ISO 14001:2015 Clause 4 Context of the organization
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One of the most significant changes to the 2015 standard is the introduction of an entirely new clause in the context of the organization. Context of the Organization makes it a formal requirement for organizations to consider:
- Your direct environmental impacts
- How environmental conditions can affect your business, customers and supply chain.
- External social and economic factors (e.g. beliefs and norms of society and its expectation of the organization, environmental performance of peers and competitors) and
- Internal capabilities (e.g. the organization’s ability to implement new technologies and influence behavior changes in its employees).
This significantly increases the planning work you need to do to maintain your ISO 14001 certification but the enhanced approach gives you a much better view of the risks and opportunities for your organization and will help develop a more robust corporate strategy. Past revisions of ISO 14001 required organizations to define the scope—the activities, processes, and buildings, and property within their EMS. The organization’s environmental policy included commitments to comply with applicable environmental regulations, reduce pollution, and continually improve its environmental performance. Context of the Organization is the first auditable part of ISO 14001:2015 and may be audited toward the beginning of the EMS audit. The auditor will be looking for and documenting high-level issues and available documentation that demonstrates the effective implementation of an organization’s EMS system.
Context of the Organization
One of the objectives of ISO 14001:2015 is the pulling together of an organization’s environmental internal issues, external issues, and interested parties that make up the firm’s business environment or the Context of the Organization. In the past, top management was never required to define the firm’s business environment as it related to internal and external issues or any interested parties. Internal issues might be air quality, waste hauling, and its costs. External issues might include customers and legal requirements. Interested parties could be the organization’s adjoining neighbors, and various local, state, federal environmental agencies. Customers also are interested parties as a result of their requirements for certain chemical use and other materials. Through the identification of the Context of the Organization, top management can focus on being more environmentally friendly and ensure that the organization remains in compliance with all regulations. Top management’s focus does not require documentation; however, most organizations will document the internal and external issues plus interested parties in the environment. It is also aimed at defining the EMS scope as it relates to the business operation. This scope could include additional items to the organization’s boundaries. An example might be air quality issues in the surrounding area of the facility, if important. This clause also defines in general terms an organization’s EMS system. This would include necessary processes for the organization to be successful. Some processes will be documented and others undocumented. Properly identifying the Context of the Organization will assist in the building of a complete EMS system that meets top management’s needs. While many ISO 14001-certified organizations included initiatives such as replacement of toxic materials, recycling activities, and reduction of fossil fuel use, the majority of the environmental programs fostered by certified organizations were “reactive” in nature. The new clauses of ISO 14001:2015, Understanding the organization and its context and Understanding the needs and expectations of interested parties, challenge organizations to analyze their operations and environmental impact from a more holistic, proactive vantage point.
With regard to the context of the organization, depending on the organization’s business model and environmental impact, there may be opportunities to have programs with a positive, proactive impact: air emissions related to climate change, improvement in soil quality of adjacent land or neighboring waterways, and supporting biodiversity (local flora-fauna) initiatives. The organization should be able to explain, within the context of its operations, what opportunities exist. A company producing machined parts or electronic components may have limited options; a large chemical plant, oil refinery, or paper mill may have many opportunities. In a similar fashion, in response to the expectations of interested parties, the organization should analyze how its activities and products may have an environmental impact on its customers, community, and neighbors. Examples could be end-of-life product disposal, voluntary labeling on products, reduction of unregulated materials, sustainable resources, and commitments to maintain adjacent community land or waterways. A key focus of ISO 14001:2015 is “life-cycle thinking,” considering each stage of a product or service, from development to end of life. Organizations producing consumer products may have many opportunities (but also challenges) to have an impact on product disposal, while manufacturers of components for sale to the industry may be limited in this regard. Organizations providing components for sale to the industry can demonstrate their commitment to life-cycle thinking by reducing or eliminating the use of environmentally challenged materials and maximizing recycle initiatives. Consumer product manufacturers can support life-cycle thinking by moving to “zero- landfill” disposal via waste-to-energy disposal options (waste is burned to produce electricity). ISO 14001:2015 requires organizations to put a policy in place that promotes environmental protection specific to the context of their business. Previous versions of ISO 14001 placed environmental protection in a somewhat reactive mode, where proactive initiatives included recycle programs and pollution prevention directly related to the organization’s manufacturing processes. With ISO 14001:2015, the organization is required to understand the important issues that can affect, either positively or negatively, the way it manages its environmental responsibilities. Examples include:
- Reduction of air emissions related to climate change
- Use of sustainable resources
- improvements in soil quality of adjacent land or neighboring waterways
- Support of biodiversity (local flora-fauna) initiatives
In addition to understanding the context of the organization, ISO 1400l:2015 requires the organization to understand the needs and expectations of interested parties The organization needs to review who are the interested parties related to its environmental compliance obligations: customers, neighbors, and community. The organization can then consider establishing voluntary compliance requirements that could impact the environment. Once it “volunteers,” the organization needs to live up to that commitment. Examples include life-cycle considerations related to product disposal, voluntary labeling on products, and environmental commitments to reduce unregulated materials (e.g., Styrofoam) or to maintain adjacent community land or waterways. The context of the organization and expectations of interested parties will be more applicable to large, multi-site organizations with transportation-related air releases- environmental impact or consumer products implication. Many organizations under ISO 14001:2004 considered greenhouse gases and climate change as part of their commitment to the prevention of pollution. External factors such as legacy issues (e.g., prior site ownership soil or water contamination responsibility) should always be part of the organization’s responsibility to ensure environmental controls are in place. At a minimum, the organization needs to present documented evidence that the context of the organization and expectations of interested parties were considered when establishing its EMS.
The “Context of Organization” clause has four sub-clauses ie
Clause 4.1 Understanding the Organization and its context
Clause 4.2 Understanding the needs and expectations of interested parties
Clause 4.3 Determining the scope of the environmental management system
Clause 4.4 Environmental management system
Clause 4.1 Understanding the Organization and its context
The organization should determine external and internal issues that are relevant to its purpose and affects its ability to achieve the intended outcomes of its environmental management system. Such issues should include environmental conditions which are affected by or have capable of affecting the organization.
- Here determine means to find out or establish.
- The purpose of the organization can be expressed through statements such as an organization ‟s vision, mission, policies, and improvement objectives.
- The term “intended outcome” means what the organization intends to achieve by implementing its EMS, which includes at a minimum the:
- enhancement of environmental performance,
- conformance to compliance obligations,
- fulfillment of environmental objectives, and
- protection of the environment
- An environmental condition can be defined as the “state or characteristic of the environment as determined at a certain point.” Environmental conditions can include: the climatic, air quality, water quality, and availability, and land use characteristics of a site, existing levels of contamination, pollution and environmental degradation, natural resource availability, and biodiversity, that can either affect the organization or be affected by the organization.
- Issues are those internal or external characteristics that can either positively or negatively affect the way the organization manages its environmental responsibilities and the ability of the organization to achieve the intended outcomes of the EMS.
- External issues can amongst others include local, regional and global environmental conditions, the views or positions of interested parties, or external cultural, social, political, legal, regulatory, financial, technological, and economic factors.
- Internal issues can amongst others include the level of management commitment and support, the competitive context and the availability of resources, including knowledge, organizational processes, and systems, and the nature of the organization’s activities, products and services, its strategic direction, and corporate culture.
As per Annex A (Guidance on the use of ISO 14001:2015 standard) of ISO 14001:2015 standard it further explains:
“The intent here is to provide a high-level, conceptual understanding of the important issues that can affect, either positively or negatively, the way the organization manages its environmental responsibilities. issues are important topics for the organization, problems for debate and discussion, or changing circumstances that affect the organization’s ability to achieve the intended outcomes it sets for its environmental management system.
Examples of internal and external issues which can be relevant to the context of the organization include:
a) environmental conditions related to climate, air quality, water quality, land use, existing contamination, natural resource availability and biodiversity, that can either affect the organization’s purpose or be affected by its environmental aspects;
b) the external cultural, social, political, legal, regulatory, financial, technological, economic, natural, and competitive circumstances, whether international, national, regional, or local;
c) the internal characteristics or conditions of the organization, such as its activities, products, and services, strategic direction, culture, and capabilities (i.e. people, knowledge, processes, systems).
An understanding of the context of an organization is used to establish, implement, maintain and continually improve its environmental management system. The internal and external issues that are determined can result in risks and opportunities to the organization or to the environmental management system. The organization determines those that need to be addressed and managed.”
Clause 4, the “Context of the Organisation” requires:
- a high-level and conceptual understanding of the context of the organization,
- an understanding of the needs and expectations of interested parties and
- the determination of the scope of the EMS.
Clause 4.1, “Understanding the Organization and its context” calls for the determination of internal and external issues:
- That is relevant to the purpose of the organization;
- That affects the ability of the organization to achieve the intended outcomes of the EMS;
- That is related to those environmental conditions
- that can affect the organization and
- that can be affected by the organization.
Clause 4.1 calls for a high-level and conceptual understanding of the organization and its context. This understanding can be gleaned from a high-level or strategic determination and analysis of the internal and external issues that are:
- relevant to the purpose of the organization and
- that can affect the ability of the organization to achieve the intended outcomes of the management system.
The qualifier ‘relevant to the purpose of the organization is primarily a quality management concept, but in terms of the EMS, it means that any issues that are not relevant to the purpose of the organization can be readily discarded.
The issues that can affect the ability of the organization to achieve the intended outcomes of the EMS are issues that can either enhance or impede the achievement of these intended outcomes. This is quite important, as Clause 6.1.1 requires the determination of risks and opportunities that are posed by these issues. The issues capable of enhancing the ability of the organization to achieve the intended outcomes of the EMS are leveraged as enabling opportunities, while those capable of impeding the achievement of intended outcomes are managed as risks. The organization often does not have any control over these risks. The mitigation of and adaptation to the effects of these external conditions are often the only response strategies available to organizations. Also note that the term “affect‟ is used in this standard to refer to the potential changes caused by these issues, while the changes caused by the organization ‟s activities, products, and services to the environment are referred to as “impacts‟. These issues can originate from inside the organization as well as from outside the organization. The issues that originate from within the organization can range from matters such as leadership commitment, the organizational culture, and the availability of resources such as skills, infrastructure, information, etc. Those issues that originate from without the organization can be caused by environmental conditions as well as the regulatory, political, infrastructural, service delivery, social and cultural dimensions within which the organization operates. External environmental conditions that can affect the organization include impeding factors such as climate change (on a global scale), the availability of natural resources, weather conditions, flooding, fires, and seismic events (on a local scale), and enhancing characteristics such as location relative to natural resources and markets. Being situated outside the impact zones of natural disasters or existing in a stable and democratic socio-political system with a skilled and reliable workforce can offer opportunities that can be leveraged by organizations
Internal and External issues
The issues contemplated under clause 4.1 also include the effects on environmental conditions that are caused by the organization. These effects are actually synonymous with the environmental impacts caused by an organization’s activities as contemplated in clause 6.1.2. If the identification of the environmental aspects and impacts are required in terms of clause 6.1.2, the question is what then is required in terms of clause 4.1? The determination of the effect of the organization on environmental conditions differs from the identification of environmental aspects and impacts insofar that the former is performed at a high, strategic or conceptual level, while the latter is a more detailed and operational-level analysis.
The output of clause 4.1 includes a conceptual and high-level overview of:
- External issues that are relevant to the purpose of the organization and that affect its ability to achieve the intended outcomes of the EMS;
- Internal issues that are relevant to the purpose of the organization and that affect its ability to achieve the intended outcomes of the EMS;
- Environmental conditions that are affected by the organization; and
- Environmental conditions that can affect the organization.
Example of internal and external issues.
Example: A family-owned company, manufacturing wooden outbuildings for domestic and commercial use. The organization’s purpose is to provide both retail and bespoke sectional buildings to individuals and organizations.
Example internal issues:
- Transport and site erection costs/service
- The culture within the organization/governance and succession issues
- Opportunities to move from product to service e.g. leasing and maintenance of buildings
- Relationship with supply chain (timber traceability etc.)
- Potential sustainable material replacement program (products/packaging)
- Material consumption (recycled, durable, reusable, recyclable, biodegradable)
- Energy management
- Wastage of raw material/waste disposal/developing market for by-products
- Structure of the organization
- Roles within the organization
- Business growth strategy
- Return on investment
- Product/service quality
- Capital expenditure
- Debt and interest
- Liabilities (e.g. Public)
- FairTrade/Ethical trading
- Availability of reliable, qualified and competent workforce
- Stability of workforce/HR practices
- Impact of unionization
- Staff training levels
- Contractual arrangements with customers
- Payment terms from customers
- Solvency of customers
- Expansion of customer base
- Cash flow
- The overall strength of business to support funding needs
- Resilience of infrastructure
- Relationship with investors (including Bank)
- Credit rating and availability
- Health and Safety on-site and on client site
- Design for Environment
Example of external issues:
- Political, economic.social, technological, legal and regulatory
- Supply chain resilience
- Market sensitivity to habitat loss and biodiversity issues
- Overall economic performance in the country
- Economic plans for future
- Market conditions (customer demographic/market confidence etc.)
- Customer expectation
- Standardization and certification within the industry
- Impacts of climate volatility
- Changes to the local environmental setting (development/designation of Conservation areas/development of flood defences etc.)
- Fuel/raw material prices – international pressures, domestic market pressures government taxation regime, etc.
- Regulation within the industry generally
- Trade associations and lobbying powers
- Impact on neighbours
Clause 4.2 Understanding the needs and expectations of interested parties.
The organization should determine the interested parties that are relevant to the environmental management system and their relevant needs and expectations (i.e. requirements). The organization should also determine these needs and expectations become its compliance obligations.
- An “interested party” (also known as “stakeholder”) is any individual or organization that can affect, be affected by, or perceive itself to be affected by your organization’s decisions or activities. Interested parties may include, for example, customers, communities, suppliers, regulators, NGOs, investors, employees and trade unions.
- The phrase “compliance obligations” replaces the phrase “legal requirements and other requirements to which the organization subscribes” used in prior editions of this International Standard. The change is considered simpler to understand and does not change the intent of the previous standard ie ISO 14001:2004.
As per Annex A (Guidance on the use of ISO 14001:2015 standard) of ISO 14001:2015 standard it further explains:
“An organization is expected to gain a general (i.e high-level, not detailed) understanding of the expressed needs and expectations of those internal and external interested parties that have been determined by the organization to be relevant. The organization considers the knowledge gained when determining which of these needs and expectations it has to or it chooses to comply with, i.e. its compliance obligations.
In the case of an interested party perceiving itself to be affected by the organization’s decisions or activities related to environmental performance. the organization considers the relevant needs and expectations that are made known or have been disclosed by the interested party to the organization.
Interested party requirements are not necessarily requirements of the organization. Some interested party requirements reflect needs and expectations that are mandatory because they have been incorporated into laws, regulations, permits, and licenses by governmental or even court decisions. The organization may decide to voluntarily agree to or adopt other requirements of interested parties (e.g entering into a contractual relationship. subscribing to a voluntary initiative). Once the organization adopts them, they become organizational requirements (i.e. compliance obligations) and are taken into account when planning the environmental management system. A more detailed-level analysis of its compliance obligations is performed in clause 6.1.3″
This sub-clause requires that interested parties relevant to the EMS are determined. This is a step up from the 2004 version of the standard, in which the determination of interested parties was not explicitly required. The general interpretation of the 2015 requirement is that evidence of this determination is required. Once the interested parties have been identified, the organization is required to determine their needs and expectations. Once all the needs and expectations of interested parties have been determined, the organization needs to make a decision about which of these needs and expectations it will adopt and manage. Once adopted, these needs and expectations become compliance obligations requiring management by the organization. Responding to and addressing these adopted compliance obligations are obligatory. What are your organization’s requirements with respect to interested parties?
- Determine who are the interested parties relevant to your environmental management system (EMS). Incidentally, an organization that “perceives itself to be affected” by your decisions or activities obviously needs to make that perception known to your organization before being listed as an interested party. It would be good practice to create a “register of interested parties”.
- Determine the relevant needs and expectations of these interested parties
- Decide which of these needs and expectations are to be “compliance obligations”. Any needs and expectations that are mandatory (eg. legal obligations, contract requirements or court decision outcomes) are automatically compliance obligations. Beyond these, only needs and expectations that you consider relevant and that you choose to adopt become compliance obligations. So, you can choose to ignore some non-mandatory interested party needs and expectations.
- Make available to interested parties the “scope” of the EMS (ie. the organization’s activities that are included in the EMS), and the environmental policy. Ensure communication with interested parties meets their needs, is understandable by them, and enables them to participate. Keep records of such communications.
- Provide, to appropriate interested parties, relevant information and training related to emergency preparedness and response.
- And be mindful of the needs and expectations of interested parties when developing or reviewing environmental aspects.
- In the case of an interested party “perceiving itself” to be affected by your organization’s decisions or activities related to environmental performance, your organization must consider the relevant needs and expectations that are made known or have been disclosed by the interested party and then make a decision whether to adopt them
CLASSIFYING INTERESTED PARTIES AND THEIR RELATIONSHIPS
Simply listing suppliers, customers, communities, etc. is not enough to meet the requirements of the standard i.e. understanding the needs and expectations of relevant interested parties. Make the information more meaningful by grouping interested parties based on their relationship with the organization. This is advised in ISO 14004 – EMS Guidelines for Implementation, which provides examples of interested parties based on their relationship with the organization, by their:
- Responsibility – investors, etc.
- Influence – pressure groups, etc.
- Proximity – neighbours, etc.
- Dependency – employees, etc.
- Representation – trade unions, etc.
- Authority – regulators, etc.
Some categories may contain sub-categories, which require a different management approach. For example, customers may include key accounts which have different needs and expectations to transactional customers. Now you know who your interest parties are, it is time to identify their needs and expectations which are relevant to your management system. The operative word here is relevant. Depending on the size and complexity of your organization, it is very likely that you or your colleagues will have a good feel for the interested parties you have regular contact with. However, it is worth formalizing this knowledge and, where needed, confirming assumptions and closing knowledge gaps with research. The scale of research again depends on the size and complexity of your organization. For example:
- A two-person gardening firm may be able to complete research within a few phone calls to clients, suppliers, local council, etc.
- A multi-national pharmaceutical company may require a range of research methods (quantitative and qualitative, primary and secondary).
This relates two important relationship variables:
- How much interest do they have in your decisions and activities? This could be interpreted as the strength of their relevance.
- How much power or influence do they have over your decisions and activities? This could be interpreted as their significance or risk.
Plotting interested parties help to prioritize the effort required to meet their needs and expectations:
Process for mapping interested parties
- Identify relevant interested parties. Compile a categorized list of your interested parties.
- Determine their needs and expectations. Use different research methods as necessary to confirm your knowledge of each group or significant stakeholder.
- Rank them in terms of power and interest: Consider their strength of interest and level of influence over your decisions and actions. Plot them in the Power/Interest Matrix to determine their rank.
- Set objectives and priorities. Define what results are necessary to deliver to those relevant interested parties to reduce the risk that their needs and expectations are not met.
You should end up with something like this example – but create a framework that suits your own needs:
|Interested Party||Needs/Expectations||PI rank||Objective||Priority|
|Customer||Expect the organization to supply goods and service on time||Keep satisfied||Achieve revenue targets, Retain contracts, Increase repeat order||High|
Example of interested parties and potential needs/ expectations ( – to be verified in practice):
Example: A family-owned company, manufacturing wooden outbuildings for domestic and commercial use. The organization’s purpose is to provide both retail and bespoke sectional buildings to individuals and organizations. (same example as taken previously from Clause 4.1 Understanding the Organization and its context )
External Interested parties and potential needs/expectations
|External Interested parties||Needs/Expectations|
|Government||Prompt payment of taxes due|
|Customers||Prompt delivery/good value|
|Product End User (Customer’s customer)||Prompt delivery/good value|
|Neighbors/Local community||Lack of intrusive noise or odour or vibration|
|Insurer||Good and demonstrable risk management|
|Suppliers (1st, 2nd, 3rd tier)||Level playing field/prompt payment/clear work instructions/good working conditions/fair approach to tractability and custody chain/fair trade|
|Utility companies – power, water, fuel, telecoms||Prompt payment/good resource management|
|Staff dependents||Maintenance of income, reputation|
|Trade bodies/associations||Adherence to professional and membership requirements. Maintenance of standards|
|Competitors||Maintenance of reputation of the sector. Ethical behaviour|
|Investors||Return on investment. Demonstrable Risk Management|
|Emergency services||Good risk management. Emergency procedures in place and drilled|
|Business partners||Solid economic growth. Good risk management|
|Contractors||Level playing field/prompt payment/clear work instructions/good working conditions|
|Bank and/or other finance providers||Good risk management, prompt payment on loans|
|Environmental pressure groups||Good risk management, active regeneration projects|
Internal Interested Parties and potential needs/expectations
|Internal Interested Parties||Needs/Expectations|
|Directors||Good risk management continued growth|
|Business Partners||Good risk management, Good reputation, continued growth|
|Workers'(labor) representative (Union)||Good working conditions, training opportunities, maintenance of company reputation and good working relations|
|Staff||Good working conditions, training opportunities, maintenance of company reputation and continued income|
|Family Members||Good governance, maintenance of legacy, good reputation, good risk management|
4.3. Determining the scope of the environmental management system
The organization should determine the boundaries and applicability of the environméital management system to establish its scope. When determining this scope, the organization should consider its organizational units, functions, physical boundaries, activities, products, services, authority, and ability to exercise control and influence. The organization should also consider its external and internal issues referred and their compliance obligations.
As per Annex A (Guidance on the use of ISO 14001:2015 standard) of ISO 14001:2015 standard it further explains:
“The scope of the environmental management system is intended to clarify the physical and organizational boundaries to which the environmental management system applies, especially if the organization is a part of a larger organization. An organization has the freedom and flexibility to define its boundaries. it may choose to implement this international Standard throughout the entire organization, or only in specific parts of the organization, as long as the top management for those parts has authority to establish an environmental management system. In setting the scope, the credibility of the environmental management system depends upon the choice of organizational boundaries. The organization considers the extent of control or influence that it can exert over activities, products, and services considering a life cycle perspective. Scoping should not be used to exclude activities, products. services, or facilities that have or can have significant environmental aspects. or to evade its compliance obligations. The scope is a factual and representative statement of the organization’s operations included within its environmental management system boundaries that should not mislead interested parties. Once the organization asserts it conforms to this International Standard, the requirement to make the scope statement available to interested parties applies.”
Once the scope is defined. all activities, products, and services of the organization within that scope need to be included in the environmental management system. The scope shall be maintained as documented information and be available to interested parties. Making the scope available to interested parties is a passive duty as the requirement is not to actively distribute the documented scope of the EMS. The requirement to make the EMS scope available to interested parties is an attempt to counter concerns that organizations misrepresent the actual scope of their EMSs.
An example of how a scope could be derived
1. Organization’s purpose and strategic direction
- Purpose: As one of India’s leading providers for sheetfed and heat set lithographic printing services, our reason for’being’ is a combination of our vision, mission, and values.
- What is our vision? To become the most trusted provider for print services within India and Europe.
- What is our mission? To expand our operations by consistently meeting customers’ expectations and our legal requirements; which includes the enhancement of customer satisfaction, and protection of our environment. through the effective application of our processes for continual improvement and environmental performance.
- What are our values? Sustainable business, social economic and environmental impacts, responsible governance and equal opportunity. These are re-enforced through sustainability principles and workforce integrity throughout all business operations. Cooperation and collaboration are expected norms within the organization’s management, with recognition provided for all through regular appraisals. We encourage and embrace any values which support the behaviours that employees cherish.
- Strategic Direction: To open a new office in Germany and New Delhi this year bringing together the technology and expertise in India with the market needs of Europe and beyond. To implement and gain accredited certification to ISO9001 and ISO14001 in these new offices, within a year of the offices opening. To employ a motivated workforce that will embrace the organization values, and complement the cooperation and collaboration needed to achieve the effective application of our processes for continual improvement.
2. Organization’s intended outcome(s) of its EMS
From the’1 Scope’ of the Standard:
- To provide value for the environment, our organization, and our interested parties
- To enhance our environmental performance
- To fulfil our compliance obligations; and
- To achieve our environmental objectives
Specific to our organization:
- A more sustainable product, with the smallest possible carbon and resource footprint;
- Financial benefit through the effective application of improvement and operational processes
- Effective control/influence over interested parties, within our product life cycle, thereby improving our overall environmental performance
3. External issues
- Honey Printers Pvt. Ltd is situated in Khopate, a medium-sized town of some 60,000 inhabitants. The Good Prospect factory is a three-floor complex that comprises both the print works and offices of Honey Printers, taking up nearly 50,000sq feet of space in total. The rest of the site is shared with other office-based companies who occupy the remaining floors of the complex which consists of a 16 story high rise building. (Issue: Noise vibration odour interested party complaints.)
- The entire complex is situated west of the tunnel, just off the main Uran-Panvel Road, overlooking JNPT Harbour, a major trading port area. Like most places on the island, its position is tightly constrained by neighbouring buildings in a mixed business and residential area. (Issue: Carbon footprint increase and contribution to traffic congestion and emissions through vehicle fleet noise, odour, interested party complaints)
- The company operates a prescribed process using regulated substances in accordance with a license issued under Regional Regulations. (Issue: Legal Compliance)
- In addition, it is required to comply with a discharge permit from the MPCB EPD via the Water Pollution Control Ordinance in respect of process wastewater discharges to receiving water bodies. (Issue: Legal Compliance)
MPCB EPD regularly inspects operators, responds to complaints and, after an uncertain enforcement record in the late ’90s, has a strong and growing record of successful prosecution. (Issue: Fines and legal cost)
- Navi Mumbai is generally very hilly and particularly so in the Northern area where the Panvel sits on a relatively narrow ledge of rock between hillsides and the sea. In common with the rest of the island, the underlying geology of the site comprises volcanic rock and granite. (Issue: Potential flood zone raised sea level from Climate Change)
- To the rear of the site, the Sai Laxmi Park acts as home to the Upper and Lower reservoirs (capacity 266 million imperial gallons/1,210,000m3 ). A nature trail runs through the tops of the hills immediately overlooking the site. (Issue: continuity of process water supply, VOC emissions, and effect on biodiversity)
In addition, to the front of the site, the concrete flyover feeds the tunnel, the main access point to the area known as ‘MHADA colony’ a prime residential location. (Issue: odour complaints from the influential interested party/interested parties)
- The nearby JNPT Harbours continues to be the focus of development for the Navi Mumbai Harbour Area Treatment Scheme (NMATS) into which, traditionally, most of Sewage and effluent had been ejected. However, the declining quality of the marine environment prompted an urgent program lead and funded by, the State Government. (Issue: Contribution to local water pollution, legal compliance)
- Navi Mumbai can experience very heavy rainstorms during Monsoon. The annual average rainfall is about 245 cm. During particularly heavy rainstorms, flooding in the rural low-lying areas and natural flood-plains in the northern part of the territory and in parts of the older urban areas may occur. The Panvel is a formally identified flooding hotspot. (issue: Flooding)
- In recent years, the company has had an increase in requests from customers for environmental information concerning the company’s products and activities, particularly in the areas of paper sourcing, energy use and CO2 emissions from transport.Key customers appear to be implementing procedures to include environmental performance in supplier selection criteria and Honey Printers Pvt. Ltd has been unable to respond adequately to requests for information. (Issue: Interested party complaints, evaluation of compliance with customer requirements)
- Guidance documents on environmental responsibilities have been published by relevant local industrial trade associations and the Maharashtra Pollution Control Board (MPCB) and the company is beginning to make use of those. (Issue: Interested party complaints, legal compliance)
- In response to international market pressures and to ensure that the company’s interested party expectations were being met, the management of the company authorized the implementation of an Environmental Management System. The company decided not to acquire a third-party certification of the system. (Issue: Loss of interested party confidence, demonstrable corporate responsibility open to question)
- The company was formed 40 years ago and has always operated at the Good Prospect Factory.Early production focused on servicing local and regional customers. Original print runs (number of copies printed) were high due to the fact that even relatively small jobs were printed in two or three different language versions, including English, Hindi, and Marathi. (Issue: Contaminated land from previous operations.)
- With the increasing demand for the short run, lower volume and better quality printing, Honey Printers Pvt. Ltd invested heavily in new sheet-fed lithographic printing equipment to extend their printing capabilities into the international market for ‘on demand’ and bespoke the catalog printing.(Issue: Higher resource use from cleaning between the high number of low print runs, high potential emissions and hazardous waste from solvent based cleaning materials larger carbon footprint from international distribution of finished product greater concern on ROI from earlier technology investment leads to less funding for environmental projects )
4. Internal issues
- Honey Printers Pvt. Ltd prints collate and bind publications for a variety of customers. It also arranges transportation of the finished publications either direct to customers’ warehouses (due to the lack of bulk storage on their own site), or straight to the client’s target audience in India and the rest of India through a direct mailing system.(Issue: Energy use, resource and material use)
- The site is taken up mainly by the Good Prospect Factory of which the bottom floor is entirely occupied by the primary print production facility (the 4sheet fed lithographic presses as well as associated paper holding bays, ink stores). There is very little space to spare and stores on site are kept to a minimum, relying on just in time delivery of materials. (Issue: Energy use resource and material use hazardous substances, carbon management)
- There is also a bindery area comprising 4 saddle stitch and 4 perfect binder lines where signatures (individual pages of the publications) from the presses are collated together and bound. A small holding bay also exists for finished publications. (Issue: Energy use, air emissions resource, and material use)
The remainder contains the following operations:
2nd floor; Prepress preparation area (scanners, proofers and plate managers) secondary print area (2 high-speed photocopying machines) Includes a small area for General Stores. There is also a Direct Mail Unit, including stores for packaging, a small area for progress checking. (Issue: Energy use resource and material use hazardous substances)
3rd-floor Offices for Production Administration, Sales and Purchasing, Executive functions, Staff Restaurant, and a separate testing laboratory for checking inks and adhesives. (Issue: Energy use resource/material use and hazardous substances)
- The site employs a total of 62 people, with 5 working mostly off-site as Sales Representatives. Nineteen people work in the administrative section which comprises sales, orders, purchasing, and accounts. Operational staff work on a 3 shift, 24-hour day, 6 days a week system.Shift hours are: 6 am — 2 pm, 2 pm — 10 pm, and 10 pm – 6 am. (Issue: Energy use, resource, and material use)
- Occasionally work is carried out over the weekends, mainly for maintenance or for direct mail campaigns but sometimes to accommodate extra work for urgent, complex or large orders. (Issue: Energy use, interested party complaints about noise and vibration)
- The company already operates Quality and Health and Safety Management Systems and where appropriate, environmental controls have been integrated into these existing systems. The company started developing its Environmental Management System last year.The Facilities Manager was charged with the responsibility of implementing the system by the Board; he has delegated the responsibility on a day to day basis to the new post of Head of Safety, Health Environment, and Quality (SHEQ), created six months ago. (Issue: resources to support system)
- The project has involved other managers including both the Operations Manager and the Accounts and Purchasing manager. The Facilities Manager’s previous environmental experience relates only to health and safety, and he has only recently had responsibility for environment added to his job speciﬁcation. (Issue: resource and training required to maintain competence)
- The Head of SHEQ has overall responsibility for maintaining the environmental manual as part of the integrated environment, health and safety and quality system. He wrote the environmental manual and general procedures on environmental management, whilst the Facilities Manager, aided by the Operations Manager was responsible for the more technically based documentation. (Issue: loss of staff and associated competence)
- The site conducted an initial review (12 months prior to audit), and has since developed an environmental policy and environmental manual containing programs and procedures for managing the site’s operations.
- Operations at the site include preparation for the presses where customer’s artwork is received via electronic transfer of ﬁles, though special artwork can sometimes require hard copy delivery. (Issue: Energy use, GHG release, resource and material use, hazardous substances, the potential for spillage and associated contamination of land or process water and stormwater discharges.)
- This information is converted into images on cellulose ﬁlm in the prepress area. The images are stabilized using ﬁxer and developer before the image is transferred to aluminium plates by high-energy UV rays. Typically this equipment uses 2,500 watts for operation (Issues: Energy use, resource and material use, hazardous substances and associated waste and water discharges)
- Plates are then cleaned in a sink with chemicals and taken to the mu|ti—unit print presses, where printing ink is applied to the paper substrate via the aluminium plates to produce the printed image (signatures). (Issue: Energy use, resource and material use, hazardous substances and associated waste and water discharges)
- The inks can be premixed or are applied as standard colours to different plates to produce the right co|our. This is checked against standard specifications. (Issue: hazardous substances and associated waste and water discharges)
- The transfer process is carried out using a fountain solution, which is produced by dosing mains water with fountain solution chemical to get the desired dilution. Surface coating of publication covers is sometimes requested, and this is applied during the printing process. (Issue: resource use (water) hazardous substances and associated waste and water discharges)
- Bindery operations are where the ﬁnished elements are collated together and bound either by inserting metal wire staples or glued (perfect bound) together. The ﬁnished publications are bound and shrink-wrapped onto wooden pallets prior to shipping to the customer (Issue: Packaging hazardous substances and associated waste and water discharges)
- Feedstocks mainly comprise cellulose ﬁlms, aluminium plates, and paper. Liquid raw materials include printing inks, binding adhesives; heat-seal coatings, cold-seal coatings, and solvents. (Issue: Resource use)
- Drummed solvents are dispensed into 25-litre containers for internal transport to process areas. Inks are delivered in half tonne mini-bulk tanks and are off-loaded in the ink storage area, at the rear of the building. The inks are transferred manually to the sheet-fed printing presses, but the latest line can be fed from an integral reservoir. Other coating materials are delivered in either 25 or 200-liter drums, directly to the primary Print Shop room. (Issue: Packaging, hazardous substances, and associated waste and water discharges)
- Inks from bulk storage tanks and smaller containers are blended on-site to produce “ﬁnished” printing ink and adhesives, originally premixed in a separate Mixing Room, are now mixed in a small area next to the main presses to make efﬁcient use of the main air, emission abatement equipment ducting that was installed (ﬁve years prior to audit). Consumption of inks is estimated at 35 tonnes per month. Emissions from pre-mixing operations are vented directly to the atmosphere. (Issue: Packaging air emissions, hazardous substances, and associated waste and water discharges)
- Printing and coating are carried out in the Print Shop, which is split into four distinct work areas; sheet-fed lithographic presses take up the entire space. Two high-speed photocopying machines sit together on the second ﬂoor as a self-contained ‘print on demand’ unit. (Issue: Energy use, hazardous substances, resource use, and associated waste and water discharges)
- Printing operations involve the application of materials with relatively high solvent content to the surface of a moving plate or ﬁlm. Rapid solvent evaporation is achieved by the movement of heated air across the plate and sheet surface, which results in solvent laden air being emitted from the system. (Issue: Energy use, hazardous substances, air emissions)
- All application of printing inks and other wet materials is carried out in the Print Shop area and associated cleaning rooms. Volatiles are either captured by the abatement equipment in the Print Shop area or vented directly to the atmosphere by the building’s forced ventilation system. (Issue: water discharges, air emissions)
- Total solvent losses to the atmosphere from pre-mixing and printing processes were estimated to be about 0.5 tonnes per month prior to a change of ink supplier and product. (Issue: water discharges, air emissions)
- Cleaning of printing equipment is carried out in a self-contained, solvent emissions ducted washroom adjacent to the Print Shop. The plant is solvent based and uses 1 tonne per year of ethyl acetate and ethanol. An underground sump collects waste residues from the cleaning process and is emptied bi-annually. (Issue: water discharges, air emissions, contaminated land from the underground tank).
- In addition, there is an ultrasonic cleaning plant, which uses an aqueous caustic solution for roller cleaning and ancillary cleaning. Twenty-five litres of ethyl acetate is used per application, which is thought to be captured by the abatement ﬁltering system but may also ultimately be lost to the atmosphere. Both sets of the plant are themselves cleaned periodically with cleaning liquids (solvent and caustic), being fully replaced with fresh chemicals. (Issue: Energy use, hazardous substances, water discharges, and air emissions)
- Finished goods are packaged manually in the Finishing Department. Due to the restricted size of the storage area, the site operates its own distribution service and owns ten 7.5 tonne trucks. In addition, some delivery is subcontracted to a Local carrier which may move ﬁnished goods to a leased warehouse in Indore for further distribution. (Issue: Energy use, vehicle emissions)The Testing Laboratory employs a full-time chemist who carries out sample testing of incoming inks. Small quantities of numerous different solvents, inks and other chemicals are used to test different ink formulations and are stored in a dedicated storage room within the laboratory. (Issue: Hazardous substances, spillage, waste disposal, and water discharge).
- Hazardous wastes are generated from primary production, laboratory operations, and cleaning processes. Waste inks and solvents are stored in a bulk container for off-site recycling.So|vent-based inks are ﬁltered on-site to produce a solvent waste stream which is recycled and a solid waste stream which is disposed of as hazardous waste. (Issue: Liquid and solid, hazardous and general waste)
- Waste cooling waters from the printing lines are discharged to a foul sewer. The area’s drains are to be included in the second phase of the Navi Mumbai Area Treatment Scheme (NMATS) under the management of the MPCB EPD. They currently discharge directly to the harbour via a 1-kilometre undersea outfall pipe. (Issue: water discharges, the current level of marine pollution)
- Stormwater surface drains are currently blocked in the solvent storage area and the site has constructed an underground sump to collect local rainwater ﬂooding this area. The sump discharges to the stormwater system, which in turn discharges directly to the harbour via the area outfall pipe already mentioned. (Issue; ﬂooding)
- Volatile organic compound (VOC) emissions from the pre-mixing operations, printing, and (occasionally) binding activities are mostly vented to atmosphere through abatement ducting, fans and ﬁlters which have been retroﬁtted in the print shop area. Fugitive emissions include those from manual transfer of solvents and inks, ink mixing, adhesives, from the bindery emissions from the test laboratory and those from the ultrasonic cleaning plant. (Issue: Air emissions)
- The site has received complaints from the public and other local businesses concerning both noise and odours. In the past six months, over eight complaints have been received from four different sources regarding noise, and approximately seven complaints have been made about strong odours from four different sources, two of which also complained about noise problems. (Issue: Interested Party complaints)
- The site’s planning/land use permission contains limits on environmental noise emissions between the hours of 17.00 and 08.00, of 45 dB(A). The local Environmental Inspector has conducted noise monitoring and has recorded an exceedance of this limit on two out of 14 occasions during the regulated time period. The local government administration has, therefore, requested that the site implements environmental noise reduction measures where practical. Response to this request in ongoing. (Issue: Legal Compliance)
- The site is developing a program to implement the license requirements to manage and reduce emissions of VOCs to the atmosphere. This is being monitored carefully by the MPCB, who are keen to ensure regulatory requirements are met, and that public complaints are reduced. (Issue: Legal Compliance)
The site had a small spill of toluene to the stormwater drain approximately one month ago, when a drum was knocked over which was not sealed. This was immediately reported to the authorities.
4. Interested Parties and needs and expectations of Interested Parties.
Needs and expectations of External interested parties
|External Interested Parties||Example needs/ Expectation|
|Regulators||Identiﬁcation of applicable statutory and regulatory requirements for the environmental aspects under our control/ inﬂuence, understanding of the requirements, the application within our EMS, update/maintenance of them, compliance to them, prompt responses to investigations and inquiries|
Needs and expectations of Internal interested parties
|Internal Interested Parties||Needs/Expectations|
|Staff including drivers,|
bindery, loading etc.
5. Compliance obligations
All the above will become compliance obligations with the exceptions of:
- Media (All) This will be re-visited once the EMS is operational
- Customers( 4. Environmentally sustainable product), we are striving for this but this will not become a compliance obligation yet
- Distributors ( 2. Continuity of product supply), we cannot guarantee
- Neighbours (1.Absence of noise/odour/vibration incidents), we cannot guarantee: the absence of noise/odour/vibration incidents but a compliance obligation will be reductions wherever ‘reasonably practicable’
- Staff (3. Training and support for all and 5.Continuity of employment) we cannot guarantee, depends on budget, etc.
- Contractors/Suppliers (4.Level playing field for all environmental requirement), we cannot guarantee at the present
6. Organizational unit(s), function(s), physical boundaries
‘Honey Printers Pvt. Ltd operates from its sites in Panvel, Navi Mumbai, and soon in Pune and New Delhi. No sites are/will be shared with other organizations and each site has a clearly deﬁned boundary/demarcation to their neighbors. At each site, the organizational unit(s)/ function(s) comprises of Ofﬁce administration (ﬁnance, sales, order processing, Support functions, HR, Quality, IT, Environmental, OH&S, general management), Design of customer’s artwork. At the Panvel, Navi Mumbai HK Isite only, Development (preparation), Production (Printing signatures), Production (pressrooms), Production (bindery), and ﬁnal Dispatch of printed materials (Delivery).
7. Activities, products, and services of the organization
The design, development, production, and delivery of a range of high-quality and environmentally sensitive printing solutions. Print work providers for sheetfed and heat set lithographic services and can be prepared on a bespoke basis, or chosen from a range of standardized offerings. Delivery is provided through outsourced transportation services.
8. Authority and the ability to exercise control and inﬂuence
Full authority and ability to control is possible over our main printing sites in Navi Mumbai, Pune, and New Delhi, and a strong authority and ability to inﬂuence over our outsourced transportation services. We have a strong authority, and great ability to inﬂuence our paper sourcing suppliers’ environmental performance and that of our inks procurement suppliers’ environmental performance. However, we have little authority and limited ability to inﬂuenceunused stock policies from our customers. Our current levels of inﬂuence over our customer’s choice of environmentally benign raw materials are not high, though we are seeking to increase this through a change in policy in sales contract negotiations. Finally, we have no authority and marginal ability to influence the final disposal of our product.
9. Determined scope
The scope of ‘Honey Printers Pvt. Ltd’ Environmental Management System applies to the design, development, production, and delivery of a range of high quality and environmentally sensitive printing solutions from its site in Hong Kong, with a planned rollout program to include our proposed Germany and Beijing ofﬁces. Print work providers for sheetfed and heat set lithographic services and can be prepared on a bespoke basis, or chosen from a range of standardized offerings. It covers the management of business activities that support these products and services (including transportation outsourcing) and the influences (where possible) of any significant aspects that occur in its life cycle e.g procurement, unused stock, and final disposal.
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4.4 Environmental management system
The organization must establish, implement, maintain and continually improve its environmental management system, which includes its process and its interactions in accordance with the requirements of these international standards so as to achieve its intended outcome which includes enhancing its environmental performance. While establishing and maintaining its environmental management system the organization should consider the knowledge gained while determining its external and internal issues and needs and expectations of interested parties.
As per Annex A (Guidance on the use of ISO 14001:2015 standard) of ISO 14001:2015 standard it further explains:
The organization retains authority and accountability to decide how it fulfills the requirements of this International Standard. including the level of detail and extent to which it:
a) establishes one or more processes to have confidence that it is controlled, carried out as planned, and achieve the desired results;
b) integrates environmental management system requirements into its various business processes such as design and development, procurement, human resources, sales, and marketing;
c) incorporates issues associated with the context of the organization and interested party requirements within its environmental management system.
if this international Standard is implemented for a specific part of an organization, policies, processes and documented information developed by other parts of the organization can be used to meet the requirements of this. International Standard, provided they are applicable to that specific part
ISO 14001:2015-Clause 4.4 states that the organization shall establish, document, implement, maintain and continually improve an EMS, the requirements which encompass all the requirements of the Standard. The words used in the Standard are ‘establish’ and ‘maintain’. There is no guidance as to the level or depth of establishment or what evidence is required to show maintenance. However, it can be taken to mean that there must be some objective evidence of the system being in place and reviewed and revised. Such review processes can take the form of monthly progress meetings, corrective actions from audits, and of course audit themselves. Audits are evidence of reviewing; that is, asking the question: ‘Are the planned activities of the organization occurring in practice?’ It would be very prudent for an implementing organization to offer evidence of one or two audits of a significant impact over a period of 2 to 3 months. An improvement in the environmental management system is intended to show an improvement in environmental performance. The organization is expected to periodically review and evaluate its environmental management system to identify opportunities for improvement and its implementation. The rate, extent, and timescale of this continual improvement process are to be determined by the organization in the light of economic and other circumstances. An organization is required to
- establish an appropriate environmental policy,
- identify the environmental aspects arising from the organization’s past, existing or planned activities, products, and services, in order to determine the environmental impacts of significance,
- identify applicable legal requirements and other requirements to which the organization subscribes,
- identify priorities and set appropriate environmental objectives and targets,
- establish a structure and programmed to implement the policy and achieve objectives and meet targets,
- facilitate planning, control, monitoring, preventive and corrective actions, auditing and review activities to ensure both that the policy is complied with and that the environmental management system remains appropriate, and
- be capable of adapting to changing circumstances.
This sub-clause, like its predecessor, makes provision for the entire life cycle of an EMS, ranging from its establishment to its continual improvement. The third revision adds the processes and interactions between the elements of the EMS. The EMS shall be established and managed to ensure that the intended outcomes of the EMS are achieved and environmental performance is enhanced. The focus of the third revision of the EMS on the enhancement of environmental performance should be noted, as the first two revision of the standard required the improvement of the management system, which means that the enhancement of environmental performance is an outcome of the improvement of the management system. This sub-clause also suggests that the output of clause 4 is knowledge. This generated knowledge is to inform other processes of the EMS. The high-level analysis of the organizational context generates conceptual information or knowledge about the relationships between the organization, the environment, and the environmental management system. The standard does not require that this information or knowledge be documented (with the exception of the scope of the management system). The standard does, however, require that this knowledge be considered when other requirements of the ISO 14001: 2015 standard are addressed. The requirements demanding consideration of the outputs from clause 4.1 include:
- Clause 4.3, determining the scope of the EMS;
- Clause 5.2, environmental policy;
- Clause 6.1, actions to address risk and opportunities.
The issues need to be unpacked and documented as risks and opportunities that require management in terms of the following clauses:
- Clause 9.2.2 Internal audit program; and
- Clause 6.1.4, planning to take action;
- Clause 6.2.1, environmental objectives;
- Clause 9.3, management review.
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