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Hari Srinivas |
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Concept Note Series E-167. May 2018
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Lying at the core of the environment standard of ISO14001 is the development and implement of an environmental mangement system (EMS). ISO14001 stipulates that an EMS must contain five main requirements: (1) Environmental Policy, (2) Planning, (3) Implementation, (4) Checking and Corrective Action, and (5) Management Review .
The objective of this section is to provide an overview of the five elements. Actually putting an EMS in place requires resources - human and other - to be utilized. The best and first step towards an EMS, especially for a local government, is to setup an Citizen's EMS Committee that will help the city to develop and implement an EMS with appropriate assisstance.
Some of the key lessons learnt from cities that have tried EMS is that commitment to the EMS begins with top level support. An EMS is built around sets of procedures - which is what makes it a 'management' system! The most effective way to implement an EMS is to align existing environmental processes, manuals and procedures with ISO14001 (through a gap analysis). It is critical to have one person to be made responsible for the EMS, who makes sure records are in order to prove actions, and communication and training are implemented as a part of the EMS.
The EMS Cyclical Process
POLICY [1/5]
- Top management commitment
- Commitment to prevention of pollution
- Commitment to continual improvement
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he most important starting point for an EMS* is the development of an environmental policy. ISO14001 requires local governments to implement their own environmental policy. The environmental policy acts as a basis for the environmental management system.
The policy outlines the key environmental issues that the EMS will tackle. The policy must be relevant to activities, products and services, and must show commitment to continual improvement, prevention of pollution, and compliance with laws. It must also be well documented and implemented.
When developing the EMS Policy, one of the first steps is for top management to define the actual policy, make a strong commitment to continual improvement, commit to comply with relevant laws and regulations, and develop a framework for setting and reviewing environmental goals.
The objective of an Environmental Policy is to provide a framework for action. However, it needs to be specific enough to enable the setting of environmental targets and goals. In terms of setting environmental targets, it depends on the organization and its activities. If large amounts of air pollutants are being discharged, then a specific statement in the Environmental Policy is needed to address that fact. In this case, an Environmental Policy could include a general objective to reduce air pollution by 5% a year over the next 5 years. This way, a framework is set - but specific enough to promote action.
It is critical that the environmental policy is communicated to all members of the organization, and also made available to the general public. An Environmental Policy needs to provide a framework for action, but be specific enough to enable target setting. It provides the foundation for all future action, and needs top management commitment and implementation. Performing a gap analysis and developing guidelines for implementation will help in operationalizing the environmental policy.
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The Environmental Management System - or EMS - is the vehicle by which ISO14001 requirements are systemized and incorporated into an organization's everyday management, be it a private company or a local government.
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PLANNING[2/5]
- Environmental aspects and impacts
- Legal and other requirements
- Objectives and targets
- Gap analysis
- Programme to reach objectives and targets
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he second element of an EMS is Planning. Planning an EMS requires consideration of the following: What are the "Environmental aspects" of the organization? What laws and other requirements need to be complied with? What are the organization's environmental objectives and targets? Has an Environmental Management Programme been developed? In essence, the organization will need to consider how it is impacting on the environment, what it needs to aim for, and how it should go about achieving those goals.
ISO14001 requires that an environmental management system is planned properly. It requires the organization to consider the following carefully: Environmental Aspects; Legal and Other Aspects; Objectives and Targets; and an Environmental Management Program
The planning process begins with the identification of "Environmental Aspects", and "Significant Environmental Aspects". An "environmental aspect" is defined by ISO14001 (Section 3.3) as an "element of an organization's activities, products, or services that can interact with the environment." A "significant enviornmental aspect" is an environmental aspect that has a "significant environmental impact". "Environmental impact" is defined by ISO14001 as "any change to the environment, whether adverse of beneficial, wholly or partially resulting from an organization's activities, products, or services" (Section 3.4).
Sample environmental aspects include: Energy use/consumption (building, heating, cooling, lighting);
Material consumption (paper, office products);
Nonhazardous waste (scrap paper, empty cartons, containers);
Aluminum can and paper recycling;
Chemical use/consumption (degreasing and cleaning agents);
Water use/consumption;
Energy use/consumption;
Hazardous waste (sludge cake);
Wastewater discharges;
Unplanned releases;
Chemical use/consumption (oils);
Energy use/consumption;
Material consumption (metal plates) ;
Metals recycling/waste prevention;
Oil recycling/waste prevention;
Solvent reuse/waste prevention;
Nonhazardous waste (scrap metal, used oil, used solvents);
consumption (boxes, pallets, shrink wrap, paper, nylon tape); Recycling/waste prevention (plastics, wood, cardboard)
Nonhazardous waste (wood, plastics, nylon tape);
Chemical use/consumption (water-treatment chemicals);
Energy use/consumption (boilers, heating coils, building hearing, cooling, and lighting);
Nonhazardous waste (rinsed containers, metal scrap); etc.
These aspects are prioritized as significant by ranking them, by weighting environmental aspects; or by requesting opinions from experts.
IMPLEMENTATION [3/5]
- Structure and responsibility
- Training, awareness and competence
- Communication
- EMS documentation
- Document control
- Operational control
- Emeregency preparedness and response
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he crutial step to ensure success of an EMS is its implementation and operation. This step outlines the structure and responsibility of the implementation process; calls for training, awareness and competency to be developed; set up communication systems to keep everyone involved informed; document all steps and stages of the EMS; create document and operational control procedures; and also ensure that a plan for emergency preparedness and response is in place.
The two requirements for implementation of an EMS is to define, document, and communicate roles, responsibilities and authorities, and to allocate the resources needed to implement and control the EMS.
Awareness needs to be raised among staff members on the importance of complying with the EMS and how they can make a difference (the significance of environmental impacts of activities, and benefits of personal improved performance). Their roles and responsibilities to achieve EMS implementation, and objectives and targets, should be clarified. Also, the potential impacts of non-compliance with specified procedures should be indicated.
Communication is one of the most important components of EMS implementation. This can be internal and external communications. Internal communication is especially important - it needs to be multidirectional, not just top down. A procedure to receive, document and respond to external communications need to be put in place. With the extensive use of the internet and the world wide web, external communication to the wider public is becoming easier.
EMS documentation is critical in monitoring the implementation process. Responsibilities for documentation need to be clearly set and documents reviewed periodically, revised and updated, and approved by responsible staff. Documents need to be readily available and easy to locate - and obsolete documents retained for reference or other purposes are identifiable as such. The EMS Manual, operating procedures, work instructions, environmental records etc. are examples of EMS documentation.
Parallel to the documentation control process is the operational control process. Here, staff and their activities causing significant environmental impact are identified. EMS procedures and criteria for these staff and activities are established. These procedures and criteria are then communicated to suppliers and contractors for action.
Emergency preparedness is also part of the EMS implementation process. Potential for accidents and emergency situations are identified, and the associated environmental impacts prevented/mitigated. Emergency response and preparedness procedures need to be reviewed and periodically tested.
CHECKING [4/5]
- Monitoring and measurement
- Corrective and preventive action
- Records
- EMS audit
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he ISO14001 standard requires that the EMS be a 'living and applied' system. As such, checking and correction procedures are important to the standard. This is done through intensive monitoring and measurement; correction and prevention action; keeping proper records and undertaking EMS audits.
The key requirement in this EMS step is to regularly monitor and measure key characteristics of activities and operations
that could have a significant impact on the environment. Changes to EMS procedures may become necessary in order to deal with nonconformances with the EMS, with mitigating environmental impacts, or corrective and preventive action.
Under ISO14001, records are not simply documents. "Records" show evidence that an activity has actually occurred - internal memoranda, procedural forms, plans and other materials. "Documents" show evidence of current activities or those being planned. An organization is required to maintain procedures for the identification, maintenance and disposition of records. Training records and results of EMS audits and management reviews must be included.
Another key aspect of checking action is an EMS Audit. This is an audit that focuses on the EMS itself. It's important to note that an EMS audit focuses on whether or not the EMS conforms to ISO14001 requirements. The audit's scope, frequency, methodology and reporting responsibilities need to be clarified. Audit questions are directly related to the different requirements of ISO 14001, and check if they have been indeed carried out.
REVIEW [5/5]
- Meetings to review results of the EMS steps
- Decide on corrective and continual action
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he final requirement of the ISO14001 standard is Management Review. The EMS needs to be reviewed by top management periodically to make sure that the program is still suitable, adequate and effective.
The organization will be required to formalize a management review of the EMS, to both check on its progress and decide on future courses of action. Management review can be used to improve the EMS in line with the ISO14001 concept of "continual improvement"*.
Some of the broader review questions can include - Does the EMS address all activities, products and services including recent changes? Does the EMS contain any systemic problems? Is the EMS being complied with? Does the EMS provide a framework for continual improvement? Are legal and other requirements being met? Is information accessible and relevant? Are environmental targets being met? If so, can they be further improved?
The management review process ensure that information is collected to enable management to carry out proper review. Top management review the need for changes to policy, objectives and targets, and ensure that a commitment to continual improvement is being demonstrated.
Once the final audit is completed, an organization can go for "Self-declaration" or seek registration by an independent registrar who is accredited by ISO.
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Remember that "continual improvement" in ISO14001 refers to improvement of the EMS (i.e., the system), not the environmental condition. |
