environmental management system — guide for the phased ... · 58 a.2 emas potential variations...
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Document type: International Standard Document subtype: Document stage: (30) Committee Document language: E M:\dms\dgie\xdom384.2\DOC\TC207 SC1\WG3\ISO 14005\CD2\avant vote\ISO_CD2 draft_14005_(SC FINAL)V2clean.doc STD Version 2.2
ISO/TC 207/SC 1/WG 3 N 51 Date: 2008-02-14
ISO/CD 14005.2
ISO/TC 207/SC 1/WG 3
Secretariat: SCC
Environmental management system — Guide for the phased implementation of an environmental management system — Including the use of environmental performance evaluation
Système de management environnemental — Guide pour la mise en place par phases d'un système de management environnemental — Incluant l'évaluation de la performance environnementale
Warning
This document is not an ISO International Standard. It is distributed for review and comment. It is subject to change without notice and may not be referred to as an International Standard.
Recipients of this draft are invited to submit, with their comments, notification of any relevant patent rights of which they are aware and to provide supporting documentation.
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Contents Page 15
Foreword .............................................................................................................................................................5 16
Introduction.........................................................................................................................................................6 17
1 Scope......................................................................................................................................................7 18
2 Normative references............................................................................................................................7 19
3 Terms and definition .............................................................................................................................7 20
4 Phased implementation process .......................................................................................................11 21 4.1 General .................................................................................................................................................11 22 4.2 The phased implementation process ................................................................................................11 23 4.3 The importance of support, commitment and involvement from management and 24
staff .......................................................................................................................................................12 25
5 Securing management support and commitment for the phased 26 implementation of an EMS.............................................................................................................13 27
5.1 Intention ...............................................................................................................................................13 28 5.2 Methodology ........................................................................................................................................13 29 5.2.1 Involvement of top management .......................................................................................................14 30 5.2.2 Identifying and selecting a project ....................................................................................................14 31 5.2.3 Planning the selected project ............................................................................................................14 32 5.2.4 Implementation of the selected project.............................................................................................15 33 5.2.5 Management review ............................................................................................................................15 34
6 Overview of activities..........................................................................................................................17 35
7 Tools that support the EMS................................................................................................................20 36 7.1 Environmental Communications .......................................................................................................20 37 7.2 Resources, roles, responsibility and authority ................................................................................24 38 7.3 Competence, training and awareness...............................................................................................25 39 7.4 Records ................................................................................................................................................27 40 7.5 Documentation and Documentation control ....................................................................................28 41
8 Developing and implementing an EMS .............................................................................................31 42 8.1 Preparing and implementing an Environmental Policy...................................................................31 43 8.2 Identifying your significant Environmental Aspects .......................................................................32 44 8.3 Identifying your legal and other requirements.................................................................................35 45 8.4 Evaluating Compliance with your Legal and Other Requirements ................................................36 46 8.5 Setting Objectives and Targets and establishing program ............................................................37 47 8.6 Developing Performance Indicators..................................................................................................39 48 8.7 Controlling the Environmental Impacts of your Operations...........................................................41 49 8.8 planning for and Responding to Emergencies ................................................................................43 50 8.9 Monitoring and Measuring Progress.................................................................................................44 51 8.10 Internal Audits .....................................................................................................................................46 52 8.11 Managing When things Don’t Go As Planned ..................................................................................48 53 8.12 Management Review of Progress and Performance .......................................................................50 54
Annex A (informative) EMAS..........................................................................................................................53 55 A.1 EMAS statement ..................................................................................................................................53 56 A.1.1 Intention ...............................................................................................................................................53 57 A.2 EMAS potential variations with text in ISO 14005 as its stands.....................................................55 58 A.2.1 Scope of an EMS .................................................................................................................................55 59 A.2.2 Legal compliance ................................................................................................................................55 60
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A.2.3 Initial review .........................................................................................................................................55 61 A.2.4 Significant environmental aspects ....................................................................................................55 62 A.2.5 Performance/continual improvement................................................................................................56 63 A.2.6 Employee involvement........................................................................................................................56 64
Annex B (Informative) Cross Reference Table..............................................................................................57 65
Bibliography......................................................................................................................................................61 66 67
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Foreword 68
ISO (the International Organization for Standardization) is a worldwide federation of national standards 69 bodies (ISO member bodies). The work of preparing International Standards is normally carried out 70 through ISO technical committees. Each member body interested in a subject for which a technical 71 committee has been established has the right to be represented on that committee. International 72 organizations, governmental and non-governmental, in liaison with ISO, also take part in the work. ISO 73 collaborates closely with the International Electrotechnical Commission (IEC) on all matters of 74 electrotechnical standardization. 75
International Standards are drafted in accordance with the rules given in the ISO/IEC Directives, 76 Part 2. 77
The main task of technical committees is to prepare International Standards. Draft International 78 Standards adopted by the technical committees are circulated to the member bodies for voting. 79 Publication as an International Standard requires approval by at least 75 % of the member bodies 80 casting a vote. 81
Attention is drawn to the possibility that some of the elements of this document may be the subject of 82 patent rights. ISO shall not be held responsible for identifying any or all such patent rights. 83
ISO 14005 was prepared by Technical Committee ISO/TC 207, Environmental management, 84 Subcommittee SC 1, Environmental management systems. 85
This second/third/... edition cancels and replaces the first/second/... edition (), [clause(s) / subclause(s) 86 / table(s) / figure(s) / annex(es)] of which [has / have] been technically revised. 87
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Introduction 89
The purpose of this standard is to encourage and guide organisations, especially small to medium-90 sized enterprises (SMEs), to develop and implement an environmental management system that 91 meets the requirements of ISO 14001. 92
Many organisations have profited from having a formal environmental management system. But many 93 more organisations, especially small to medium-sized enterprises (SMEs), do not have such a system 94 even though it could benefit them greatly. Taking time and money away from recognised business 95 needs is a major step for any organisation. This standard provides a simpler, structured way for an 96 organisation to start to develop an environmental management system. It uses a phased approach to 97 building an environmental management system that can grow to meet the requirements of the 98 international standard for environmental management systems, ISO 14001. 99
A phased approach offers several advantages. Users can evaluate how the time and money put into 100 an EMS provides a return. They can see how environmental improvements help to reduce costs, 101 improve their community relations, assist them in demonstrating compliance with environmental legal 102 and other requirements, and help them live up to customer expectations. They can track the benefits 103 of their EMS while they build their system step by step, adding or expanding elements as they provide 104 value to the organisation. When the scope of the EMS includes all of the organisation�s activities, 105 products and services that it wishes to cover and these are addressed using all the elements of ISO 106 14005 to their full extent, the organisation should have a system that meets the requirements of ISO 107 14001. 108
ISO 14001, the most widely accepted international EMS standard, is a structured approach to 109 managing an organisation�s environmental matters. It is consistent with, and forms the basis of, many 110 other regional management system approaches such as the management system requirements of the 111 European Union�s Eco-Management and Audit Scheme (EMAS), the Japanese EcoAction 21 112 programme and others. 113
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114
Environmental management system — Guide for the 115
phased implementation of an environmental management 116
system — Including the use of environmental performance 117
evaluation 118
1 Scope 119
This International Standard provides guidance for all organisations, but particularly small and medium-120 sized enterprises, on the phased development, implementation, maintenance and improvement of an 121 environmental management system. It also includes advice on: 122
- the integration and use of environmental performance evaluation techniques, 123
and 124
- the integration of such a management system with other management systems, where 125 appropriate. 126
The guidelines in this International Standard are applicable to any organisation regardless of its level 127 of development, the nature of the activities undertaken or the location at which they occur. 128
This standard has not to be used for interpretation of ISO 14001. 129
2 Normative references 130
The following referenced documents are indispensable for the application of this document. For dated 131 references, only the edition cited applies. For undated references, the latest edition of the referenced 132 document (including any amendments) applies. 133
For this standard no normative references apply. 134
3 Terms and definition 135
For the purpose of this document, following terms and definitions apply, 136
3.1 137 auditor 138 person with the demonstrated personal attributes and competence to conduct an audit 139 NOTE The relevant personal attributes for an auditor are described in ISO 19011. 140 [ISO 9000:2005, 3.9.9] 141
3.2 142 audit findings 143 results of the evaluation of the collected audit evidence against audit criteria 144
NOTE Audit findings can indicate either conformity or nonconformity with audit criteria or opportunities for 145 improvement 146
[ISO 9000:2005, 3.9.5] 147
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3.3 148 audit programme 149 set of one or more audits planned for a specific time frame and directed towards a specific purpose 150
NOTE An audit programme includes all activities necessary for planning, organizing and conducting the audits. 151
[ISO 9000:2005, 3.9.2] 152
3.4 153 continual improvement 154 recurring processes of enhancing the environmental system in order to achieve improvements in 155 overall environmental performance consistence with the organisation�s environmental policy 156
[ISO 14001:2004, 3.2] 157
3.5 158 corrective action 159 action to eliminate the cause of detected nonconformity 160
[ISO14001:2004, 3.3] 161
3.6 162 document 163 information and its supporting medium 164
NOTE 1 The medium can be paper, magnetic, electronic or optical computer disc, photograph or 165 master sample, or a combination thereof. 166 NOTE 2 Adapted from ISO 9000:2000, 3.7.2.[ISO14001:2004, 3.4] 167
3.7 168 environment 169 surroundings in which an organisation operates, including air, water, land, natural resources, flora, 170 fauna, humans and their interrelation 171
NOTE Surroundings in this context extend from within an organisation to the global system. 172
[ISO14001:2004, 3.5] 173
3.8 174 environmental aspect 175 element of an organisation�s activities or products or services that can interact with the environment 176
NOTE A significant environmental aspect has or can have a significant environmental impact. 177
[ISO14001:2004, 3.6] 178
3.9 179 environmental impact 180 any change to the environment , whether adverse or beneficial, wholly or partially resulting from an 181 organisation�s environmental aspects 182
[ISO14001:2004, 3.7] 183
3.10 184 environmental management system EMS 185 part of an organisation�s management system used to develop and implement its environmental policy 186 and manage its environmental aspects 187
NOTE 1 A management system is a set of interrelated elements used to establish policy and 188 objectives and to achieve those objectives. 189 NOTE 2 A management system includes organisational structure, planning activities, responsibilities, 190 practices, procedures, processes and resources. 191 [ISO14001:2004, 3.8] 192
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3.11 193 environmental objective 194 overall environmental goal, consistent with the environmental policy, that an organisation sets itself to 195 achieve 196
[ISO14001:2004, 3.9] 197
3.12 198 environmental performance 199 measurable results of an organisation�s management of its environmental aspects 200
NOTE In the context of environmental management systems, results can be measured against the 201 organisation's environmental policy, environmental objectives, environmental targets and other 202
environmental performance requirements. 203
[ISO14001:2004, 3.10] 204
3.13 205 environmental performance evaluation EPE 206 process to facilitate management decisions regarding an organisation�s environmental performance by 207 selecting indicators, collecting and analysing data, assessing information against environmental 208 performance criteria, reporting and communicating, and periodically reviewing and improving this 209 process. 210
[ISO14031:1999, 2.9] 211
3.14 212 environmental performance indicator EPI 213 specific expression that provides information about an organisation�s performance 214
[ISO14031:1999, 2.10] 215
3.15 216 environmental policy 217 overall intentions and direction of an organisation related to its environmental performance as formally 218 expressed by top management 219
NOTE The environmental policy provides a framework for action and for the setting of environmental objectives 220 and environmental targets. 221
[ISO14001:2004, 3.11] 222
3.16 223 environmental target 224 detailed performance requirement, applicable to the organisation or part thereof, that arises from the 225 environmental objectives and that needs to be set and met in order to achieve those objectives 226
[ISO14001:2004, 3.12] 227
3.17 228 interested party 229 person or group concerned with or affected by the environmental performance of an organisation 230
[ISO14001:2004, 3.13] 231
3.18 232 internal audit 233 systematic, independent and documented process for obtaining audit evidence and evaluating it 234 objectively to determine the extent to which the environmental management system audit criteria set 235 by the organisation are fulfilled 236
NOTE In many cases, particularly in smaller organisations, independence can be demonstrated by the freedom 237 from responsibility for the activity being audited. 238
[ISO14001:2004, 3.14] 239
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3.19 240 management performance indicator MPI 241 environmental performance indicator that provides information about the management efforts to 242 influence an organisation�s environmental performance 243
[ISO14031:1999, 2.10.1] 244
3.20 245 nonconformity 246 non-fulfilment of a requirement 247
[ISO 9000:2005, 3.6.2] 248
3.21 249 operational performance indicator OPI 250 environmental performance indicator that provides information about the environmental performance 251 of an organisation�s operation 252
[ISO14031:1999, 2.10.2] 253
3.22 254 organisation 255 company, corporation, firm, enterprise, authority or institution, or part or combination thereof, whether 256 incorporated or not, public or private, that has its own functions and administration 257
NOTE For organisations with more than one operating unit, a single operating unit may be defined as 258 an organisation. 259
[ISO14001:2004, 3.16] 260
3.23 261 phased implementation 262 implementation of a module which has measurable outputs which can be used to demonstrate the 263 progress towards ISO 14001 264
3.24 265 preventive action 266 action to eliminate the cause of a potential nonconformity 267
[ISO14001:2004, 3.17] 268
3.25 269 prevention of pollution 270 use of processes, techniques, materials, products, services or energy to avoid, reduce or control 271 (separately or in combination) the creation, emission or discharge of any type of pollutant or waste, in 272 order to reduce adverse environmental aspects. 273
NOTE Prevention of pollution can include source reduction or elimination, process, product or service 274 changes, efficient use of resources, material and energy substitution, reuse, recovery, recycling, 275 reclamation and treatment. 276
[ISO14001:2004, 3.18] 277
3.26 278 procedure 279 specified way to carry out an activity or a process 280
NOTE 1 Procedures can be documented or not. 281 NOTE 2 Adapted from ISO 9000:2000, 3.4.5. 282 [ISO14001:2004, 3.19] 283
3.27 284 record 285 document stating results achieved or providing evidence of activities performed 286
NOTE Adapted from ISO 9000:2000, 3.7.6. 287
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[ISO14001:2004, 3.20] 288
4 Phased implementation process 289
4.1 General 290
An organisation may decide to apply a systematic approach to managing its environmental aspects. 291 This may be triggered by the need to solve an individual problem or to capitalise upon a specific 292 opportunity. Alternatively the organisation may be seeking to implement an environmental 293 management system (EMS) that enables it to manage its full range of environmental aspects, in order 294 to meet the requirements of ISO 14001. 295
There are many potential benefits to be gained by an organisation from managing its environmental 296 aspects. Organisations may however be deterred from applying a systematic approach to 297 environmental management because they wrongly perceive this as being an inflexible, limiting, 298 bureaucratic or costly process. They may also be overwhelmed by the apparent size of the task. 299
The model outlined in this standard has been developed to help an organisation to implement an EMS 300 in a logical, step-by-step way whilst growing the extent and scope of the system, through time, in line 301 with the objectives of the organisation and the resources available. 302
A number of key terms are used throughout this standard. The first time they appear in the text, they 303 are highlighted in bold italics. These are consistent with the terms used in other members of the ISO 304 14000 series family of standards and particularly with ISO 14001:2004, ISO 14004:2004 and ISO 305 14031:1999. In order to provide a greater understanding of their meaning an explanatory glossary has 306 been provided at the end of this document. 307
4.2 The phased implementation process 308
The model has been designed to provide structured guidance regarding the sequence of activities that 309 an organisation might follow in order to implement an EMS. In this respect the process applies the 310 plan-do-check-act (PDCA) approach as used in ISO 14001. This enables the organisation to follow a 311 logical progression of actions which will enable it to achieve its planned outputs. 312
The adoption of a phased approach, in a linear form as laid out in this standard, may suit organisations 313 that have not previously adopted a systematic approach to managing their environmental issues. 314
Organisations may consider alternative approaches if they have to meet specific requirements such as 315 demonstrating legal compliance, minimising the environmental impacts created by their suppliers, 316 meeting particular discharge limits or performance standards or have other management systems in 317 place. Alternative approaches may be based on the selection of a particular module or parts 318 (elements) of module that may be implemented consecutively or concurrently to achieve a specific 319 requirement or to meet the requirements of ISO 14001. 320
The process also allows the flexibility for an organisation to grow their EMS by increasing the range of 321 activities and environmental aspects covered by the system as the organisation becomes more 322 familiar with the EMS process, as internal support builds and as resources allow. 323
In selecting its approach the organisation should consider the reasons for implementing an EMS and 324 the intended scope of that EMS, as well as the human, financial and other resources it has available to 325 support its approach. These may limit its ability to adopt a phased approach and force the 326 organisation to adopt an alternative approach. 327
Organisations adopting a phased approach to implementing their EMS may do so in a planned and 328 systematic manner. An implementation plan should be developed that identifies the approach to be 329 adopted, the timescale in which it is to be achieved, the resources required, roles and responsibilities 330
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of those implementing the plan, records required and the methods by which progress can be 331 consistently monitored and measured. Progress may be measured in terms of achievement of the 332 implementation outcomes specified at the end of each module and compliance with the 333 implementation plan. The phased implementation process also recommends the organisation evaluate 334 its progress towards implementing ISO 14001. 335
Measuring progress towards implementing ISO 14001 is necessary to ensure the efficient use of 336 resources and achieve the organisations objective. 337
4.3 The importance of support, commitment and involvement from management and 338 staff 339
In order to successfully implement an effective EMS which adds value to the organisation�s activities, it 340 is essential to secure and maintain support, commitment and involvement from management and staff. 341 However, this is rarely achieved in one step. More usually, support and commitment grows as people 342 become involved in the process and begin to benefit from the rewards that can come from managing 343 their impacts on the environment. 344
Management commitment may be reflected in statements of support, such as a policy, but must be 345 followed up by making available the necessary human, financial and other resources to support EMS 346 implementation. 347
Those working for the organisations behalf must be motivated to participate in and contribute to the 348 implementation process. Participation and contribution may, amongst other things, take the form of 349 attending meetings, providing suggestions and using their initiative to promote the understanding and 350 acceptance of the phased implementation process among their peers. 351
It may be that sufficient support and commitment already exists within the organisation to at least start 352 the EMS implementation process. If however this is not the case, section 5 of this standard outlines a 353 possible approach that could be applied to gain sufficient support and commitment to begin 354 implementing an EMS. 355
4.4 How to use this standard 356
This standard is divided into four key sections (5, 6, 7 and 8). 357
Section 5 provides an overview of how an EMS approach can be applied to environment related 358 projects. Following the approach outlined in section 5 should provide an organisation with 359 demonstrable benefits which will help to secure sufficient internal commitment and support for 360 environmental management activities to be able to implement an EMS which meets the full 361 requirements of ISO14001. 362
It may be that the organisation decides to conduct several projects, either at the same time or 363 sequentially, in order to secure sufficient commitment and support or to progressively build its level of 364 environmental action. Alternatively, the organisation may decide that it wishes to immediately start 365 implementing an ISO14001 compliant EMS. In this situation the organisation can move directly to use 366 sections 6, 7 and 8. However, the organisation may still find it useful to read and refer to the guidance 367 provided in section 5 throughout this process. 368
Section 6 provides a tabular overview of the activities, organised into rows, required to implement an 369 EMS. Their sequence when reading down the table approximately follows the Plan-Do-Check-Act 370 model referred to in section 4.2. In addition, reading across each row suggests a logical series of steps 371 that can be taken to carry out each activity. It is however important to note that implementing an EMS 372 is not a linear process. It does in fact require achievements in some activities to provide inputs to steps 373 in other activities. it is therefore unlikely that an organization will be able to progress sequentially, step 374 by step, in the order shown in the table. 375
When reviewing section 6, many organisations will be able to identify a number of steps that they have 376 already taken, often for reasons other than environmental ones (for example cost savings, responding 377
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to customer requirements, etc). The extent to which this is true will vary from organisation to 378 organisation. Carrying out such a review enables an organisation to identify what steps have already 379 been taken to support the implementation of an EMS and to recognise that some progress has in fact 380 already been made. Demonstrating in this way that the organization has already made progress 381 towards implementing an EMS also helps to build support and commitment to expand the activities to 382 meet all of the requirements of ISO14001. In addition, this review also shows the organisation the 383 extent of the task remaining and an indication of the likely effort required to complete the EMS 384 implementation. 385
Section 7 outlines some tools which will be required to support the EMS implementation. These tools 386 will be required to varying extents at all stages of the EMS implementation and the extent to which 387 these tools are required will grow as the EMS develops. Consequently they do not easily fit within the 388 PDCA process outlined in section 6. They have therefore been organised into their own section. 389
The tools themselves need to be developed as part of the EMS implementation process. As in section 390 6 therefore, they are organised into rows of logical steps which indicate how they can be developed 391 and used. 392
Section 8 expands upon the steps outlined in section 6 by suggesting ways in which these might be 393 achieved. 394
5 Securing management support and commitment for the phased implementation of 395 an EMS 396
5.1 Intention 397
Development and implementation of an Environment Management System (EMS) in an organization 398 is a process which usually generate benefits, but may also require resources , energy and probably 399 some important changes. Experience shows that this process is unlikely to be successful if it has not 400 received sufficient support and commitment from top management and employees . Indeed, it is often 401 difficult, if not impossible, even to start the EMS implementation process without some degree of 402 support and commitment from within the organization. 403 404 Before starting to implement an EMS and in order to secure new, or strengthen existing, commitment, 405 an organization may find it helpful to run a limited scope project which would allow it to become 406 familiar, with the basic constituents of an EMS and to experience some of the benefits that can 407 generated by managing environmental issues. 408 409 This could be done by considering a small project focusing on just one, or a limited number of, 410 environmental issues of particular and immediate interest to the organization. For example there may 411 be a specific waste stream for which disposal is costly or difficult, there may be regulatory 412 requirements which have to be addressed, the organization may have high raw material or energy 413 costs which require reduction or there may be improvements in pollution control measures which could 414 enhance relations with local communities or customers. 415 416 The number of issues considered and the extent to which they are addressed or resolved may be 417 progressively increased as tangible benefits are secured and additional resources are made available. 418
5.2 Methodology 419
The steps described in this section represent the basic constituents of an ISO 14001 type EMS. They 420 follow the PDCA model: 421 422
-P= PLANNING: identify and select a project and prepare a preliminary environmental action plan 423 -D= DOING : implement the action plan including assigning roles and responsibilities 424 -C= CHECKING : evaluating the achievements 425 -A= ACTING : reviewing the process and deciding further action in a management review 426
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5.2.1 Involvement of top management 428
It is essential to obtain the involvement of people within the organization who have the authority to 429 ensure that action is taken and who have control over the resources needed to support the successful 430 implementation of the EMS. Such people are typically seen as top management. It is important that it 431 is clearly understood by these people that their commitment and support is important and that it is 432 communicated to others within the organization. 433 434 In order to provide a focal point of the EMS or environmental project, it is good practice for top 435 management to appoint a �project champion�. When implementing an EMS that meets the 436 requirements of ISO 14001, this person is known as the management representative. For the 437 purposes of the guidance given in this standard, we will use the term management representative to 438 also mean �project champion� depending upon whether we are talking about implementing a fully 439 ISO14001 compliant EMS or a smaller scale environmental project. 440 441 5.2.2 Identifying and selecting a project 442
In order to start deciding which environmental project(s) might generate benefits which would 443 encourage commitment and support, it can be helpful to collect information on a wide range of 444 environmental issues facing the organization. This might include regulatory compliance, environment 445 related complaints, obvious negative impacts on the environment (smoke, odours, water pollution, 446 etc), costs associated with energy, waste, water and raw materials usage, requests from customers, 447 suggestions from staff, or the views of other or interested parties, etc. 448 449 It is often useful to conduct an initial environmental review or the organizations activities, products and 450 services in order to get a complete picture of the extent to which the organization can impact upon the 451 environment. This can help the organization to identify which project(s) may be of greatest potential 452 value to the organization. In addition, conducting such a review would also provide a valuable 453 indication of the likely scope and extent of implementing an ISO14001 compliant EMS. 454 455 The selected project should of sufficiently limited scope to be manageable with limited resources but 456 also be able to produce demonstrable value to the organization in order to secure support for further 457 environmental projects or the implementation of an ISO 14001 compliant EMS) a full EMS. 458 459 Attention should be given to the potential level of the required effort, resources and return on 460 investment including potential benefits and opportunities. The selected project with its defined scope, 461 expected benefits, and necessary budget and potential fall backs should be submitted to top 462 management in order to secure its approval. 463 464 465 5.2.3 Planning the selected project 466
Before starting work on the selected project it is good practice to prepare an action plan. This may be 467 very short, especially for small organizations, but it should at least briefly outline what the project is 468 intended to deliver, why this will be of value to the organization and how it can be achieved. The plan 469 may also include expected costs. 470 471 More extensive plans should involve the management of all activities included in the scope of the 472 project. 473 It may start by conducting a review in order to identify and analyse: 474
o the main legal environmental requirements applicable to the organization activities, or product 475 or services included in the scope of the project; some consideration may also be given to 476 other requirements (for example: contractual requirements) 477
o the main impact on the environment of those activities or product or services, with the sources 478 of those impacts (those activities, products and services are called environmental aspects in 479 ISO 14001) 480
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In doing so, the organization may look in permits delivered by authorities and information available 481 from trade associations concerning discharges to air, water, wastes, soil contamination, harmful 482 substances use and production and consider views of interested parties 483 484 It is not expected that the review should be exhaustive but it should be honest and focus on key 485 elements in order to provide a reliable assessment of the value that an EMS could add to the 486 organization. 487 It may be necessary to perform some quantitative evaluation of the environmental aspects and the 488 costs, where such information does not already exist, in order to facilitate the rest of the methodology : 489 tons of wastes, cubic meters (or gallons) of liquid effluents, money lost as potentially recoverable 490 product or spent for disposal, number of complaints, composition of the effluents�. Those figures are 491 called performance indicators; it is practical to express them per level of activity (ton of finished 492 product). 493 494 Following this, goals for improvement (called objectives and targets) should be identified; for example : 495 the reduction of non conformities, decrease of harmful discharges)_The progress goals should be 496 quantified as much as possible using the indicators described just above. A prioritization of goals is 497 necessary taking in consideration business operations, available resources, goals of management, 498 and other issues concerning the organization. 499 500 The action plan should eventually define: 501
- the actions necessary to reach these goals 502 - the corresponding resources (human and financial) 503 - time scales ; in particular, a precise time limit should be set up for the completion of the project 504 - adequate responsibilities for its implementation 505
506 The action plan should be submitted to top management for approval to continue with its 507 implementation. 508 509 5.2.4 Implementation of the selected project 510
Responsibilities should be assigned to specific persons in the organization and adequate resources 511 provided according to the specifications of the action plan. All the actions included in the plan should 512 be implemented; additional training may be required for an efficient achievement of some of them. 513 514 Proper attention should be given to the operational controls and procedures to be sure 515 that they will be performed according to the plan. 516 Progress against the chosen indicators may be assessed periodically with the personnel involved in 517 operational activities included in the project in order to examine: 518
-progress of indicators 519 -resources and expenditures 520 -possible delays 521 -other deviations from the action plan. 522
Adequate corrective actions should be taken if necessary. 523 5.2.5 Management review 524
When the action plan has been fully implemented (preferably at the end of the period indicated in the 525 plan), top management should review the process and the results to examine and evaluate : 526
- whether all of the planned actions have been adequately implemented 527 - the level of achievements made against the planned goals 528 - the financial outcomes 529 - the possible consequences to the organization�s structure 530 - other costs and benefits of the project including possible reactions of interested parties 531
532 The evaluation should assess the adequacy and suitability of the EMS for the organization and should 533 consider possible future changes for example changes in regulations, requests from new customers, 534 additional concerns from local communities or the establishment of new activities). 535
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536 It may be appropriate for the management representative, in charge of the project to prepare a 537 summary report taking into consideration the points described above. 538 539 At the end of the review, top management should be in a position to decide whether to postpone until 540 a later time any idea of implementing an EMS which meets the full requirements of ISO14001 or to 541 increase their understanding of the benefits of an EMS by improving (or completing) the current 542 project or start an additional project focusing on another environmental issue, for example 543 modifications of the action plan, better communication, allocation of additional resources, new 544 assignment of responsibilities, changes in the scope, etc. In this case, it is possible to repeat the 545 methodology used for the initial project taking in consideration the new parameters and focus and 546 building upon the lessons learnt in the initial project. 547 548 If the organization decides to continue with implementation of an EMS that meets the full requirements 549 of ISO14001, top management should formally express its commitment and support and take all the 550 adequate measures necessary for the implementation of the actions described in the following text, 551 including designation of a management representative and the allocation of sufficient time and 552 resources. In any case, top management should clearly communicate and explain its decision to all 553 personnel within the organization. 554
EXAMPLE OF CARRYING OUT A LIMITED SCOPE PROJECT 555
The manager of a small metal fabricating plant meets with his factory supervisor after a series of minor 556 spills in the chemical delivery and storage area are an issue in terms of its staff, the environment and 557 neighbours, The spills represent a modest cost in loss of raw materials, but the cleanup of the spills 558 adds substantially to the cost of waste disposal and spills are inconsistent with the plant’s public 559 policy commitment to prevent pollution of their property. There have been six spills in the past year. 560 Although the spills were small, any of them could have been larger and could have had a significant 561 impact on the environment. 562
They reviewed the facts and agreed upon a goal of preventing pollution. The supervisor, who is 563 responsible for the unloading operations, analyzed the past spills and found that each spill could have 564 been prevented by the safeguards already installed. Five spills occurred with untrained staff who did 565 not use of appropriate equipment such as drain covers; and the last occurred when one of the 566 safeguards was used improperly. He also learned that there is a legal requirement to report spills to 567 the environmental regulatory agency. 568
They agreed that their objective would be the elimination of spills. To achieve these objectives, they 569 set three operational targets, first that the safeguards should be used for every unloading operation, 570 that all appropriate current staff should be trained immediately in unloading and using the equipment, 571 and that no staff could unload vehicles until they have been trained and demonstrated their ability to 572 use the equipment. 573
The programme to meet the objectives and targets included: 574
1. an awareness communication explaining the risk to the staff themselves and their neighbours of 575 not using the equipment provided, 576
2. a training procedure for current staff and new staff upon hire, and 577
3. a procedure to require that unloading is done only by staff who had demonstrated their 578 competency to properly use the equipment. 579
Responsibilities were assigned and milestones defined. 580
The operational controls included placing signs at the unloading area saying that the safeguard 581 equipment should always be used. The unloading logbook was changed so the operator could record 582 whether the safeguards were in place or if they were not used, a justification as to why not. Quarterly, 583 a document summarizing the logbook is reviewed at the Manager’s meeting. A year-end audit of the 584
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records showed there were no spills. However, the early morning operator had begun to omit using 585 safeguards giving the reason “Insufficient time”. Action was taken to correct this in the form of 586 reviewing the morning schedule and revising it to ensure there was sufficient time. Preventive action 587 was taken in the form of training all of the operators to notify their supervisor when there are operating 588 problems that interfere with procedures. 589
In addition to preventing spills, emergency procedures were developed to minimize and contain any 590 spill that might occur and to ensure that the regulatory requirements are met. Drills were scheduled 591 quarterly and included in the objectives. After a drill, the emergency procedures were reviewed. 592
An annual meeting of management and key staff was arranged to review this environmental 593 improvement project in conjunction with the annual review of business objectives. This management 594 review would cover progress against the goals and an evaluation of the benefits derived. In addition it 595 would also decide if the organisation should seek other projects or should implement a full 596 environmental management system and then determine what actions should be taken. 597
6 Overview of activities 598
Identifying significant Environmental Aspects 599 Recognize that the organisation has activities, products and services that interact with the environment.
Identify the environmental aspects that might result from the organization�s activities, products and services
Develop a procedure to identify the organization environmental aspects
Identify the impacts associated with the organizations environmental aspects
Develop a procedure to determine those aspects that have , or can have, significant impact (s) on the environment (i.e.; significant environmental aspects)
Compile and keep up-to-date a list of significant aspects
600
Identifying Legal requirements 601 Recognize that the organization may need to comply with legal and other requirements that relate to its environmental aspects
Identify relevant legal and other requirements
Determine how the legal and other requirements apply to the organisation�s environmental aspects
Keep up-to-date an understanding of the legal and other requirements which are applicable to the organisation.
Preparing and implementing an Environmental Policy 602
Recognize the need to have an environmental policy for the organization
Prepare a preliminary environmental policy suitable for the organization
Develop the environmental policy document to ensure that the content meets the requirements of ISO 14001
Make environmental policy available to the public
Make all those working for and on behalf of the organisation aware its content and meaning
603
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Setting Objectives and Targets and establishing environmental management programme(s) 604
Recognize the need to establish and implement goals in order to improve performance
Gather information which will enable objectives, target and program(s) to be developed
Develop and document objectives, target and program(s) in order to improve performance
work towards achieving objectives and targets through the Implementation of the program(s)
605
Controlling the Environmental Impacts of your Operations 606
Recognize the need for controlling those operations associated with significant environmental aspects
Plan the ways in which operations related to the organizations significant aspects are to be controlled
Develop, implement and test the controls
Review the effectiveness of the implemented controls
607
Planning for and Responding to Emergencies 608
Recognize that emergency situations may occur and need to be managed
Identify which emergency situations may occur and their potential environmental impacts
Developed a procedure that responds to the identified potential emergency situation
Implement and test (where practicable) the procedure that responds to the identified potential emergency situation
Review the responses to emergency situation and revised the procedure if necessary
609
Monitoring and Measuring Progress 610
Recognize the need for monitoring and measuring the performance of the EMS, including the calibration of equipment
Identify the key characteristics that need to be monitored and measured and the equipment which needs to be calibrated
Calibrate equipment and retain records
Develop a procedure to monitor and measure, on a regular basis, the key characteristics of its operations
Gather results of monitoring and measurement
611
Managing When things Don�t Go As Planned 612
Recognize that things can go wrong (non conformity) and that actions need to be taken to correct and/or avoid their occurrence
Identify what could go wrong and take actions to prevent occurrence.
Identify what went wrong and correct it
Analyse why it went wrong and identify actions to avoid re-occurrence
review the effectiveness of corrective action(s) and take preventive action(s).
613
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Management Review of Progress and Performance 614
Recognize that we need to review the performance of our EMS
Identify inputs to the review process
Identify improvement opportunities
Secure improvements the system and/or actual performance
615
616
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7 Tools that support the EMS 617
7.1 Environmental Communications 618
lf an environmental improvement action or the implementation of a management system is to be effective, then those involved in its use need to own and 619 support it. Furthermore, the better they understand why they should provide support, and the sooner they get feedback on what has been achieved, the better 620 motivated they will be. This requires an effective and regular flow of information between management and staff to provide not only direction but also updates 621 on progress. In addition, there must be good communication between the affected areas of the organisation so that each understand s the environmental 622 implications that their actions may have on others in the organization. 623
It is also important that good two-way communication is established and maintained with customers, communities and other external interested parties. 624 Listening to the concerns, views and ideas of those outside the organization can help to build trust and can even lead to improved business and access to 625 markets. As the environmental targets and objectives are developed and the management system is maturing, involving interested parties to an appropriate 626 degree can help the organisation understand, address and be responsive to external views before they become issues. 627
The decisions as to what needs to be communicated to whom and in which ways should be undertaken in a planned way. 628
The organisation recognises the need and value of communicating on environmental issues.
Identify what will be communicated and to whom
Plan how information will be communicated with stakeholders
Implement the communication process
Monitor the results of communications to determine if they have been effective
Step 1 629
Communication on environmental issues is important in an organisation to ensure the effective implementation of an environmental management system. This 630 would include communicating internally within the organisation and with external interested parties. Identifying examples of where poor communication has 631 caused difficulties for the organisation or where good communication has delivered benefits is a good way to start developing a communication strategy. 632 Additional information regarding environmental communication can be found in ISO 14063. 633
Step 2 634
The organisation will need to identify and determine what information is needed and to whom it should be communicated. This information may include: 635
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o the organisation�s environmental policy, the extent and scope of its significant environmental aspects, objectives and targets for improvement in 636 environmental performance, current levels of environmental performance and compliance with legal requirements, 637
o any feedback received from internal and external interested parties (including complaints, regulatory compliance audits and customer questionnaires 638 amongst others., 639
o other relevant information required to ensure the effective implementation of an EMS. 640
The organisation will need to decide on the target audiences, which will include its internal and external interested parties. It should ensure that there is a two-641 way communication mechanism internally between management and staff and externally with interested parties such as customers, communities, authorities 642 and others. Decide on what communications are important for each audience, i.e. delivering a message, seeking input and support, or regulatory approval. 643
Step 3 644
Most organisations already have in place methods of communicating with their staff, its community, customers, suppliers, and other interested parties. Where 645 this is not the case they may need to create a new communication plan. However, it will usually be most cost-effective to build on existing methods where this 646 is practical. This is also a good time to assess the effectiveness of the existing programmes and to make them more effective by looking for better methods or 647 styles and applying new channels or new approaches. 648
The organisation needs to determine the most appropriate method of communication with its identified target audiences. The method will have to address 649 proactive and reactive communication where necessary. 650
In order to maintain consistency, communication procedures should be developed and implemented by the organisation. These need not be complex but 651 should outline what is to be communicated to whom, how and for what purpose. 652
Methods used for communicating can include: minutes of meetings, bulletin board postings, internal newsletters, suggestion boxes/schemes, web sites, 653 electronic mail informal discussions; organization Open Days; focus groups, community dialogue; involvement in community events; web sites and electronic 654 mail; press releases, advertisements and periodic newsletters; annual (or other periodic) reports and telephone hotlines. 655
Decide how proactive to be with each audience on each type of communication 656
Develop key messages (including information/feedback that is being sought), set targets, objectives and performance indicators 657
Assign responsibilities and establish a timetable 658
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Develop a procedure for receiving, documenting and responding to relevant communications from external parties such as neighbours, regulatory bodies and 659 communicate the procedure internally 660
Step 4 661
At this stage the organisation should provide evidence that : 662
o Communication on environmental issues occurs throughout the organisation, as appropriate. 663
o Responses to external questions are addressed in line with its procedure(s) and acted upon . 664
o If necessary, methods for external environmental communication have been developed. 665
Step 5 666
The organisation should review its communication with its internal and external interested parties to verify the effectiveness of the communication and take 667 action to adjust the approaches taken as necessary. 668
Example SME Environmental Communications Strategy
A small engineering company has recently implemented an EMS and wants to get the message across to their various stakeholders but recognises that different stakeholders may require different types of information as follows:
Internal Stakeholders
o Board members � require information on environmental performance and progress of the EMS
o Managers needed to know about performance evaluation and future objectives and targets
o Staff and contractors require detailed work instructions and procedures to ensure performance criteria are met and future targets are recognised
External Stakeholders
o Local communities � are concerned about noise and light pollution � this information was communicated back to site managers
o Investors and Insurers � want to know about current legal and other requirements and about all risks associated with the company�s activities,
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products and services
o Clients � want information about the EMS and the life cycle impacts associated with various products.
The company decides to use a variety of communications techniques to get their message across:
o Website - details of their environmental policy and performance is compiled into an Environment Report (see below)
o Email � detailed work instructions and related environmental regulations are posted to targeted individuals and contractors
o Traditional � they provided posters to explain it�s commitment to improve environmental performance and why this is important.
o Consultation � they meet with residents to discuss local concerns and to explain the organisation�s commitment to environmental protection.
To support its communication strategy the company has also produced an Environment Report which included the following information:
• Explanation of their Environmental Policy and future strategy
• Inventory of environmental aspects and related impacts of activities, products and services
• List of relevant environmental legislation and regulations
• Data from environmental performance evaluation and related indicators
• Who has responsibility for the EMS and other environmental roles
• Summary of environmental performance including:
Progress on meeting policy aims
Objectives and targets being met
Outstanding issues including non-conformance
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This report was signed by the Chief Executive and published on the company�s website.
669
7.2 Resources, roles, responsibility and authority 670
Roles, responsibilities and authorities should be clearly defined so they are not misunderstood. Resources must also be defined. This is important so that 671 management understands the resource implications of the environmental commitments and that those who are charged with providing the resources are also 672 committed. 673
Individual responsibilities should be clearly spelled out so there are not misunderstandings such as duplication of effort or missed tasks. 674
Step 1 Step 2 Step 3 Step 4
Recognize the need to have defined resources, roles, responsibilities and authority of the organization and of implications of the EMS
Identify and defined the roles, responsibilities and appropriate resources within the organisation
Appoint a specific management representative for the EMS
Communicate the roles and responsibilities to all those affected by them and ensure that they understand and agree with them
ISO 14001 Clause 4.xx
ISO 14004 Clause 4.xx
675
Step 1 676
The organisation needs to understand that it is important for effective implementation of the EMS that all roles, responsibilities and authority are 677 recognised. Examples of how such activities have helped the organization in other areas (for examples control of finances, running of departments, etc) 678 can be used to explain this need. 679
Step 2 680
Responsibilities should be job specific wherever possible and should be documented. This is often accomplished through job descriptions. Another way 681 may be specific role and responsibility descriptions with regard to environmental protection (for example making someone a management 682
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representative, project champion or another specific environmental role). Formalizing key roles, responsibilities and authorities within the organisation is 683 done by getting agreement that the existing assignments are correct, and expanding them to include environmental issues. An allocation of resources 684 that coordinates the activities, timetables and milestones of the programme with the resources required is also needed.. 685
Step 3 686
In order to meet the requirements of ISO 14001, top management is required to appoint a �management representative� who ensures that the 687 environmental management system is established, implemented and maintained and who reports on progress to top management. It is critical that the 688 individual assigned is able to give the management system adequate priority relative to the person�s other responsibilities and that they have the 689 authority to implement necessary actions 690
Step 4 691 692 Defining the roles, responsibilities and authorities is only the first step. They must be communicated to the entire organization; the appropriate 693 individuals assigned must be committed to achieving the goals, targets and objectives; and the functional areas must have the time, financial support 694 and technical ability to fulfil their commitments and complete any required training. 695
7.3 Competence, training and awareness 696
Environmental awareness among employees and contractors to the organisation is a crucial factor for implementing an effective EMS. It will be necessary for 697 the organisation to satisfy itself (and often others) that employees an contractors that carry out activities which can impact upon the environment are trained 698 are competent to do so. This may require additional training and possibly assessment. 699
Step 1 Step 2 Step 3 Step 4
Recognize the need to have competent personnel in the organization and awareness of implications of the EMS
Determine the competence requirements that are necessary for activities that can impact upon the environment
Plan and implement the training and awareness program as necessary
Assess competence against the requirements and ensure that they are met
Maintain the competence, training and awareness program
ISO 14001 Clause 4.xx ISO 14004 Clause 4.xx
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700
Step 1 701
The value of the intangible asset of personnel having awareness, competence and trained should be realised by the top management, In addition it should be 702 recognised that there are risks to the organisation which can arise from personnel not being trained and competent to carry out their tasks effectively. 703
Step 2 704
The organisation should identify what knowledge, understanding, skills and competencies are needed to carry out the tasks required of 705 employees and contractors within the EMS. This can be achieved by carrying out in a number of ways including:- 706
o Carrying out a training needs analysis 707
o Asking staff and contractors what training they feel they might need 708
o Benchmarking competence against industry standards and professional qualifications 709
In order to focus efforts on minimising risk to the environment and the organisation, it is helpful to start by looking at key activities which have 710 the potential to cause the greatest environmental impact. 711
The identification of required competence should be based on achieved training, education or on experience. The organisation should provide 712 training for the personnel in relation to both the EMS itself and the organisations significant environmental aspects. It is particularly important to 713 ensure that personnel understand why it is important to the organisation that actions are carried out in a particular way, so reducing risk to the 714 organisation and minimising harm to the environment. 715
Step 3 716
The training and awareness program should plan to provide a range of training for personnel which is relevant to their roles and job functions 717 and that is delivered in such as way that they understand what they need to do and why this is beneficial to themselves, the organisation and 718 the environment. The plan may include a range of techniques including formal training, on-the-job guidance and assessment and mentoring by 719 colleagues. The planning and implementation also requires the by allocation of resources and responsibilities. Records of training activities and 720 demonstrations of competence should be kept. 721
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To improve the environmental competence among personnel a long term strategy for recruitment should also be developed. In addition it is 722 important to remember the need for inclusion of environmental aspects in the induction of new staff, site visitors and contractors. 723
Step 4 724
The organisation should collect feedback from personnel regarding the training and competence development and assessment techniques used 725 in order to improve the process. In addition, it is important to remember that periodic re-training and assessment can help to maintain 726 competence at a suitable level. 727
7.4 Records 728
Records documented information generated as the outcome of some activity and are a statement of the facts at the time the record was made. 729
Records that provide value to the organisation should be kept for the length of time that they have value. Some records are prescribed in both format and 730 retention time by legal or other requirements, but most records are created and kept at the discretion of the organisation. Since the organisation may be 731 required to demonstrate implementation of its environmental management to external interested parties, those records should be maintained in a legible, 732 accessible form for the time management considers necessary. 733
Recognise the need to maintain records as evidence of its ongoing EMS
Determine which records are required and how they will be controlled
review and maintain records as necessary.
734
Step 1 735
Records provide the evidence that the environmental management system is functioning and they must be maintained so that they are protected and can be 736 retrieved when needed 737
Step 2 738
An organisation is likely to be already keeping some records related to environmental matters. They should be reviewed against the legal and other 739 requirements, objectives and targets, operational controls, etc. to ensure that there will be adequate records to demonstrate compliance with requirements 740 and conformity to the EMS. 741
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Records include, for example, log books with dated and signed notations of activities, equipment charts tracking some particular data over time, lists of wastes 742 shipped offsite, notes or minutes of meetings, and checklists or forms used to implement the organisation's management system. 743
The organisation needs to determine what records are to be maintained, by whom, where, how they are kept and for how long, and how they are disposed of. 744 There should be a regular procedure for removing records after the specified storage time. 745
Step 3 746
Collect, review and maintain records that are required to demonstrate conformance with the EMS. 747
Note: It is common for the way that we keep records (and their content) to change as our operations change and the EMS itself develops. As a result, it may 748 be the case that the comparison of records across time relating to a specific activity may be difficult. This will arise because the data that we are recording 749 may have changed and the way that we record them may also have changed. 750
For example should there be a change in the type of resource used (from diesel to natural gas), the corresponding records may change as well. (See 751 Documentation). 752
7.5 Documentation and Documentation control 753
The need to produce documentation is often perceived as bureaucratic and unnecessary. Nonetheless, appropriate documentation is not only essential, but it 754 also provides value. 755
An employee, an interested party, or anyone should be able to understand the organization's management system by reading the documents that describe the 756 system and how it works. The documentation need not be compiled into a single manual, although many organizations find an Environmental Manual to be a 757 useful tool. Documentation does not necessarily correspond to paper documents 758
Recognize the need to have documentation and control it
Determined what documentation is needed and plan for its control
Develop and organize documentation
Implement the documentation and its controls
Verify that the documents implemented are working properly
759
Step1 Recognize the need to have documentation and control it 760
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Documentation helps an organization to ensure that activities which present a risk to it are controlled in a consistent way. In addition, the organisation can 761 demonstrate what decisions it has made, upon what information and circumstances these decisions were based, how any necessary actions were carried out 762 (including by whom and that they were trained and competent to do so) and what the results of those actions are. 763
The extent to which documentation is required and the form that it takes will depends upon the needs of the individual organisation. Some organisations, 764 especially SMEs, may have limited need for documentation or may already have a well established programme for documenting environment related business 765 activities and decisions 766
Step2 Determine what documentation is needed and plan for its control 767
Procedures for documentation should be developed as part of the development of individual environmental programmes and the management system as a 768 whole, and should take into consideration significant environmental aspects as well as legal and other requirements. 769
For an EMS to comply with the requirements of ISO 14001, a procedure is required which outlines how the organisation controls documents within the EMS. 770 Where and how the documents are kept is less important than that they are accessible, and that they are effectively maintained. 771
Control procedures may be different from document to document. Internal documents generated by the organisation should be identified in some way, dated, 772 display revision dates and numbers, document numbers, copy numbers, effective dates, approvals, etc. For external documents such as legal and other 773 requirements, it is important to identify the origin of documents and to ensure that revisions are obtained and distributed to those who need to use them on a 774 timely basis. 775
The procedure should include a listing of the documents being managed, a description of how documents are created, approved, distributed, revised, 776 reviewed and replaced. Responsibility and authority for these steps should be clearly assigned and limited to those individuals. 777
Step3 Develop and organize documentation 778
When implementing an EMS it is helpful to prepare an environmental manual which outlines the structure of the EMS, the organization�s environmental policy, 779 its significant environmental aspects, any environmental objectives and targets and the environmental programs that will deliver them. An environmental 780 manual does not need to be big, nor does it need to be in paper form. Electronic manuals held on organization�s intranets are becoming increasingly common. 781 It is however important that the manual is appropriate to the needs of the organization and that it is accessible to and used by those involved in the 782 implementation of the EMS. 783
The processes the organisation uses to operate its system, e.g. how it selects �significant environmental aspects�, how documents are controlled, etc. should 784 be written documents, included with the organisation's system documentation. Other documents such as procedures describing for example how the 785
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organisation�s activities should be conducted, emergency response plans, or training plans. can also be included with the system documentation or they may 786 be managed with the other documented procedures for the specific areas where they apply 787
Documents requiring control mechanisms encompass internal documents generated by the organisation as well as external documents like e.g. legal and 788 other requirements, or permits. 789
In particular if documents provide critical information to those responsible for environmental activities, then they must be controlled such that they are 790 approved by a competent person, kept up-to-date and readily accessible to those who need to use them. 791
The individual(s) responsible for environmental matters should work with the those that collect and record data and maintain documents to ensure that correct, 792 current, approved documents and records are available and are used by all who need them. 793
Step4 Implement the documentation and its controls 794
The following are outputs that can be achieved by carrying out the activities within this section: 795
o Collection and maintenance of documents necessary for the operation of the EMS. 796
o A procedure to ensure that correct, current, approved documents are available and are used by all who need them. 797
Step5 Verify that the documents implemented are working properly 798
Verify the documentation is working properly and modify it if needed. 799
800
801
802
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8 Developing and implementing an EMS 803
8.1 Preparing and implementing an Environmental Policy 804
The Environmental policy is a short public declaration that outlines the intentions and commitments of the organization with respect to improving its 805 environmental performance. 806
Step 1 Step 2 Step 3 Step 4 Recognize the need to have an environmental policy for the organization
Prepare a preliminary environmental policy suitable for the organization
Develop the environmental policy document to ensure that the content meets the requirements of ISO 14001
Make the environmental policy available to the public Make all those working for and on behalf of the organisation aware its content and meaning
ISO 14001 Clause 4.2ISO 14004 Clause 4.2 807
Step 1 808
Using the information gained during the identification of environmental aspects,(fromactivities carried out under either section 5.2.2 above or 8.2 below), top 809 management should be able to develop understanding of how the organisation�s operations can impact upon the environment, the expectations of regulators, 810 customers, shareholders and other interested parties, and the strategic environmental issues which it should address. 811
Step 2 812
Top management should guide the development of the policy, but with input from throughout the organisation. Broad participation will help make the policy 813 appropriate to the organisation and will ensure that both staff and management are committed to its contents. 814
An organisation should not expect to prepare a policy which fully reflects their needs and the requirements of ISO 14001 (clause 4.2) at the first attempt. It is 815 often however useful to prepare a preliminary environmental policy as a starting point. 816
Start by reviewing any environmental policies or commitments that the organization has already made, even if they were not formalized or written. It may also 817 help to look at policies that other, similar organisations have. In addition attention should be paid to declarations or commitments made by parent 818 organizations where these exist. 819
The organisation should define the boundaries of its EMS. It should decide if the EMS will be applicable to single or multiple locations, particular activities or 820 products? It should consider whether there is reason to limit it to only part of a location or some products or services, e.g. if part of the location is owned and 821 controlled by another organisation. Once defined, the full scope of activities, products and services within those boundaries should be considered. 822
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In order to meet the requirements of ISO 14001 (clause 4.2) the policy should include commitments to comply with legal and other requirements, prevent 823 pollution and continually improve its management processes with the objective of improving its overall performance. Depending on other priority issues 824 unique to the organisation, it may include additional commitments to other requirements such as thoise that are relevant to the environmental aspects of its 825 operations. For example, if recurring complaints are received, a commitment to community involvement might be considered; if a history of spills or releases 826 exist, a commitment to restoring the environment may be appropriate. 827
At this stage however, it is not essential that this preliminary environmental policy, fully complies with all the requirements of ISO 14001. 828
Step 3 829
Check that the preliminary environmental policy is still relevant and amend it or expand it as necessary in light of any new information that has been gathered 830 since the early drafting stage. 831
Check that the written content fully complies with the requirements of ISO14001 as noted in step 2 above by cross-checking the content with these 832 requirements and amending as necessary. 833
The completed environmental policy document should be signed by top management. 834
Step 4 835
Communicating the policy is as important as writing it. Make it available to staff, contractors and the public. In addition an organisation may wish to display its 836 policy at their premises or publicise it on the internet. 837
An idtroduction to the policy should be included in the orgnaisation�s induction process for new employees, contractors and, where applicable, visitors. It is 838 good practice to display the policy visibly throughout the workplace, or incorporate key concepts from it in the company logo and letterhead. Most importantly, 839 top management must emulate the values expressed in the policy commitments through word and deed. Staff need to be able to explain to others what the 840 commitments are and how they as individuals play a part in achieving them. 841
8.2 Identifying your significant Environmental Aspects 842
Any organisation that performs activities, delivers products or provides services affects the environment. Identifying the ways in which its activities, products 843 and services can impact the environment (these are known as the organisation�s �environmental aspects�) and determining which of these are the most 844 important (significant) are essential steps in establishing an EMS. They will help the organization to focus its resources and efforts on actions that minimize, 845 eliminate or at least control any negative impacts and accentuate positive impacts. Managing environmental aspects not only provides significant 846 environmental improvement but can also generate financial benefit and other commercial benefits. 847
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Recognise that the organisation�s activities, products and services interacts with the environment.
Identify the environmental aspects that might result from the organization�s activities, products and services
Develop a procedure to identify the organization environmental aspects
Identify the impacts associated with the organizations environmental aspects
Develop a procedure to determine those aspects that have,
or can have significant impact(s) on the environment (i.e.; significant environmental aspects)
Compile and keep up-to-date a list of significant aspects
848
Step 1 849
Recognition that an organisation interacts with the environment can be prompted by external pressures such as regulatory bodies, customers or neighbours. 850 Alternatively it may be gained through action taken within the organisation. This action could include collecting and evaluating information using the process 851 defined in Section 5 above.. 852
Step 2 853
The identification of aspects and impacts should involve those people in the organisation who are familiar with its activities, products and services. This 854 includes how products are used and disposed of and how services are delivered. If there is insufficient information available within the organisation, 855 information from external resources, such as trade associations, regulatory agencies, suppliers, publications/internet, or consultants can be sought. 856
To plan for controlling its environmental aspects, an organisation must know what these aspects are and where they come from. Discharges to water, 857 emissions to air, releases to land, use of energy and water, are examples of environmental aspects. It is important to note that the way some equipment or 858 processes can impact on the environment may change with at times such as start-up, shutdown or malfunction. It is therefore necessary to consider these 859 abnormal operating conditions as well as normal operating conditions and the impacts associated with potential emergency situations. 860
Tools such as cause and effect diagrams or flowcharts illustrating inputs and outputs from processes can aid in this process. It is also helpful to have a site 861 plan upon which the boundary of the site can be marked, along with other key features such as effluent discharge points, the location of pipe work and 862 services, chimneys and boiler houses, the locations where hazardous materials are stored, and so on. 863
An organisation is only expected to address those aspects which it can control or those that it can influence. For example, while an organisation probably has 864 control over how much electricity it buys from a supplier, it may not have control or influence over the way in which that electricity is generated. While an 865
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organisation cannot control how a consumer disposes of their product, they may be able to influence that consumer by providing instructions on handling and 866 disposal. 867
The organisation will need to Identify the environmental aspects related to: 868
o the organisation�s activities, products and services. 869
o any new or modified projects undertaken by the organisation. 870
o historical activities on the organisation�s site. 871
o any potential and actual emergency situations that the organisation might face. 872
Step 3 873
Aspects can cause, or have the potential to cause, changes in the environment, i.e. environmental impacts. These impacts can be either positive (using less 874 resources by making a product out of recycled materials) or negative (killing fish by discharging toxic materials to a stream). Information from any 875 permits/licenses, existing monitoring data and past environmental incidents or readily available from regulatory agencies can be used to assist in the 876 identification of the associated impacts. 877
An organisation may decide to record its aspects with their associated impacts in a database, register or list. 878
Step 4 879
The determination of which of the organisation�s aspects are significant enough to need managing should involve those people in the organisation who are 880 familiar with the environmental aspects associated with these impacts. 881
A method that includes a consistent and repeatable routine should be used to determine which of the organisation�s environmental aspects are significant. 882 Complex analysis and measurements are typically not necessary for small or medium sized enterprises; a simple process of ranking could be used. 883
A method for keeping up-to-date the information on the organisation�s significant aspects is necessary. The method can be refined in the future as the 884 organisation gains experience and expertise in environmental management. 885
886
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The method should also consider the how the concerns of internal or external parties, such as organisational values, public image, employee concerns, or 887 views of neighbours and community members and/or legal requirements are incorporated into deciding what is significant. Other criteria might include 888 duration, frequency and severity of environmental impacts, the likelihood of them occurring, the potential consequences and the extent to which controls are 889 already in place to deal with the se impacts. 890
Step 5 891
Significant environmental aspects should be taken into account when establishing, implementing and maintaining the environmental management system: 892 implementing controls to minimize aspects, training staff, and establishing plans to respond to accident/incidents to name a few. 893
In order to make them easier to review and manage, it is useful for an organisation to record its significant aspects in a database, register or list. 894
8.3 Identifying your legal and other requirements 895
Identifying all relevant legislative obligations and other requirements is essential for any environmental management system. It is important that the 896 organisation understands those legal obligations that are related to its environmental aspects in order to meet its obligation to society, ensure legal 897 compliance, prevent prosecution, avoid fines and to maintain or improve its image. As legal obligations vary within each country, site and organisation relevant 898 legal obligations will be unique to each organization and site. Other requirements to which the organisation may subscribe can include non binding protocols, 899 voluntary agreements and/or codes of practice. 900
Recognize that the organization may need to comply with legal and other requirements that relate to its environmental aspects
Identify relevant legal and other requirements
Determine how the legal and other requirements apply to the organisation�s environmental aspects
Keep up-to-date an understanding of the legal and other requirements which are applicable to the organisation.
901
Step 1 902
Organisations may have legal obligations based on resource use (such as water, non-renewable energy, etc), product design and prescribed discharge limits 903 for water, air, noise, odour, etc. or for installing and/or operating particular equipment such as boilers, underground tanks etc., or for the storage of hazardous 904 waste. These may be prescribed by government regulatory bodies in the form of legislation, permits, licenses and discharge limits. 905
Since the potential consequences of not complying with legal obligations could present a threat to the organisation�s existence (possibly including fines, 906 interruptions to operations, community concern, customer dissatisfaction or contractual disputes) all organisations need to know how legal obligations affect 907 their operations and develop plans for complying with them. 908
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The organisation may also have other environmental requirements such as those that might be included in supply contracts, expected by trade associations, 909 or other agreements into which the organisation has entered. 910
Step 2 911
Organisations should designate competent staff to establish a process for identifying obligations. If there is a lack of internal expertise in this area, it may help 912 to get assistance from external sources with experience in the organisation�s business and with knowledge of the local/national legal obligations and other 913 requirements. Trade associations, business support networks or the regulatory bodies themselves may be able to provide information regarding relevant 914 legislation. 915
An organisation should document its legal obligations and/or other requirements in a database, register or list. 916
Step 3 917
Individual(s) with technical knowledge of the legal and other requirements and how they apply to the organisation�s operations should be responsible for 918 determining, communicating and monitoring legal obligations and other requirements to those responsible for the relevant operations including contractors. 919
Step 4 920
Legal obligations and other requirements should be reviewed on a periodic basis. The frequency of this review will depend upon how often changes are likely 921 to occur. Consideration should be given to new or changed requirements or those that may apply if changes in the organisations structure, size or product or 922 service range occur. Relevant information should be communicated to those responsible in a format which they can understand and act upon. This may 923 include establishing or changing operating procedures, monitoring emissions and discharges, or taking other actions to comply. 924
8.4 Evaluating Compliance with your Legal and Other Requirements 925
Having identified legal obligations and other requirements it is essential to verify how well the organisation is complying with them. In order to demonstrate 926 compliance on a continual basis it will be necessary to establish methods and indicators to measure compliance. Evaluation of compliance is also necessary 927 to demonstrate improvements in performance. 928
Recognize that the organization is subject to legal and other requirements and that it needs to comply with them
Identify and plan the methods used to monitor and measure compliance.
Periodically evaluate compliance with all legal obligations and other requirements.
Record and report the results of the evaluation including compliance and/or non compliance with all legal obligations and other requirements.
929
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Step 1 930
Top management must be aware of the need for the organisation to demonstrate compliance with its legal obligations. 931
Step 2 932
Organisations should designate competent staff to identify and plan methods for monitoring and measuring compliance. 933
A method that includes a consistent and repeatable routine should be used to evaluate compliance. The method can be refined in the future as the 934 organisation gains experience and expertise in monitoring and measuring compliance. 935
The method requires the identification of indicators necessary to demonstrate compliance with legal obligations. The indicators may be qualitative and/or 936 quantitative. 937
Step 3 938
The organisation should periodically compare the results of its monitoring and measuring with the values specified in the relevant legal obligations and other 939 requirements as necessary using the defined method. The monitoring frequency may be dependent on legal obligations and/or the results of past compliance. 940
Step 4 941
Records should be kept to demonstrate compliance and should be reported to relevant stakeholders as necessary. Note: where a non compliance is detected 942 action is to be taken in accordance with XXX. 943
8.5 Setting Objectives and Targets and establishing program 944
By setting environmental objectives and targets and implementing action plans to achieve them, the commitments in the organisation�s policy are translated 945 into action. Objectives and targets form a central part of the environmental management system and can provide a clear focus for environmental management 946 system activity. By tracking progress against the objectives and targets, management can determine how well the environmental management system is 947 working and whether it is achieving the improvements to which it has committed. The programme is a detailed plan of activities required to support the 948 achievement of the organisation�s environmental objectives and targets. It provides a clear and defined plan for future proposed activity and responsibilities in 949 both the implementation and the operation of the environmental management system. 950
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Recognize the need to establish and implement goals in order to improve performance
Gather information which will enable objectives, target and program(s) to be developed
Develop and document objectives, targets and program(s) in order to improve performance
work towards achieving objectives and targets through the Implementation of the program(s)
951
Step 1 952
Environmental goals and action plans to achieve them can be established to improve performance in any element of the organization's environmental 953 management system. 954
o Objectives are overarching goals consistent with the commitments in the policy. 955
o Targets are the quantifiable performance goals established to support the objectives within a specified time period 956
Step 2 957
Programs are the action plans that the organization puts in place in order to achieve its goals. They identify the �what, when and who�. A program defines how 958 the objectives are to be achieved and the required actions; the timeline for reaching the desired objective; and, the allocation of resources and assignment of 959 responsibilities for the actions. 960
The following information can be useful in helping the organization to set objectives and targets and to establishing environmental action program(s) 961
o Policy commitments 962
o Significant environmental aspects 963
o Legal and other requirements 964
o Technological options 965
o Operational and business requirements 966
o Views of internal and external parties 967
o Actions required to achieve objectives and targets. 968
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o Timescales required for achieving objectives and targets. 969
o Resource requirements for carrying out actions within specified timescales 970
o Awareness, skills, and knowledge building activities required. 971
o roles and responsibilities for individuals or groups for actions towards achieving objectives and targets. 972
Step 3 973
Objectives and targets should be measurable and support the commitments made in the environmental policy. The organization should establish performance 974 indicators for each objective and track progress by monitoring the indicators. They should communicate progress to internal and external interested parties. 975 Not all goals need to be aimed at continual improvement; some may be set to continue the current performance. 976
Step 4 977
Review existing arrangements against objectives and targets 978
Define additional activities and resources needed to achieve Objectives and targets 979
Objectives, targets and programs should also be prioritized and tailored to take into account the organization's unique financial position and the costs involved. 980 It should also take into account resources available. Responsibility for working towards objectives and targets should be designated to relevant personnel, 981 functions and levels within organization. Other considerations should include operational priorities (such as areas for improvements) and business 982 considerations (such as planned expansions or modifications to core business). 983
8.6 Developing Performance Indicators 984
In order to track the organisation�s environmental performance it is necessary to set performance indicators. This performance may relate to both the 985 management system as well as its outcome. The performance indicators that are set will be used to measure the objectives and targets and to ensure the key 986 characteristics are met. The collection and use of environmental performance data can support the continual improvement of environmental performance. 987
Recognize the need to develop indicators to track performance
Gather information which will enable performance indicators to be developed
Set performance indicators
Evaluate suitability of
Collect measure and analyse performance
Evaluate performance of the organization.
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indicators.
988
Step 1 989
The organisation should understand that implementing an EMS in itself may not achieve improvements in environmental performance. Improvements are 990 needed in both the performance of the EMS and its outcome. The outcome includes performance related to the activities, products and services of the 991 organisation. Performance can be measured by the setting of environmental performance indicators (EPI). 992
Step 2 993
The organisation needs to gather information on the key characteristics of its operations that may have a significant impact on the environment. These may 994 include process characteristics such as pressures, temperatures, flow rates, product characteristics, energy use, material composition, product disposal and 995 service characteristics such as transportation methods. 996
Step 3 997
Performance can be measured using different categories of indicators, including where appropriate: 998
o Management performance indicators (MPIs) used to track the performance of the organisations EMS e.g. number of people trained in environmental 999 awareness. 1000
o Operational performance indicators (OPIs) providing information relating to the effectiveness of managing environmental aspects e.g. energy 1001 consumption/per day 1002
o Environmental condition indicators (ECIs) providing information on the impact that the organisation�s discharges are having on the environment e.g. 1003 oxygen content in the water downstream of a discharge point. 1004
Step 4 1005
The collected data should be analysed and converted into information describing the organisation�s environmental performance, expressed as indicators for 1006 EPE. To avoid bias in the results, all relevant and reliable data that have been collected should be considered. Data analysis may include consideration of the 1007 data quality, validity, adequacy and completeness necessary to produce reliable information. Information describing the organisation�s environmental 1008 performance can be developed using calculations, best estimates, statistical methods, graphical techniques, or by indexing, aggregating or weighting. 1009
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The organisation should ensure that the indicators selected are subject to verification to ensure they have been selected appropriately. 1010
Step 5 1011
The information derived from analysed data, expressed in terms of EPIs and possibly ECIs, should be evaluated against the organization�s environmental 1012 performance criteria, including objectives and targets. This evaluation may indicate progress or deficiencies in environmental performance. The information 1013 describing the organization�s environmental performance and the results of the evaluation should be reported to management, to support appropriate 1014 management actions to improve or sustain the level of performance. 1015
8.7 Controlling the Environmental Impacts of your Operations 1016
Operational controls are necessary to ensure that the organisation�s significant aspects are being managed in a way that minimizes their impact on the 1017 environment. Control procedures should also support the achievement of objectives and targets, which in turn will support the organization�s policy 1018 commitments to continual improvement and compliance with relevant legislation and other requirements. 1019
Recognize the need for controlling those operations associated with significant environmental aspects
Plan the ways in which operations related to the organizations significant aspects are to be controlled
Develop, implement and test the controls
Review the effectiveness of the implemented controls
1020
Step 1 1021
Management has a responsibility to control its operations in order to meet its environmental policy commitments, achieve its objectives and targets, comply 1022 with environmental legal requirements and other environmental requirements to which the organization subscribes, and to ensure that its significant 1023 environmental aspects are minimized. 1024
Step 2 1025
To plan for effective and efficient operational controls, an organization should identify where such controls are needed and what they are intended to achieve. 1026
When determining the controls that it needs, an organization should consider all of its day-to-day activities such as manufacturing, maintenance and product 1027 storage as well as those related to management functions such as purchasing, sales, marketing, research and development, design and engineering of 1028 products. It should also consider how products are transported off-site. In addition, consideration should be given to operations carried out by its contractors or 1029 suppliers. 1030
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Step 3 1031
In deciding what controls are appropriate the organisation should initially take a proactive approach and try to eliminate the need for specific controls. If this 1032 cannot be achieved it may be possible to transfer the risk to another organisation (outsourced waste water treatment facility) or substitute a lower risk (use of 1033 water based instead of solvent based paint). Where a proactive approach cannot be achieved it may be necessary to respond in a reactive way to minimise 1034 the organisations impacts. This may include using approaches that reduce, reuse and/or recycle, treat and where all other options are exhausted, disposal. 1035
Controls specify the way to carry out an activity or a process and can include engineering controls such as primary and/or secondary containment, physical 1036 barriers etc., and /or administrative controls such as documented procedures or work instructions, technical specifications in relation to equipment and 1037 machinery and contractual agreements specifying requirements for suppliers/contractors. 1038
Procedures can be very detailed and limited in application (for example a procedure for running a chemical processing operation), or they can be very general 1039 and apply broadly to several operations such as a procedure describing training. They can be complex like a process map or simple such as a bullet list of 1040 steps, checklist, flowchart or a sequence of pictures. 1041 1042
Procedures should be written and/or reviewed by those who actually do the operations and communicated effectively to others who may need to be aware of 1043 what is being done, including contractors and suppliers. 1044
Operational controls should be tested prior to implementation to ensure that they will be effective. 1045
Step 4 1046
Controls should be reviewed periodically to ensure they are effective. 1047
[insert an example here] 1048
EXAMPLE
An small company has identified as one of its significant aspects (occurring in abnormal circumstances) that during the filling of the diesel tank used to fuel its boiler, oil could overflow through the tank vent.
The company examined possible controls and decided that the most proactive and effective way to eliminate this situation was to use a closed circuit refuelling system with automatic shut off valves. However investigation revealed that the fuel supplier had no such equipment and was using a hand operated open circuit system to refuel the tank. The introduction of a closed circuit system would be very expensive.
This left the company to consider a reactive approach to controlling this risk by introducing both engineering and administrative controls as follow:
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1. The engineering control they decided to use was to place secondary containment (build a brick wall) around the tank, they thought about installing a float operated shut off valve but were concerned about its reliability and elected to use containment instead.
2. They also decided to include a requirement in the fuel supplier�s contract that during the filling process the nozzle must not be left unattended and the oil level monitored by the operator at all times. 3. A caution notice was also written and placed adjacent to the fuelling point reminding operators not to leave the filling point while this was in progress and to visually monitor the oil level in the tank.
1049
8.8 planning for and Responding to Emergencies 1050
It is necessary to avoid any environmental impacts that may result from emergency situations that may arise. Where such situations occur, controlling and 1051 minimising the impact is essential. Being well prepared and ensuring that those working for, or on behalf of the organization know what to do in such 1052 circumstances can reduce the actual impacts to the environment. 1053
Recognize that emergency situations may occur and need to be managed
Identify which emergency situations may occur and their potential environmental impacts
Developed a procedure that responds to the identified potential emergency situation
Implement and test (where practicable) the procedure that responds to the identified potential emergency situation
Review the responses to emergency situation and revised the procedure if necessary
1054
Step 1 1055
Even with the best operational controls in place, an organisation may find itself dealing with an accident or emergency situation. 1056
Step 2 1057
The determination of potential emergency situations such as fire, accidental release, explosions, floods, etc should have been addressed in the section of this 1058 standard related to the identification of environmental aspects and their associated impacts and legal requirements. However circumstances unique to the 1059 organisation�s location or operations may also create emergency situations that need to be addressed such as sabotage, public disorder etc. 1060
Step 3 1061
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Many organisations already have plans to respond to an emergency and these should be examined to ensure they adequately cover the potential 1062 environmental impacts of such emergencies and control mechanisms to minimise these.. Mitigation measures may include primary and secondary 1063 containment, fire suppression, etc. 1064
Step 4 1065
The organisation should implement its emergency procedures and test them in the actual operating environment, where practicable, in order to verify their 1066 effectiveness Practice drills should be seen as an opportunity to learn how to improve emergency preparedness planning. 1067
Step 5 1068
The organization should periodically review and, where necessary, revise its emergency preparedness and response procedures, in particular, after the 1069 occurrence of emergency situations. After the event is over, an evaluation should be conducted to identify the effectiveness of the response. Lessons learned 1070 can be captured and corrective and preventive actions developed, with operating procedures being modified accordingly. 1071
8.9 Monitoring and Measuring Progress 1072
Recognize the need for monitoring and measuring the performance of the EMS, including the calibration of equipment
Identify the key characteristics that need to be monitored and measured and the equipment which needs to be calibrated
Calibrate equipment and retain records
Develop a procedure to monitor and measure, on a regular basis, the key characteristics of its operations
Gather results of monitoring and measurement
1073
Step 1 1074
Monitoring and measuring activities provides management with key data by which an organisation can evaluate its performance against its environmental 1075 policy and performance, legal requirements, objectives and targets. 1076
Step 2 1077
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Key characteristics that may require monitoring and measuring include: 1078
o monitoring emissions and discharges to meet environmental legal and other requirements to which the organization subscribes; 1079
o monitoring water, energy or raw materials consumption to meet objectives and targets; 1080
o progress on policy, objectives and targets and continual improvement; 1081
o Documents (operating instructions, procedures established for the relevant elements of the system, other applicable specifications.) containing the 1082 key characteristics to be monitored or controlled, including those deriving from legal and other requirements 1083
o operating instructions for measuring equipment as provided by the supplier (e.g. standard instructions to operate a pH. meter) 1084
o Objectives, targets and performance indicators established by the organisation 1085
Step 3 1086
For each key characteristic (or series characteristics), define the equipment and method(s) to be applied, either by using standard protocol(s) (e.g. C.O.D. 1087 determination) or an analysis of relevant data (e.g. fuel consumption for an evaluation of CO2 emissions) 1088
When procedures do not refer to standard methods, explain and record the method used for monitoring. 1089
Ensure that equipment used for monitoring is properly calibrated and the calibration records are retained. 1090
Procedures should be developed for monitoring/measuring the key characteristics of the environmental performance 1091
Step 4 1092
Gather and assess data against the identified key characteristics to determine conformance with environmental objectives targets and performance indicators. 1093
The data provided by this process will be a fundamental input for the Management Review of the EMS. 1094
Step 5 1095
Explain that the output of Step 5 forms an input to the management review process 1096
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An organization should have a systematic approach for measuring and monitoring its environmental performance on a regular basis. Monitoring involves 1097 collecting information, such as measurements or observations, over time. 1098
Measurements can be either quantitative or qualitative. 1099
Monitoring and measurements may serve many purposes in an EMS, such as: 1100
o tracking progress on policy, objectives and targets and continual improvement; 1101
o developing information to identify significant environmental aspects; 1102
o monitoring emissions and discharges to meet environmental legal requirements or other environmental requirements to which the organization 1103 subscribes; 1104
o monitoring water, energy or raw materials consumption to meet objectives and targets; 1105
o providing data to support or evaluate operational controls; 1106
o providing data to evaluate the organization�s environmental performance; and 1107
o providing data to evaluate the performance of the EMS. 1108
To achieve these purposes, an organization should plan what will be measured, where and when it should be measured, and what methods should be used. 1109 To focus resources on the most important measurements, the organization should identify the key characteristics of processes and activities that can be 1110 measured and that provide the most useful information. 1111
Measurements should be conducted under controlled conditions with appropriate processes for assuring the validity of results, such as adequate calibration of 1112 monitoring and measurement equipment, use of qualified personnel, and use of suitable quality control methods. Written procedures for conducting 1113 measurement and monitoring can help to provide consistency in measurements and enhance the reliability of data produced. 1114
The results of measurement and monitoring should be analyzed and used to identify both successes and areas requiring correction or improvement. 1115
8.10 Internal Audits 1116
It necessary to conduct internal audits to ensure that the organisation�s planned arrangements are being met and that the EMS conforms to the pre-selected 1117 standard(s). 1118
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An internal audit may be carried out as a single activity or divided into smaller parts which together make up a complete audit programme. 1119
It may also be carried out as appropriate for specific, defined objectives. For example, an internal audit may be carried out as a check to ensure that all legal 1120 requirements have been identified or that effective communication mechanisms are in place. 1121
In any case, it is important that all units and functions of the organisation within the defined scope of its EMS, and all elements of its EMS, have been 1122 completely audited within the auditing period decided upon by the organisation. 1123
Recognise the need to ensure that the system is properly implemented and meets plan arrangement
Gather information in order to develop the audit program
Plan an audit program
Implement the audit program
Report audit findings r to management and act upon them.
Identify improvements to internal auditing
Step 1 1124
Performing internal audits will give the organization an indication as to whether procedures and practices have actually been implemented and are functioning 1125 as planned. 1126
Step 2 1127
It is necessary to determine what needs to be audited, when and to what depth so as to identify which areas are working well and which are not. 1128
Auditors need to be trained and should be familiar with the proposed EMS and where appropriate details of appropriate standard. 1129
A variety of information sources can be used to guide the development of a focused audit plan. Such information might include:- 1130
o Information related to the system elements and operational controls within the units or functions 1131
o Information regarding the extent to which objectives and targets have been met and records regarding environmental performance and the 1132 effectiveness of operational controls. 1133
o Local environmental issues surrounding organization�s site 1134
o Information from the on-site observations 1135
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o Interviews with personnel 1136
Step 3 1137
The responsibility for managing an audit program should be assigned to an individual with knowledge and understanding of audit principles, the expected 1138 competence of auditors and the application of audit techniques. An audit program to direct the planning and carrying out of audits, should consider the 1139 information gathered in step 2. it should decide how the area will be audited, for example, by procedure or by department, and when they are to be audited. 1140
The frequency of audits should be based on environmental importance and the findings of previous audits. 1141
During the planning process an audit procedure should be established which reflects how the organization has plans its audit program, including audit criteria, 1142 scope, frequency and the methods used. 1143
Step 4 1144
An audit should be conducted by one or more objective and impartial auditors, aided, where appropriate, by a technical expert. The auditors should possess 1145 the necessary personal attributes, environmental understanding, skills a strong motivation to improve the EMS 1146
Step 5 1147
When a full programme of internal EMS audits has been carried out audit findings on nonconformities or any necessary improvements identified should be 1148 reported to management so that they can be corrected or carried out. 1149
The result of audits should be recorded and kept 1150
Step 6 1151
The organization should review the audit program and procedure(s) to ensure that it continues to be effective. For example, to adjust audit frequency based 1152 upon previous audit findings and whether conditions have changed for different aspects. In addition, auditors' competence should be assessed periodically 1153 and maintained appropriately. 1154
8.11 Managing When things Don’t Go As Planned 1155
Where it is identified that the organisation�s stated policies and planned actions (and resulting procedures where applicable) are not being conformed with, it 1156 will be necessary to develop and take corrective or preventive actions. This is a fundamental element of any successful system and at the heart of continual 1157 improvement. Such non-conformities can be identified in a number of ways, and reporting these should not be restricted to the audit process. 1158
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Recognise that things can go wrong (non conformity) and that actions need to be taken to correct and/or avoid their occurrence
Identify what could go wrong and take actions to prevent occurrence.
Identify what went wrong and correct it
Analyse why it went wrong and identify actions to avoid re-occurrence
review the effectiveness of corrective action(s) and take preventive action(s).
Step 1 1159
Define (a) method(s) to detect and report possible nonconformities 1160
Step 2 1161
Developed a process to insure that all non conformities are analysed and corrected effectively, to mitigate environmental impacts and to prevent occurrence. 1162
Organize the process to prepare and implement corrective and preventive action plans for potential non-conformities: who; how; distribution; calendar of 1163 implementation, etc 1164
Define a method (s) to detect possible deviations before they actually occur, to detect in the organisation possible nonconformities and to evaluate the need to 1165 prevent non-conformities 1166
The following information should be considered when you defining such a methodology 1167
o Emergency reports to public authorities 1168
o Inspection reports 1169
o project reports 1170
o Audit reports 1171
o Data and other information related to operations which may have a significant impact on the environment 1172
o Records of complaints from interested parties 1173
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o Notification of regulatory non-compliances by public authorities 1174
Step 3 1175
Organize the process to prepare and implement corrective and preventive action plans for actual non-conformities: who; how; distribution; calendar of 1176 implementation 1177
Recording the results of corrective action and preventive action taken 1178
Modification of existing procedure(s), operating instructions and training programs 1179
Define (a) method(s) to initiate and implement corrections of actual non-conformities to review actual non-conformities in order to detect their causes 1180
Actions taken should be appropriate to the nature and the magnitude of the environmental impacts 1181
Step 4 1182
Organize the process to prepare and implement corrective and preventive action plans for actual and potential non-conformities: who; how; distribution; 1183 calendar of implementation 1184
Establishing best practice 1185
Follow-up reports on the effectiveness and timeliness of actions 1186
Modification of existing procedure(s) 1187
Modification of existing operating instructions 1188
Any other relevant EMS documentation 1189
Step 5 1190
8.12 Management Review of Progress and Performance 1191
Management review of the implementation and direction of the EMS should occur as an ongoing activity throughout the implementation process. In addition, 1192 however, formal management review activities provide top management with a structured opportunity for reviewing the performance of the EMS, and its 1193
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continuing suitability, adequacy and effectiveness. Furthermore management representatives can contribute directly to the strategy and decision making 1194 processes relating to the operation and continual development of the EMS. It will allow for management to address the need for changes to central elements 1195 of the EMS such as policy, objectives and targets, and the programme in light of experience and changing circumstances. 1196
The Management review may be carried out in any form and records of the review shall be retained. 1197
However, it should be based on appropriate information on the EMS and organisational activities, and sufficient time shall be allocated for it. 1198
Where appropriate, persons who are responsible for implementing EMS and for providing resources should be involved in this review. The Management 1199 review should be scheduled on a suitable and regular basis 1200
Recognize that we need to review the performance of our EMS
Identify inputs to the review process
Identify improvement opportunities
Secure improvements the system and/or actual performance
Step 1 1201
Explanation of the meaning of a management review including the fact that change may be necessary 1202
Step 2 1203
Explanation of the performance information needed for conduction a management review 1204
Results of internal audits and correcting actions addressing audit findings 1205
Communication from external interested parties, including complaint records 1206
Results of evaluations of compliance with legal and other requirements to which the organisation subscribes 1207
The environmental performance of the organisation (results of monitoring and measurement of environmental performance indicators on the key 1208 characteristics of its significant environmental aspects) 1209
Review progress of objectives, targets and programs 1210
Status of corrective and preventive actions 1211
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Follow-up actions from previous management reviews 1212
Information on changing circumstances, including, developments in legal and other requirement related to the organization�s environmental aspects 1213
Changes and anticipated changes to the organisation�s activities, products, or services 1214
Assessment of environmental aspects which are likely to result from planned or new developments 1215
Scientific and technological progress related to the organisation�s environmental aspects 1216
Lessons learned from emergencies and near misses 1217
Trends in stakeholder views 1218
Recommendations for improvements and planning of necessary resources 1219
Step 3 1220
In the interest of continual improvement, decisions and actions for improvement should arise as outputs of each management review. 1221
The results of management reviews indicating the appropriateness and effectiveness of the system should be kept. 1222
Decisions related to possible changes to the environmental policy, objectives, targets, and other elements of the environmental management system should 1223 be recorded, as should decisions regarding specific actions for changes and improvements, and resource allocations needed. 1224
Specific actions for enhancing the environmental management system in order to achieve improvements in overall environmental performance 1225
Step 4 1226
Top management should confirm the results of actions taken after the management review, and on a daily basis pay attention to the effectiveness of the 1227 system and to the opportunities for improving it. 1228
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Annex A 1229 (informative) 1230
EMAS 1231
The content of this annexe will be modified to be aligned with the rest of the document after 1232 agreement of the group on the main body of the document. 1233
The Eco-management and Audit Scheme (EMAS) is based on the European Regulation (EC) No 1234 761/2001. The scheme is entirely voluntary and participation is open to any organisation, including 1235 organisations in non-European countries, although EMAS Registration is restricted to organisations 1236 operating in European member states and Iceland, Norway, and Liechtenstein. 1237
EMAS incorporates an environmental management system in line with ISO 14001 and those 1238 organisations with an ISO 14001-certified EMS can progress towards EMAS registration by 1239 incorporating a number of additional elements. Some of these elements are already incorporated in 1240 this ISO 14005 guidance standard. 1241
This Annex sets out: 1242
1. the differences with ISO 14001 management system requirements; and 1243
2. laid out as a �module� the process for developing an EMAS statement 1244
A.1 EMAS statement 1245
A.1.1 Intention 1246
The intention of this section of the Annex is to assist an organisation to prepare its environmental 1247 statement. 1248
In particular, this module 1249
• describes how to develop and manage the collection of data and information; 1250
• explains how to communicate policies and statements with the public and other interested parties, 1251 including employees. ( ISO 14063 provides useful information about how an organisation can 1252 assist interested parties in understanding an organisation�s environmental commitments, policies 1253 and performance.) 1254
• explains how to compile the statement and ensure it is written in non-technical language and be 1255 publicly available and verifiable. 1256
WHY 1257
To meet today's stakeholder expectations and the requirements of EMAS, the organisation should not 1258 only communicate regarding environmental issues internally, but to also external interested parties. It 1259 will then be able to demonstrate an open dialogue with the public. 1260
By establishing a formalized approach for external communication, the organisation will assist 1261 interested parties in understanding the organisation�s environmental commitments, policies and 1262 performance and it will address interested parties� concerns. It will promote an organisation�s 1263 environmental credentials, achievements and performance enhancing interested parties� perceptions 1264 of the organisation, and increase business support and shareholder confidence. 1265
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As an internal impact to the organisation, external communication will improve understanding of 1266 interested parties� needs and concerns and foster trust and dialogue. 1267
WHO 1268
• top management 1269
• relevant manager /supervisor 1270
• relevant key individuals 1271
• environment representative 1272
INPUTS 1273
• scope of the organisation, its activities, products and services 1274
• policy 1275
• significant environmental aspects and impacts 1276
• legal requirements 1277
• objectives, targets and programmes 1278
• results from monitoring and measurement including EPE 1279
• results from internal audits and compliance reviews where available 1280
• communication from interested parties 1281
• description of the organisation 1282
• brief description of the management system 1283
HOW 1284
• gather relevant information and data using data and information generated by the management 1285 system, other sources and EPE. 1286
• review the data and information for relevance to what the organisation wishes to communicate and 1287 to the requirements of EMAS 1288
• analysis the relevant data to identify trends, KPI, illustrations etc to make the data more user 1289 friendly 1290
• develop statement that meets the EMAS requirements aiming to use simple language and 1291 illustrations to facilitate the understanding of the information and data 1292
• internal consultation with relevant individuals to ensure information and data in statement is a fair 1293 reflection of actual situation and cannot be deemed as misleading. Amend any areas as 1294 necessary. 1295
• gain, if relevant, internal approval of statement 1296
• develop communication process related to the statement 1297
OUTPUT 1298
• statement (ready for validation by EMAS verifier) 1299
• communication process including dialogue with interested parties 1300
1301
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A.2 EMAS potential variations with text in ISO 14005 as its stands 1302
A.2.1 Scope of an EMS 1303
• organisations need to be aware that for EMAS registration the scope of the EMS is related to its 1304 site except in certain circumstances; 1305
• EMAS provides requirements related to the understanding of the concept of site including allowing 1306 registration of : 1307
o �cluster� organisations (that is a number of SME with similar environmental 1308 aspects); 1309
o virtual organisations (those without a physical site for example consultants, 1310 logistic, transportation); 1311
A.2.2 Legal compliance 1312
Text for this will be added when Module B text related to legal compliance has been reviewed in 1313 Beijing. The text in ISO 14005 will be reviewed based on Annex 1B of EMAS, which states: 1314
�Organisations shall be able to demonstrate that they: 1315
a) have identified, and know the implications to the organisation of, all relevant 1316 environmental legislation; 1317
b) provide for legal compliance with environmental legislation; and 1318
c) have procedures in place that enable the organisation to meet these requirements on an 1319 ongoing basis.� 1320
A.2.3 Initial review 1321
Text for this will be added when Module B text related to initial environmental review has been 1322 reviewed in Beijing. The ISO 14005 text will be reviewed based on Annex VII of EMAS, which states: 1323
‘The review should cover five key areas: 1324
a) legislative, regulatory and other requirements to which the organisation subscribes; 1325
b) an identification of all environmental aspects with a significant environmental impact in 1326 accordance with Annex VI, qualified and quantified as appropriate, and compiling a 1327 register of those identified as significant; 1328
c) a description of the criteria for assessing the significance of the environmental impact 1329 in accordance with Annex VI, point 6.4; 1330
d) an examination of all existing environmental management practices and procedures; 1331
e) an evaluation of feedback from the investigation of previous incidents� 1332
A.2.4 Significant environmental aspects 1333
An organisation intending to implement EMAS needs to consider: 1334
• that while ISO 14001 talks about control and influence related to aspects, EMAS uses the terms 1335 direct and indirect aspects 1336
• the EMAS guidance related to the choice of criteria to use to assess significance 1337
• that its significance criteria are comprehensive, capable of independent checking, reproducible 1338 and made publicly available. 1339
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A.2.5 Performance/continual improvement 1340
• Organisations implementing EMAS need to be aware that the means to achieve objectives and 1341 targets cannot be environmental objectives 1342
• Organisations implementing EMAS need to ensure that their management system and the audit 1343 procedures address the actual environmental performance of the organisation with respect to the 1344 aspects identified. 1345
A.2.6 Employee involvement 1346
• Additional text not deemed necessary at present. 1347
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Annex B 1348 (Informative) 1349
Cross Reference Table 1350
Content of this annexe will be revised and modified after agreement of the group on the main 1351 body of the document. 1352
5 Module A � Securing management support and commitment to a phased implementation of an EMS
5.1 Intention of the module
5.2 Identifying and selecting a project to demonstrate benefits
5.3 Planning the selected project ISO 14001:2006 Clause 4.3 (Planning)
ISO 14004:2004 Clause 4.3 (Planning)
5.4 Implementation of the selected project ISO 14001:2006 Clause 4.4 (Implementation and Operation)
ISO 14004:2004 Clause 4.4 (Implementation and Operation
5.5 Securing management support and commitment to a phased implementation of an EMS
ISO 14001:2006 Clause 4.5 (Checking)
ISO 14004:2004 Clause 4.5 (Checking)
ISO 14001:2006 Clause 4.6 (Management Review)
ISO 14004:2004 Clause 4.6 (Management Review)
5.6 Review of module A results
6 Module B � Identifying What to Manage
6.1. Intention of the module
6.2. Maintaining Support & Commitment from Staff and Management
6.3. Carrying out an "Initial environmental review"
ISO 14001:2006 Annex A, (A.1 General Requirements)
ISO 14004:2004 Clause 4.1.4 (Initial Environmental Review)
6.4. Preparing a preliminary environmental policy
ISO 14001:2006 Clause 4.2 (Environmental Policy)
ISO 14004:2004 Clause 4.2 (Environmental Policy)
6.5. Identifying the organisation's environmental aspects
ISO 14001:2006 Clause 4.3.1 (Environmental Aspects)
ISO 14004:2004 Clause 4.3.1 (Environmental Aspects)
6.6. Determining the significance of the organisation's environmental aspects
ISO 14001:2006 Clause 4.3.1 (Environmental Aspects)
ISO 14004:2004 Clause 4.3.1.5 (Environmental Aspects)
6.7. Identifying the organisation's Legal and Other requirements
ISO 14001:2006 Clause 4.3.2 (Legal and Other Requirements
ISO 14004::2004 Clause 4.3.2 (Legal and Other Requirements)
6.8. Evaluating Compliance with the organisation's legal and other requirements
ISO 14001:2006 Clause 4.5.2 (Evaluation of Compliance)
ISO 14004::2004 Clause 4.5.2 (Evaluation of Compliance)
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6.9. Review of module B results
7 Module C � Planning for Action
Finalising the organisation's environmental policy
ISO 14001:2006 Clause 4.2 (Environmental Policy)
ISO 14004:2004 Clause 4.2 (Environmental Policy)
7.2. Setting Objectives & Targets
ISO 14001:2006 Clause 4.3.3 (Objectives, Targets and Programme(s))
ISO 14004:2004 Clause 4.3.3 (Objectives, Targets and Programme(s))
ISO 14031:2000 Clause 3.3.5 (Analysing and Converting Data)
ISO 14031:2000 Clause 3.3.4 (Assessing Information)
7.3. Establishing environmental management programmes
ISO 14001:2006 Clause 4.3.3 (Objectives, Targets and Programme(s))
ISO 14004:2004 Clause 4.3.3 (Objectives, Targets and Programme(s))
7.4. Developing Performance Indicators
ISO 14001:2006 Clause 4.3.3 (Objectives, Targets and Programme(s))
ISO 14004:2004 Clause 4.3.3 (Objectives, Targets and Programme(s))
ISO 14031:2000 3.2.2 (Selecting Indicators for EPE)
7.5. Review of module C results
8 Module D - Taking Control of the organisation's environmental aspects
8.1. Controlling the environmental aspects of the organisation's operations
ISO 14001:2006 Clause 4.4.6 (Operational Control)
ISO 14004:2004 Clause 4.4.6 (Operational Control)
ISO 14031:2000 Clause 3.3.5.2 (Internal Reporting and Communication)
8.2. Planning for and responding to emergencies
ISO 14001:2006 Clause 4.4.7 (Emergency Preparedness and Response)
ISO 14004:2004 Clause 4.4.7 (Emergency Preparedness and Response)
8.3. Review of module D results
9 Module E - Adding elements to track and maintain progress
9.1. Intention of the module
9.2. Monitoring and Measurement ISO 14001:2006 Clause 4.5.1 (Monitoring and Measurement)
ISO 14004:2004 Clause 4.4.7 4.5.1 (Monitoring and Measurement)
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ISO 14031:2000 Clause 3.3.2 (Collecting Data)
9.3. Internal audit
ISO 14001:2006 Clause 4.5.5 (Internal Audit)
ISO 14004:2004 Clause 4.5.5 (Internal Audit)
ISO 14031:2000 Clause 3.3.2 (Collecting Data)
ISO 14031:2000 Clause 3.3.5.2 (Internal Reporting and Communication)
9.4 What to do when things don�t go as planned
ISO 14001:2006 Clause 4.5.3 (Non-conformity, corrective action and preventive action)
ISO 14004:2004 Clause 4.5.3 (Non-conformity, corrective action and preventive action)
ISO 14031:2000 Clause 3.3.5.2 (Internal Reporting and Communication)
9.5. Management review of progress and performance
ISO 14001:2006 Clause 4.6 (Management Review)
ISO 14004:2004 Clause 4.6 (Management Review)
ISO 14031:2000 Clause 3.3.5.2 (Internal Reporting and Communication)
ISO 14031:2000 Clause 3.4 (Reviewing and Improving EPE)
9.6. Review of results of module E
10 Module F �environmental performance evaluation
10.1. Intention of the module
10.2. Review of results of module F
11 Module X � Tools and activities that support the EMS
11.1. Intention of the module
11.2. Awareness
ISO 14001:2006 Clause 4.4.2 (Competence, training and awareness)
ISO 14004:2004 Clause 4.4.2 (Competence, training and awareness)
ISO 14031:2000 Clause 3.3.5.2 (Internal Reporting and Communication)
11.3. Resources, roles, responsibilities and authority
ISO 14001:2006 Clause 4.4.1 (Resources Roles Responsibility and Authority)
ISO 14004:2004 Clause 4.4.1 (Resources Roles Responsibility and Authority)
ISO 14031:2000 Clause 3.3.5.2 (Internal Reporting and Communication)
11.4. Communication ISO 14001:2006 Clause 4.4.3 (Communication)
ISO 14004:2004 Clause 4.4.3 (Communication)
ISO 14031:2000 Clause 3.3.5.2 (Internal Reporting and
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Communication)
ISO 14031:2000 Clause 3.3.5.2 (Internal Reporting and Communication)
ISO 14031:2000 Clause 3.3.5.3 (External Reporting and Communication)
11.5. Competence and training
ISO 14001:2006 Clause 4.4.2 (Competence, training and awareness)
ISO 14004:2004 Clause 4.4.2 (Competence, training and awareness)
11.6. Managing Documents and records ISO 14001:2006 Clause 4.4.5 (Control of Documents)
ISO 14004:2004 Clause 4.4.5 (Control of Documents)
11.7. Review of results of module X
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