpreventive action.”

Description The results of Monitoring and Measurements, audit findingsand other systemic reviews should be documented andreviewed, and must lead to Corrective Actions. Proceduresshould be in place so that the organization can ensure thatCorrective Action has taken place, and that it has beeneffective. Further, the root cause of the systemic failure shouldbe determined, if possible. And, patterns and trends should benoted and analyzed.

Some steps to achieve this end might be:

1. Inform the employees that it is everyone’s responsibility toidentify and perform corrective actions. This would includereporting non-conformances of operational and proceduralnatures. Specific steps should be outlined to effect thatreporting.

2. As with the reporting of Corrective Actions, it should beclear to all employees of an organization that everyone isresponsible for solving non-conformances as well.Emphasis on problem solving, rather than focusing on thenegative aspects of human error can go a long way inachieving this goal.

Foster the belief that the concepts of “continual improvement”

Fixing EMS problems andavoiding them in thefuture



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are the basis of everyone’s performance review. It would bedifficult to identify any aspect of a person’s performance that ismore crucial than the belief that they can improve in someway, every day!

Purpose The corrective action portion of any EMS will be the mostheavily scrutinized portion of the System by regulatoryagencies in the event of a catastrophe. It will also be one ofthe most scrutinized portions of the EMS during a Registrar'saudit because of its importance in reducing the potential of acatastrophe. Registrars may expect an organization to showdocumentation that several corrective actions have takenplace which conform to the design specifications of the EMS,and that follow-up has occurred.

Deviations from the norm may be either singular or regular intheir frequency. There are a great many causes for suchfailures, including items such as human fatigue, error, poorequipment or equipment maintenance, or errors in the designof the EMS itself. By recording the events of a non-conformance and its Corrective Action, patterns of successand failure of the EMS can be reviewed and the system, theequipment, or the people adjusted accordingly.

Procedure Procedures must be maintained for defining responsibility andauthority, investigating non-conformances with the EMS andtaking action to correct impacts when requirements are notmet. If there is a pattern of non-conformance recognizable,good policy is to register the Corrective Action and report it.Usually, Corrective Actions are the responsibility of thesupervisor in a department, because Corrective Actions areusually aimed at the behavior of individuals. Procedures forinquiry and corrective measures are:

◊ Determine the cause

◊ Decide if immediate action is required



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◊ Decide which action should be taken

◊ Take action to lower the risks to acceptable levels

◊ Check to see if measures are effective

◊ Record shortcoming of Corrective Actions

◊ Record changes in procedures required to avoidduplication

It is also important to illustrate the differentiation of CorrectiveActions from Preventative Actions within the organization.Preventive Actions may include analysis of environmentalperformance indicators previously discussed to determineprobabilities of non-conformance. Corrective Action will be theprocess changes or procedural activities that are initiated ifand when the preventative actions detect a problem.

Corrective Actions are, many times, the most difficult to initiatein an organization. Hurt feelings may arise from any stepstaken to dictate changes in procedures for an individual afteran incident. As such, this should be handled with care toprevent the entire process from becoming a “witchhunt”. Areasonable approach would be to structure the process in theform of assistance for the employee or department involved.Ask them what they think should be done to resolve the issue,what they think could be done to ensure it does not recur, anddo what can be done to include their input if it is reasonable, inthe final solution.

Steps to develop a Corrective Action program:

1. The MR should review and record pertinent EMSperformance information with management and employeesalike. This should include: complaints from customers,agencies and third parties, monitoring deviations, rawmaterials costs reductions, accidents, processimprovement resulting in waste reduction, pollutionprevention or other lessening of environmental impact.

2. Preventative action results from the analysis of data. If theanalysis finds trouble, then corrective action is taken. To

Did you:Design a process forinvestigating, correctingand preventing systemdeficiencies?

Design a process toassign roles andresponsibilities formonitoring the completionof corrective actions?

Design a process to revisethe procedures ordocuments that are thebasis for correctiveactions under the EMS?



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fully implement the system, costs data for environmentalaspects should be analyzed and reviewed for possibleimprovements, processes should be analyzed to see ifthere are avenues for improvement or for solving repeatproblems. Work teams should be encouraged to solvethese problems as they arise.

3. This portion of the system will be the basis for tracking andrecognizing opportunities for continuous improvement forthe EMS and for the environmental performance of thecompany. Many well-developed systems fail because theycan’t differentiate individual failure in procedures that areeither not performed correctly or done well fromprocedures that, from a design perspective, do notaccomplish the desired goal.



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Records

ISO 14001 4.5.3 “The organization shall establish and maintain procedures forthe identification, maintenance and disposition ofenvironmental records. These records shall include trainingrecords and the results of audits and reviews.

Environmental records shall be legible, identifiable andtraceable to the activity, product or service involved.Environmental records shall be stored and maintained in sucha way that they are readily retrievable and protected againstdamage, deterioration or loss. Their retention times shall beestablished and recorded.

Records shall be maintained, as appropriate to the system andto the organization, to demonstrate conformance to therequirements of this International Standard.”

Description Records are required to demonstrate compliance with theEMS. They’re collected within the framework of the EMS, andthey record the extent to which the EMS design is performing.Procedures are developed to maintain, identify, collect, index,and store records. Included in the records being maintained bythe system are contractor, procurement, audit, managementreview, and training records necessary for the confirmation ofthe EMS.

Records should be legible and identify the activity, product, orservice involved. Records should include details of non-conformance and corrective actions, records of regulatoryviolations and corrective actions, incident reports and follow-ups, complaints and responses, supplier and contractorinformation, inspection and maintenance records, MSDS, andmonitoring data. Records management under an ISO 14001EMS must be able to prove that the organization is actuallydoing what it says!

Check to see:

Are all the records to bemaintained identified?

Are retention timesdetermined?

Is there a good storageand retrieval system inplace?



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Purpose For the purposes of EMS Registration, or seeking relief underthe EPA’s Self-Policing Policy, a firm must have documentedproof of their activities as they relate to EMS practices. ARegistrar may wish to see some months of systems records inorder to approve the Registration of the EMS to the Standard.

Procedure The retention and maintenance of records associated withyour EMS serve several purposes. Primarily, these recordsare the evidence of an effectively operated EMS. Thisevidence must be shown to registrars and auditors to verifythat your EMS conforms to the ISO 14001 Standard. Also,these records may include procedures that have beenremoved from service which are retained for an operationalhistory of mothballed equipment or to retain operatingexpertise for techniques that have been supplanted. You maychoose to integrate the Record-keeping aspect of your EMSwith other record keeping. Be advised that, since this Record-keeping is an auditable portion of the EMS operation, youshould be sure when you include any record or sets of recordsin this process.

Records can be maintained, as were the documents, in eitherpaper or electronic form. For records in electronic form, goodMIS procedures should be followed. A listing of the files instorage, their format, and their retention time, may be some ofthe considerations that would be made. For paper records,you should establish steps to protect these records such asputting sensitive records in fire-proof cabinets, not storingcrucial records in basements prone to flooding, and the like. Amaster list of stored records should be maintained thatincludes: name of record, why stored, where stored, format ofstorage (paper or electronic, etc.… ), retention time, finaldisposal determination and decision matrix. It is also prudentto maintain a record of those records destroyed, under whoseauthority and the date of destruction.

Some of the records that should be maintained in your EMS



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include:

• Legal and other requirements listing.• Environmental Aspects determination documentation.• Training records.• Inspection and monitoring data.• Calibration and maintenance records for instrumentation.• Non-conformance and corrective actions records and

reports.• Environmental audits and management review

documentation.• Records of emergency response drills.• Contractor and Supplier notifications regarding your

Aspects.

Tips Ø Identify all environmental information required for theoperation of your EMS and determine which recordsshould be maintained under this portion of the Standard.

Ø What are your organization’s capabilities for maintainingthese records? (Electronic media is more efficient for thispurpose where possible.)

Ø Are there process records that might be included in thisRecord-keeping?

Ø Can you easily retrieve any records that are centrallyimportant?

Ø Are your records safe?



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Environmental management system audit

ISO 14001 4.5.4 “The organization shall establish and maintain (a)programme(s) and procedures for periodic environmentalmanagement systems audits to be carried out, in order to:

a) determine whether or not the environmental managementsystem

1. conforms to planned arrangements for environmentalmanagement including the requirements of thisInternational Standard; and

2. has been properly implemented and maintained; and

b) provide information on the results of audits to management.

The organization’s audit programme, including any schedule,shall be based on the environmental importance of the activityconcerned and the results of previous audits. In order to becomprehensive, the audit procedures shall cover the auditscope, frequency and methodologies, as well as theresponsibilities and requirements for conducting audits andreporting results.”

Description An EMS must include a routine systems audit. This auditshould determine compliance with the ISO 14001 EMS, andmay also be combined with regulatory compliance audits,quality audits, energy audits and other forms of managementinquiry if so desired. BUT be careful to ensure that anycombined audit be well conceived. You don’t want a findingabout your quality system to effect the results of yourenvironmental audit or visa versa.

A combined environmental compliance audit and EMS auditmakes the most sense. The requirements of ISO 14001 do notrequire compliance with regulations, but they do require thecommitment to compliance and routine monitoring of yourcompliance status. As a result, compliance is more closelyrelated to EMS auditing than quality auditing. An energy audit



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is also easily fit in. But, combining quality, compliance andEMS audits into a single audit may prove difficult. Logistics,alone, will be troublesome and disruptive to the operation, butthe real issue will be the assembly of adequate audit teamresources to perform a professional audit of those aspects atonce.

Whether or not internal or third party auditors are used, theyshould possess the qualifications outlined in ISO 14012:

1. Expertise in environmental science and technology.

2. Expertise in the technical and environmental aspects offacilities operations.

3. Expertise in environmental law, regulations.

4. Expertise in environmental management systems.

5. Expertise in EMS auditing techniques.

These qualifications are essential for auditors. Any firm shouldbe inquisitive in determining the qualifications of externalauditors. An auditor should be registered with a recognizedenvironmental auditor certification scheme such as theEnvironmental Auditor Registration Association (EARA) inEngland or ANSI/RAB∗ in the United States. Without the aboveareas of expertise, the systems audit will NOT yield operationalinformation that will be useful for the achievement of continualimprovement. Auditors with expertise in quality systems, legalcompliance or other singular portions of the EMS arena will notbe capable of determining whether or not technicalOperational Controls have been effectively established in thesystem's development. This could most certainly becomegrounds for enforcement agencies to rule against the entireEMS audit as illustrating a reasonable “Standard of Care” or"Good Faith Effort".

∗ American National Standards Institute/Registrar Accreditation Board

Auditing

Questions:

Is there an auditing programdeveloped?

How frequently will audits beperformed?

Are the auditors selected,trained and capable?

Are audit proceduresdescribed in the EMSprogram (check 14010,14011and 14012 during this phasefor guidance)?

Is audit record keepingdescribed?



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Purpose External auditing is recommended for ISO 14001 EMS.Further, EPA requirements for their Self-Policing Policy, andStar Track Program includes independent auditing. The neutralvision of the auditor is at the core of this concern. The intent ofauditing is to supply management with better vision from whichthey make decisions. In-house staff may not be comfortabledelivering completely objective information critical enough tobe useful for system modification. This is not at issue with thirdparty auditors. But, one of the best ways to train internal facilitystaff in operating their EMS is to involve staff from onedepartment in the audits of another. This can be performed inconjunction with independent third party auditors to gain"internal" perspective as well as external.

Procedure It is essential to develop procedures that clarify audit scope,audit frequency, auditor qualifications, reporting requirements,follow-up. Two major objectives should be expected from anaudit:

• The determination of compliance with the environmentalmanagement system as outlined by the Objectives andTargets, Aspects, Environmental Management Program,the Environmental Manual, Procedures, and workinstructions, and to check for effective implementation ofthem all.

• Determine if the system is effective in achieving theexpectations of the Policy.

If the system is to be Registered, early inquiry with theRegistrar auditor is important. They may supply informationconcerning their expectations of audit procedures that will aidin the development of the EMS to their interpretation of theStandard, as well as the specificity of the auditors who willRegister it. Special emphasis should be placed on theindividual areas to be considered, i.e. organizational structure,operational and administrative procedures, work instructions,operational controls, process engineering, emergency



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preparedness, and the audit intensity should be clarified.

Prudence mandates Registrars of “quality” to add credence tothe entire process. Combined audits with quality systemsaudits are possible, but separate certifications should bedemanded. Experience has found this procedure to be costeffective, but not systematically or temporally effective.

Tips Ø Focus on objective conformance evidence. Use theStandard as your template for audit protocols.

Ø Discuss audit findings with operational staff during theaudit. This may lead to a better understanding of rootcauses and systemic failures.

Ø Perform audits with a team that has the requisite technical,regulatory, legal, management, and operational expertiseto effectively determine “operational control”.

Ø Consider auditing for EMS conformance along withregulatory compliance. BUT… this will require auditors ofsignificant expertise in BOTH areas. Also, the structure ofthe EMS audit protocol should address some of the legalissues at the heart of any audit.



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Management Review

ISO 14001 4.4.6 “The organization’s top management shall, at intervals that itdetermines, review the environmental management system, toensure its continuing suitability, adequacy and effectiveness.The management review process shall ensure that thenecessary information is collected to allow management tocarry out this evaluation. This review shall be documented.

The management review shall address the possible need forchanges to policy, objectives, and other elements of theenvironmental management system, in the light ofenvironmental management system audit results, changingcircumstances and the commitment to continual improvement.”

Description Management Review is an essential portion of the continualimprovement of the organization’s EMS. The improvementprocess does not end with the establishment of an initialPolicy, realization of initial Objectives, or certification of theEMS to a Standard. Management Review is the essentialelement for systems improvement, along with preventive andcorrective action.

A Management Review of the EMS must be of a scope toinclude all environmental potentialities for organizationalactivities, products, and services. This may include thefinancial impacts of these environmental potentialities and howthe environmental concerns of the firm might relate to businessopportunity.

Purpose The Review must assess the extent of compliance or non-conformance to the EMS Standard, and then review theeffectiveness of Corrective Action. Management Reviewshould also suggest corrective measures to solve problemsidentified in EMS design, intent, or scope. The form of theManagement Review could be a dedicated internal audit of thesystem for “top management”. This Audit and Review will onlybe effective if the participants have the expertise outlined in

Management Review?

Is “top management” involvedin the process?

Are the results beingdocumented?

Is there a follow-up procedurefor action items that resultfrom the review?

Does the review include thefinancial efficacy of theprogram’s activities?



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ISO 14012 for EMS auditors. The report from such a reviewshould be submitted to top management, the MR, andappropriate line management specific to the operation beingreviewed.

Procedure The MR should plan for conducting the required ManagementReview. The agenda should include review of instances ofnonconformance, Corrective Actions, continuousimprovements associated with the EMS, results of complianceand EMS Audits, complaints, results of any pollutionprevention programs, waste minimization programs, and asummation of Measurement and Monitoring results.

The MR, along with the CEO, Director of EH&S, and othersenior management representatives should review the overalleffectiveness of the EMS in meeting the Targets andObjectives of the system. The results of the review should beused to determine modifications to the EMS required forachieving continuous improvement. Follow-up at a later date toverify that the EMS modifications were effective is alsoneeded.

The Review process should:

⇒ Assess whether company personnel have complied withPolicy and Procedures using audit reports. Reviewrecommendations concerning the EMS in Audits and otherreviews and how these might be implemented. Considerthe continued appropriateness of Environmental Aspectsand their rating.

⇒ Review Targets, Objectives, and environmentalperformance indicators to establish their continuedsuitability in light of changing environmental impact andconcerns, regulatory developments, concerns amonginterested parties, market pressures, internalchanges/organizational activity changes, and changes inthe environment. Determine if Targets and Objectives arebeing met.

⇒ Determine if capital resources are adequate for supporting



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the EMS requirements of the firm.

⇒ Review regulatory compliance and whether EMSrequirements have been achieved. Determine root causesof systemic non-conformances.

⇒ Determine if the Operational Controls, Procedures,Corrective Actions, Preventative measures, andContinuous Improvement efforts have resulted inenhanced environmental performance. Document changesthat result in process improvement.

⇒ Determine if energy efficiencies, accounting practices,information management systems are adequate.

⇒ Determine areas of improvement in organizationalstructure, staff expertise, practices, administrative andoperational procedures, training, work instructions, processimprovements, pollution prevention programs, energyutilization, accounting practices which may lead toenvironmental opportunities and increased profit margins.

⇒ Formulate corrective actions, preventative measures as aresult of the review of systems nonconformance, and verifyCorrective Actions are effective and appropriate.



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Tips Ø Include people with the right information as well as peoplewho can make the decisions.

Ø Combine the management Review with other meetings.

Ø Document the results of the management review andmaintain records of the meeting.

Ø Any changes since the last management review should beconsidered as to how they might impact the actual orpotential environmental aspects of the firm.

Ø Someone must be responsible for follow-up.



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Implementation After the EMS has been developed, implementation follows.To demonstrate compliance with EMS Standards, organizationemployees need to demonstrate an understanding of theirresponsibilities relative to the EMS system. A first step inimplementation could be to distribute EMS procedures andindividual work instructions to the staff during training. Theyshould have been reviewed by employees during proceduraldevelopment. Training should point out individual requirementsunder the EMS, as well as organizational requirements toachieve Registration if applicable. Training needs of theemployees should have been documented in the roles andresponsibilities and determined by the organizational structure.

Implementation of an EMS to any Standard must be carefullyprepared and effected. Because the implementation processmay require a significant portion of the organization resourcesfor a period of time, it may be best to have a steeringcommittee oversee this phase in a larger organization. Forsimplicity’s sake, this should be the Project Team from EMSdesign.

For effective implementation a simplified design which limitsformalization of the system will be easiest. Personnel must bemotivated commensurate to their expected contribution to EMSdevelopment and implementation. A functional approach thatfocuses on the following will be most effective:

1. Are there significant environmental aspects and riskscovered by procedures and instructions, and are thesedocumented?

2. Are the systems requirements appropriate to the natureand significance of the environmental aspects in thesphere of influence of the specific employee?

3. Have successful historic practices been included in theEMS design?

4. Have positive “corporate culture” environmental issuesbeen optimized in the implementation process?

Implementation will ONLY be effective if those who need to act



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Integration

have been motivated to become involved. The effort fromindividual employees should directly relate to theenvironmental impacts of their operational responsibilities.Training should promote this awareness. The individual shouldalso have the time required to actually perform tasks that theyhave been assigned relating to the EMS. Performance shouldbe acknowledged and rewarded.

Full integration of the EMS with other management tools isessential, and a foundational concept of any EMS approach.This integration may be in the form of sharing organizationalvalues, uniformity of control mechanisms, standard workpractices, and administrative procedures. Specifically,integration should be seriously considered with financialaccounting practices and life cycle assessment forachievement of full cost accounting. Even the mostrudimentary applications of this integration can lead tosignificant reductions in costs, as well as significant increasesin the capabilities of executive management to “see”environmental issues in their full light through more accuratefinancial measures of specific activities.

Strategic Environmental Management elements that should beintegrated with existing management practices:

◊ Policies

◊ Allocation of resources

◊ Operational Controls mechanisms

◊ Information systems

◊ Training programs

◊ Staff development

◊ Organizational structure

◊ Responsibilities/accountability

◊ Staff Review and Compensation



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◊ Measurement/Monitoring systems

◊ Documentation/Communication/reporting

Procedural/integration issues, because they are “owned” byspecific managers who may be involved in the EMSdevelopment process, may best be handled by third party EMSdevelopers. Managers often become defensive for thoseprocedures under their control, and may be wary ofrelinquishing control to others. An objective third party may bebest capable of identifying where combining practices are tobe used.

ISO 14001 EMS implementation is easily understood whenone spends time with the concepts. All become enthusiasticabout the enhanced control of operations, the clarity ofpurpose and responsibility, and the support of topmanagement throughout the organization. To paraphrase Dr.Benjamin Spock, the world-renowned pediatrician, an EMS is“Reasonable guidelines, reasonably enforced”. Dr. Spockwould consider an ISO 14001 EMS “good parenting” of theenvironmental function.

During implementation, both top management anddepartmental team members play crucial roles. Sinceimplementation on the shop floor requires constant attention,the departmental team members must be relied on to supplythat effort, support and motivation. This is especially importantwhere employees' regular job functions absorb the bulk of theirtime, and they have little time to devote to the implementationof the EMS. If so, new practices, procedures, and personnelshould be used so that all members of the production andmanagement team can fully support their portion of the EMS.There will always be the traditional resistance to change. Toensure success, the following formula is effective:

• Commitment of top management

• Financial support

• Motivated and supporting department team



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• Ample on-the-job training and information

After implementation, actual environmental performanceshould be recorded and assessed. When the internal stafffeels confident that the system is working well, then a third-party auditor should be considered. Once this first level ofexternal auditing has been satisfied, then the EMS can be saidto be effective. Only certification remains, where desired.

Questions to Ponder During Management Reviews

• Did we achieve our objectives and targets? (If not, why not?)Should we modify our objectives?

• Is our environmental policy still relevant to what we do?

• Are roles and responsibilities clear and do they make sense?

• Are we applying resources appropriately?

• Are the procedures clear and adequate? Do we need others?Should we eliminate some?

• Are we monitoring our EMS (e.g., via system audits)? What dothe results of those audits tell us?

• What effects have changes in materials, products, orservices had on our EMS and its effectiveness?

• Do changes in laws or regulations require us to change someof our approaches?

• What stockholder concerns have been raised since our lastreview?

• Is there a better way? What else can we do to improve?



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The Registration Process

What gets Registered?

ISO 14001 EMS Registration will cover the environmentalmanagement system of a particular business operation. Asingle certificate can cover a specific site of a company, aspecific facility, several sites or facilities, or portions of sites orfacilities. For example, one ISO 14001 certificate might registera business unit that encompasses six different sites in sixdifferent states, and a portion of a site in a seventh state. Ifthese sites are audited at the same time against the sameStandard, they can be covered under a single certificate.

However, it is unlikely that a company will receive six differentcertificates for six different production units at a single site,since most environmental aspects of a facility are closelyrelated to a site. This differs from the ISO 9000 series ofquality standards. The quality management system forproduction of one product may be covered under onecertificate, while other processes or products at the same sitecould be covered by subsequent certificates.

A certificate of registration is usually valid for three years,though this can vary depending on the certification body.Some Registrars provide indefinite certificates, pendingcontinuing successful surveillance visits. In most cases,certification bodies conduct surveillance audits on a six-monthschedule. When a certificate expires, the Registrar conductseither a complete reassessment at the end of the certificationperiod or an assessment that is somewhere between asurveillance visit and a complete reassessment.

“Accreditation”, “Certification”, and“Registration”

The following distinctions among the three terms are derivedfrom the International Organization for Standardization:

⇒ Certification is a procedure by which a third party giveswritten assurance that a product, process, or serviceconforms to specified requirements. Certification to ISO14001 stipulates that a company is in compliance with anenvironmental management system (EMS) that meets all



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requirements of ISO 14001.

⇒ Accreditation is a procedure by which an authoritativebody gives formal recognition that a body or person iscompetent to carry out specific tasks. With regard to ISO14001, accreditation means that a body is authorized togrant certification to a company that it has successfullyassessed as meeting ISO 14001 EMS requirements and ashaving the processes in place to maintain that system.

⇒ Registration is a procedure by which a body indicatesrelevant characteristics of a product, process, or serviceand then includes or registers the product, process, orservice in a publicly available list.

In the United States the term "registration" is usedinterchangeably with "certification" in the context ofmanagement system standard conformance. In Europe,environmental management systems certification is the properterm, rather than environmental management systemsregistration, which is the US terminology.

Registrars and Registration

Environmental management system registration is theassessment and audit of an organization's environmentalmanagement system by a third party, likely to be known as acertification body or a "Registrar" in US terminology. TheRegistrar evaluates an environmental management system forconformity to ISO 14001.

The evaluation will include an examination of the company'senvironmental policy, environmental management system andits documentation, EMS auditing program and procedures, andenvironmental records. It will include a thorough on-site auditto determine conformance to the ISO 14001 Standard. Whena company's environmental management system is verified toconform to the requirements of ISO 14001, the Certifier willissue a certificate describing the scope of the company'senvironmental management system that has been certified.The certification is then listed in a register or directory that isavailable to the public. The Registrar allows the company todisplay the Registrar’s mark on advertising, stationery, etc., asevidence that it has achieved certification.

Overview ofthe Typical

EMS RegistrationProcess:

1. Application

2. EMS Documentation

3. On-site EMS ReadinessReview

4. Registration Audit

5. RegistrationDetermination

6. Surveillance



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Self Certification /Self Declaration

One of the key battles of the ISO 14000 series draftingprocess was whether companies can "self-certify," or must useexternal registrar auditors to verify compliance with ISO 14001.European countries pushed for an EMS-style system wherecompanies are externally audited, and reports of those auditsare provided to the public. However, that position did notprevail in the ISO arena: companies can perform their ISO14001 audits internally and declare that they are incompliance. Many feel that such "self-certifications" will haveno credibility. However, self-certification will satisfy the ISOstandard, and may offer certain advantages for firms who wishto develop internal practices that they do not want reviewed byexternal Registrars. It is quite possible for such a firm todevelop an ISO 14001 EMS, Self-Declare, and retainsignificant control over external review of the system.

While third-party certification and self-declaration areacceptable for ISO 14001, both types of assessments haveadvantages, and experts are divided on their relative values.Independent assessment potentially provides managementwith a less biased opinion and self-assessment providesgreater depth of knowledge on the subject.

Statistical investigation notes that the perceived value of theISO 14001 EMS lies in the process for awarding the certificate.That process entails investigation by qualified independentauditors using the Standard as a uniform tool and not in adiscretionary manner. The criteria for auditing and auditor skillsmust be consistent to have national and international value forcertified audits. But, there is also significant skepticismregarding the universal recognition of certifications. One mustbe extremely careful regarding the selection of a Registrar.

Because ISO 14001 is an international standard developed byconsensus with scores of countries participating, it is acceptedworldwide. Therefore, a certificate issued by an accreditedcertification body should be acceptable to all customers of afirm worldwide. However, acceptance depends on mutualrecognition among accreditation bodies. Mutual recognitionmeans that a company's certificate awarded by an accreditedcertification body in one nation will be accepted by theaccreditation agency (and by all customers) in other nations.Mutual recognition is an unsettled issue, and agreements arebeing developed in this area.

Information sources toconsider:

• audit results

• internal suggestions

• externalcommunications

• progress on objectivesand targets

• other environmentalperformance measures

• reports of emergencies,spills, other incidents

• new or modifiedlegislation andregulations

• new scientific/technicaldata on materials andprocesses used by theorganization

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