ISO 14001:2015 Leadership establishes clear expectations for top management. Not only are executives accountable for the effectiveness of these respective systems, but they also have specific tasks ranging from establishing objectives to supporting relevant managers in their roles. It requires that managers integrate requirements into the organization’s business process. These managers will need to focus on the planning process to ensure that these systems meet the intended outcomes, as well as to establish performance objectives. For those implementing an environmental management system (EMS), ISO 14001 expects the organization not only to include the prevention of pollution but also the protection of the environment. This requires top management to learn and understand what the standard means when it says “protect the environment.” Topics such as sustainability, climate change mitigation, and protection of biodiversity and ecosystems are suggested by the standard in a note. The standard states that top management must take accountability for the “effectiveness of the EMS.” This one statement sets the tone for the whole of Section 5. No longer is there specific mention of a “management representative” in terms of taking responsibility, although specific responsibilities for other tasks may be delegated to the management representative elsewhere in the EMS. Given that top management will now be held responsible for the system’s effectiveness, it stands to reason that when this is broken down, then the following aspects must also be displayed by top managers under audit conditions:
- Ensuring that the strategic plans of the organization and the EMS objectives are compatible and integrated, and within the scope of the organizational context
- Ensuring the correct resources are available and that the EMS can interact with the existing business processes
- Adopting responsibility for delegating and directing people to ensure performance objectives are met
- Ensuring continual improvement can be achieved
- Providing leadership to other supporting roles in the organization to ensure overall targets can be met
- Communication: ensuring that critical objectives, aspects, and performance metrics and results are continually communicated effectively to all stakeholders
So, the leadership requirement is a huge departure from the 2004 standard, where responsibility could be devolved and delegated to a large degree to a “management representative” or other nominated people. This is clearly no longer the case, and that means big changes for many top managers, including a huge increase in EMS involvement and knowledge. Whilst there is scope for delegating authority, the new standard sets out clearly that top management is responsible for the effectiveness of the EMS and they must ensure that embedding environmental considerations are embedded into core business processes. The standard really does mean top management, and uses the definition of a “person or group of people who directs and controls an organization at the highest level.” “Top management” will have to be able to:
- Demonstrate knowledge of the EMS objectives and provide an overview of where these sit within the organization’s overall vision
- Demonstrate that consideration has been made over the coordination of the EMS and other strategic goals and internal processes jointly
- Demonstrate that leadership has been shown to the team in terms of communicating the importance of the EMS, ongoing results, and progress versus stated environmental objectives
- Be familiar with the process of ensuring and encouraging continual improvement and demonstrate that this culture exists within the organization as a result of that leadership.
This greater role and accountability for top management will likely be a new focus for external auditors, and you should expect audit itineraries to include a reasonable time with top management during the audit. The senior team will, therefore, need to have a clear understanding of the requirements of the new standard and be prepared to take a greater part in the audit process. So, it would appear that the days of the auditor being passed over to the management representative after the initial introductions, and remaining there until the audit ends, may be over. Clearly, the leaders of organizations are now expected to lead and lead by example. They are also expected to be able to understand and justify the objectives, results, resourcing, and methodologies of the EMS. Some additional responsibilities to the top Management means:
- An expanded and more detailed process to identify significant environmental issues
Organizations must fundamentally rethink their process to identify and prioritize significant environmental aspects. As well as your own impacts, you will need to develop a process that considers stakeholder needs and expectations and any environmental issues that are capable of affecting the organization. You will also need to analyze and prioritize these issues and with senior management, assess how these issues affect your organization’s business strategy.
- The EMS team will need to work more closely with the senior management team
In many organizations, top management only has limited involvement with the EMS. The new requirements mean that the environmental manager must have much greater contact and influence with the management team to meet the standard’s requirements. Setting up this closer working relationship may not be straightforward in all organizations.
- Senior management need to develop new knowledge and competencies
The new requirements for senior management mean that they will likely need to build their knowledge and competencies on environmental management. This may require training from the EMS team or external companies.
The “Leadership” clause has three sub-clauses ie
Clause 5.1 Leadership and Commitment
Clause 5.2 Environment Policy
Clause 5.3 Organizational roles, responsibilities and authorities.
Top management should demonstrate leadership and commitment to the environmental management system. This can be done by taking accountability for the effectiveness of the environmental management system. Top Management should ensure that the environmental policy and environmental objectives are established and are compatible with the strategic direction and the context of the organization. Top Management should ensure the integration of the environmental management system requirements into the organization’s business processes. Top Management must ensure that the resources needed for the environmental management system are available. They must communicate the importance of effective environmental management and of conforming to the environmental management system requirements. They must ensure that the environmental management system achieves its intended outcomes; They must direct and support persons to contribute to the effectiveness of the environmental management system. They must promote continual Improvement. They must support other relevant management roles to demonstrate their leadership as it applies to their areas of responsibility.
(Reference to “business” can be interpreted broadly to mean those activities that are core to the purposes of the organization’s existence.)
As per Annex A (Guidance on the use of ISO 14001:2015 standard) of ISO 14001:2015 standard it further explains:
To demonstrate leadership and commitment, there are specific responsibilities related to the environmental management system in which top management should be personally involved or which top management should direct. Top management may delegate responsibility for these actions to others, but it retains accountability for ensuring the actions are performed.
It is the responsibility of top management to provide leadership and direction for environmental management within the organization. They must establish strategic Environmental policies, directives, and objectives consistent with the purpose and capabilities of the organization. The Environmental policies and Environmental objectives are to be established for the Environmental management systems that are compatible with the strategic direction of the organization. The organization should have clarity in its mission and vision. and policies are to be developed in line with the mission. The objectives are to be in line with the vision of the company. The strategies are to be developed and modified from time to time depending on the situation by keeping the target of achieving the vision. The organization needs to specify the strategies for the year and give yearly targets. This work is to be done by the top management and not to be assigned to people down the line or to an outside consultant. They can take help, but not give up responsibility. They must establish the organizational structure and internal environment that motivates personnel to achieve the organization’s quality management goals and objectives. Ensuring the integration of the Environmental management system requirements into the organization’s business processes is the prime responsibility of the top management. If the top management is not committed and taking ad hoc decisions. shortcuts. and unethical means of achieving their interests. the system cannot be implemented effectively. The organization can somehow get certified by the auditors. but cannot achieve stakeholder satisfaction and shall fail in the long run.
Top management needs to demonstrate leadership and commitment with respect to the environmental management system to ensure:
- The environmental policy and environmental objectives are established and compatible with the strategic direction and context of the organization
- The integration of the environmental management system requirements into the organization’s business processes
- The resources needed for the environmental management system are available
Clause 5 is the overarching statement of what is required of top management to support the organization’s EMS. The organization’s management notes and performance records should indicate how effectively top management is leading the EMS by way of providing resources, strategic direction, communications, and results.
What’s changed from ISO 14001:2004? ISO 14001:2015 emphasizes management’s need to support the EMS and integrate it into the organization’s business planning and strategy. Later chapters offer examples where the organization’s management notes can provide evidence of the integration of the EMS with the business planning and strategy.
Demonstrating leadership and commitment with respect to the EMS is an example of an ISO requirement subject to interpretation. As a third-party lead auditor providing hundreds of ISO 14001 audits, I have experienced only one organization—a large manufacturing site—where I had to issue a nonconformance against the organization’s leadership. During the first two days of the audit, several issues were raised: environmental management meetings were not held per the organization’s procedure, waste materials were not being stored according to the procedure, and environmental objectives were not established for the current period. Clearly, top management was not supporting the EMS.
The list of top management leadership and commitment obligations set out in clause 5.1 includes five personal accountabilities and four responsibilities that can be delegated.
|Personal Accountabilities||Responsibilities that can be Delegated|
Top management should establish, implement and maintain an environmental policy that within the defined scope of its environmental management system is appropriate to the purpose and context of the organization, including nature, scale, and environmental impacts of its activities, products, and services; The Environmental Policy should provide a framework for setting environmental objectives. The Environmental Policy should include a commitment to the protection of the environment, including the prevention of pollution and other specific commitment relevant to the context of the organization. (Other specific commitments to protect the environment can include sustainable resource use, climate change mitigation and adaptation, and protection of biodiversity and ecosystems.) The Environmental Policy should include a commitment to fulfill its compliance obligations. The Top Management should include a commitment to continual improvement of the environmental management system to enhance environmental performance. The environmental policy must be communicated within the organization and be available to interested parties. This environmental policy should be maintained as documented information.
As per Annex A (Guidance on the use of ISO 14001:2015 standard) of ISO 14001:2015 standard it further explains:
“An environmental policy is a set of principles stated as commitments in which top management outlines the intentions of the organization to support and enhance its environmental performance. The environmental policy enables the organization to set its environmental objectives, take actions to achieve the intended outcomes of the environmental management system, and achieve continual improvement.
Three basic commitments for the environmental policy are specified in this International Standard to:
a) protect the environment;
b] fulfill the organization’s compliance obligations;
c] continually improve the environmental management system to enhance environmental performance.
These commitments are then reflected in the processes an organization establishes to address specific requirements in this International Standard, to ensure a robust, credible, and reliable environmental management system. The commitment to protect the environment is intended to not only prevent adverse environmental impacts through the prevention of pollution but to protect the natural environment from harm and degradation arising from the organization’s activities. products and services. The specific commitment(s) an organization pursues should be relevant to the context of the organization, including the local or regional environmental conditions. These commitments can address, for example. water quality, recycling, or air quality, and can also include commitments related to climate change mitigation and adaptation, protection of biodiversity and ecosystems, and restoration. While all the commitments are important, some interested parties are especially concerned with the organization’s commitment to fulfilling its compliance obligations, particularly applicable legal requirements. This International Standard specifies the number of interconnected requirements related to this commitment. These include the need to:
- determine compliance obligations;
- ensure operations are carried out in accordance with these compliance obligations;
- evaluate fulfilment of the compliance obligations;
- correct nonconformities.”
The ISO 14001 environmental policy outlines the overall intentions and direction of how the company will relate to its effect on the environment. This statement needs to come from top management since it is a primary directive for how every individual in the company will perform their job in relation to environmental impact. This is where you display what commitments your company will make to controlling and improving the environmental impact that you make. Top management needs to establish, implement, and maintain an environmental policy that is appropriate to the purpose and context of the organization and provides a framework for setting environmental objectives.
An environmental policy is your management’s declaration of commitment to the environment. The policy should serve as the foundation for your EMS and provide a unifying vision of environmental concern by the entire organization. Your policy should be more than just flowery prose. Since it serves as the framework for setting environmental objectives and targets, the policy should be brought to life in your plans and deeds. Everyone in the organization should understand the environmental policy and what is expected of them in order to achieve the organization’s objectives and targets. Your policy should contain three key commitments i.e Continual Improvement, Pollution prevention, and Compliance with relevant laws and regulations. Consider the results of your preliminary review before finalizing the policy. Also, make sure the policy reflects the environmental aspects of your products, services, and activities. Your policy should contain a commitment to continual improvement. This doesn’t mean that you must improve in all areas at once, but that the policy should drive your overall efforts to continually improve your organization’s environmental management. Keep your policy simple and understandable. Ask yourself: What are we trying to achieve? How can I best communicate this to the rest of the organization? Will we do what we said we would? Keep in mind that your policy should be explicit enough to be auditable. The policy can be a stand-alone document or it can be integrated with your health & safety, quality, or other organizational policies. Consider who should be involved in developing the policy and the best process for writing it. Input from a range of people in your organization should increase commitment and ownership. Make sure that your employees understand the policy. Options for communicating your policy internally include posting it around the site (e.g., in the lunchroom), paycheck stuffers, incorporating the policy into training classes and materials, and references to the policy at staff or all-hands meetings. Test awareness from time to time by asking employees what the policy means to them.
The environmental policy should be maintained as documented information, be communicated within the organization, and be available to interested parties.
The environmental policy should include:
- A commitment to the protection of the environment and prevention of pollution
- A commitment to fulﬁll its compliance obligations
- A commitment to continually improve its environmental management system
“Protecting the environment” can include sustainable resource use, climate change mitigation and adaptation, and protection of biodiversity and ecosystems. The environmental policy needs to be communicated within the organization and made available to interested parties. The organization needs to establish a documented environmental policy that is communicated internally and externally. The policy should demonstrate the organization’s commitment to the prevention of pollution, improvement of environmental performance, and conformance to regulatory compliance. The organization’s environmental policy should be part of the organization’s documented information endorsed by top management. Documented information should describe how the environmental policy is communicated within the organization and to persons doing work under the organization’s control and interested parties, such as the public. ISO 14001:2015 emphasizes the organization’s commitment to include the protection of the environment, along with the prevention of pollution. “Protecting the environment” can include sustainable resource use, climate change mitigation and adaptation, and protection of biodiversity and ecosystems (as appropriate). The environmental policy has some specific elements that are needed to meet the ISO 14001 requirements. Here are some explanations of what these are, and some ideas on how to address them.
- Appropriate to the organization – This isn’t really an element that needs to be written in the policy; rather it is something that needs to be remembered throughout the writing of the policy. The environmental policy needs to be appropriate to the environmental impacts of your activities. If you are a company that is heavily dependent on the use and disposal of chemicals, then having an environmental policy focused on the waste created by your cafeteria would be incorrect.
- Continual improvement – One of the main reasons for implementing any management system is to identify the processes in order to improve them. The environmental policy is expected to include a commitment to this concept of continual improvement in how your processes affect the environment. You don’t need to state how you will do this, just that you are committed to doing it.
- Prevention of pollution – Another commitment that needs to be included as a basic part of the policy is for your company to prevent pollution. Again, you don’t need to document how in the policy, but this should be something that you can easily direct someone to during an audit.
- Comply with legal and other requirements – The last commitment that is needed in the policy is to comply with all legal and other requirements related to your environmental aspects. The environmental aspects are the identified way that you interact with the environment and you need to agree that you will meet any laws or other stipulations that relate to these. Some examples could be clean air acts, wastewater emissions or noise pollution laws.
- Framework for objectives and targets – Here is where you get into the detailed information that is applicable to your company. You will need to set up plans to achieve some objectives and targets related to improving your impact on the environment, and these need to be consistent with your environmental policy. If you are setting a policy to monitor and reduce your environmental impact related to eliminating harmful chemicals used in the creation of your product, then your objective and targets will ultimately need to relate to this. Don’t put something into your policy that is unable to be acted upon with your improvement plans.
- Documented, implemented and maintained – The environmental policy is one of the items in the management system that needs to be a written document. This can be in hard or soft copy, but it can’t be word of mouth. It also needs to be implemented, meaning that there have been plans made and resources assigned to make the commitments in the policy happen. As time goes on, the policy will also need to be reviewed and updated as the nature of the company’s environmental impacts change, and this is the maintenance of the policy.
- Communicated to all employees – Employees need to understand what the company policy is and how their work actions affect the environmental impacts of the company. The policy doesn’t need to be memorized, but an employee should be able to understand what is meant and how they are involved in attaining the goal. In one training course I attended, the trainer told about auditing a company and asking an employee on the floor how his work impacted the environment if the company policy wasn’t met. The answer was “worse hunting and fishing.” For that employee, this was the reason to protect the environment. As a chemical company, this demonstrated that the employee knew how contradicting the policy could impact the environment.
- Available to the public – Unlike many management systems, the environmental policy is expected to be shared with anyone outside of the company who asks. This can be posted on the external website or made available by inquiry, but if someone wants to know what your policy is it should be readily available. This is how your investment in an environmental management system can become a publicity tool for your company.
Remember the environmental policy needs to be tailored to your company and how it interacts with the environment. Make the policy as simple as possible so that it is easily understood, but still meaningful to help your employees and others know what your company intends to do about improving its environmental impact.
Example of Environmental Policy
An example of environmental policy is shown in. Note that the text “We will strive to reduce the company’s carbon footprint” supports that the organization is promoting environmental protection specific to the context of its business and protection of the environment.
| Environmental Policy |
The company will conduct our operations in a way that is protective of the environment. We will maintain an environmental management system that will serve as a framework to achieve the following goals:Regulatory Compliance:
We will identify. evaluate. and comply with all applicable federal, state. and local environmental laws and environmental requirements of our customers as well as industry standards as applicable.Prevention of pollution
We will seek first, to oust-effectively avoid the creation of pollution and waste from our operations, and second. to manage remaining waste through the sale and responsible methods. We will strive to reduce the company’s carbon footprintConservation
We will strive to diminish our consumption of oi natural resources. using sustainable resources where possible. we roll strive to improve our environmental performance.XYZ
Sample environmental policy.
Top management should ensure that the responsibilities and authorities for relevant roles are assigned and communicated within the organization. Top management should assign the responsibility and authority for ensuring that the environmental management system conforms to the requirements of this International Standard. Top management should also assign the responsibility and authority for reporting on the performance of the environmental management system, including environmental performance, to top management.
As per Annex A (Guidance on the use of ISO 14001:2015 standard) of ISO 14001:2015 standard it further explains:
“Those involved in the organization’s environmental management system should have a clear understanding of their role, responsibilities, and authorities for conforming to the requirements of this International Standard and achieving the intended outcomes. The specific roles and responsibilities ‘identified in 5.3 may be assigned to an individual, sometimes referred to as the ‘management representative”. shared by several individuals, or assigned to a member of top management.”
Top management needs to ensure that the responsibilities and authorities for relevant roles are assigned and communicated within the organization. Top management needs to assign the responsibility and authority for ensuring that the environmental management system conforms to the requirements of this International Standard, including the reporting on the performance of the environmental management system. Top management should assign responsibilities and authorities to ensure the EMS is maintained. The organization’s documented information should define individual responsibility and authority for maintaining the EMS. Examples include responsibility for reporting the performance of the EMS, authority for communicating with regulatory bodies and the public, releasing hazardous waste manifests, and approving reports to regulatory bodies. The successful implementation of an environmental management system calls for commitment from all employees in the organization. The purpose of this sub-clause is to ensure that that personnel are assigned responsibilities for part of the environmental management system and have a clear-cut reporting structure. Job descriptions, or project responsibilities from the management program, may cover this requirement. For your EMS to be effective, roles and responsibilities must be clearly defined and communicated. In a small organization, the commitment of all employees is needed.
What’s changed from ISO 14001:2004? ISO 14001:2015 does not use the title “Management Representative” as previous ISO 14001 standards did. The organization can continue to use “Management Representative” as the title has certain responsibilities, but the intent of ISO 14001:2015 is to emphasize top management’s responsibilities as more than delegating. Some of these responsibilities are:
- ensures that the EMS is established and implemented
- reports on its performance over time; and
- works with others to modify the EMS when necessary.
This responsibility can either taken by the same person who serves as the project champion, but this is not mandatory. There needs to be a direct authority linkage. For example, in the case of a potential environmental problem, the line of communication to senior management needs to be short so that action can occur readily. Commitment begins, of course, at the top level of management, but it is accepted that in larger organizations responsibility is often delegated to a less senior individual. Management can use the information on EMS performance to improve the system over time. To determine the organization structure following steps may be taken:
- Look at the scope of your environmental management program: What capabilities do we need? Who needs to be involved to make the system effective? What training or other resources will they need?
- Look at your significant environmental impacts: What operations/activities need to be controlled? Who needs to be involved to ensure that controls are implemented?
- Look at the results of previous audits or other assessments: What does this information tell us about the effectiveness of our organizational structure? How could it be improved?
- Look at the current responsibilities for environmental management: How can we enhance ownership of environmental management across the organization? How can other business functions support the EMS?
- Look at your quality management and/or other existing management systems: What roles and responsibilities exist in these management systems? Where are the opportunities for integration?
POSSIBLE ROLE IN EMS
|Develop and implement controls for chemical / other material purchases|
|Implement a preventive maintenance program for key equipment|
Consider flowcharting your organization’s activities relating to environmental management. This can help you understand how processes work and the final product can be a great communication and training tool. Flow charts might be useful to look at processes such as chemical purchasing and distribution, employee training, and preventive maintenance, among others. Build flexibility into your organization’s EMS. Recognize that environmental management needs will change over time. Be sure to communicate to people what their roles are in the organization.