ISO 14001:2015 Clause 7.4 Communication

ISO 14001:2015 Clause7.4 Communication refers to all types of communications, both internal and external to, the organization. It requires organizations to establish and maintain a process for internal communications between the various levels and functions of the organization. It also requires organizations to document and respond to relevant communications from external interested parties.

Examples of internal communications include:

• Communicating environmental objectives and targets to employees.
• Raising awareness of environmental issues to employees.
• Communicating the environmental policy to employees.
• Advising of nonconformance to relevant departmental heads.
• Reporting incidents arising from abnormal or emergency operations to senior management.

Examples of external communications include:

• Dealing with environmental complaints or proactively inviting such stakeholders, or ‘green’ pressure groups to the site.
• Responding to media inquiries, especially in the event of an incident.

An inability to communicate effectively within the first few hours of an incident could seriously reduce the company’s ability to control the situation. This will undermine the company’s reputation in the minds of staff, customers, the media, and the public. Effective environmental management requires effective communications.  Communications will help you:

• motivate the workforce;
• explain the environmental policy both internally and externally and how it relates to the overall business vision/strategy;
• ensure understanding of roles and expectations;
• demonstrate management commitment;
• monitor performance; and,
• identify potential system improvements.

Effective internal communications require mechanisms for information to flow top-down and bottom-up. Since employees are on the “front lines,” they are often an excellent source of information, issues, and ideas. Communicating with external parties is also important for effective environmental management. Obtaining the views of neighbors, community groups, and customers, among others, will help you understand how your organization is perceived by others. Information from external sources can be critical in setting environmental and other business goals. An effective EMS should include procedures for:

• communicating internally between levels and functions, and
• soliciting, receiving, documenting and responding to external communications.

Determine how proactive your external communications strategy will be. Select an approach that fits your organization’s culture and strategy. For example, will a report on environmental performance and progress give you an edge over the competition? While a proactive external communications program may require more resources, some organizations have found that a proactive strategy can be quite beneficial. Weigh the costs and benefits for yourself, but keep in mind that there might be many interesting audiences. In communicating with employees, it is helpful to explain not only what they need to do but why they need to do it. For example, when describing a requirement based on a regulation, simply saying “the regulations require it” is not a sufficient explanation. Try to explain the purpose behind the rule and why it is important. Also, make a clear connection between the requirement and how it applies to each person’s job. Keep the message simple. All communications should be clear, concise, and accurate. Managing responses to external inquiries do not have to be a burdensome task. Use a simple method, such as stapling an inquiry to its written response and then filing them together. The key is to be able to demonstrate that the organization has a system for responding to external inquiries. Clause 7.4 Communication has three subclauses

• 7.4.1 General
• 7.4.2 Internal communication
• 7.4.3 External communication

7.4.1 General

The organization must establish, implement and maintain the processes needed for internal and external communications relevant to the environmental management system. The organization must determine what it will communicate, when to communicate, with whom to communicate, and how to communicate. While establishing its communication processes, the organization must take into account its compliance obligations and ensure that environmental information communicated is consistent with information generated within the environmental management system, and is reliable. The organization must respond to relevant communications on its environmental management system. As appropriate, the organization must retain documented information as evidence of its communications.

7.4.2 Internal communication

The organization must internally communicate information relevant to the environmental management system among the various levels and functions of the organization, including changes to the environmental management system, as appropriate. It must ensure its communication processes enables persons doing work under the organization’s control to contribute to continual improvement.

7.4.3 External communication

The organization must externally communicate information relevant to the environmental management system, as established by the organization’s communication processes and as required by compliance obligations.

As per Annex A (Guidance on the use of ISO 14001:2015 standard) of ISO 14001:2015 standard it further explains:

Communication allows the organization to provide and obtain information relevant to its environmental management system, including information related to its significant environmental aspects, environmental performance, compliance obligations, and recommendations for continual improvement. Communication is a two-way process, in and out of the organization. When establishing its communication processes. the internal organizational structure should be considered to ensure communication with the most appropriate levels and functions. A single approach can be adequate to meet the needs of many different interested parties. or multiple approaches might be necessary to address the specific needs of individual interested parties. The information received by the organization can contain requests from Interested parties for specific information related to the management of its environmental aspects or can contain general impressions or views on the way the organization carries out that management. These impressions or views can be positive or negative. in the latter case (e.g. complaints), it is important that a prompt and clear answer is provided by the organization. A subsequent analysis of these complaints can provide valuable information for detecting improvement opportunities for the environmental management system. Communication should:

1. be transparent, i.e. the organization is open in the way it derives what it has reported on;
2. be appropriate, so that information meets the needs of relevant interested parties, enabling them to participate;
3. be truthful and not misleading to those who rely on the information reported;
4. be factual, accurate and able to be trusted;
5. not exclude relevant information;
6. be understandable to interested parties

Explanation:

The clause requires the organization to have in place a system of communication that ensures that those within the organization are kept informed regarding the EMS and environmental issues associated with the organization’s operations and that communication from external interested parties is received and handled according to the established process. The function of Clause 7.4 Communication is to support the achievement of the environmental policy and objectives and the functioning of the EMS in general. The clause requirement that information regarding the environmental aspects and EMS elements be communicated to personnel within the organization is intended to assist the organization in achieving its environmental objectives as well as the commitments and overall goals expressed in the environmental policy. Employees who are fully informed of all the issues surrounding the EMS and who feel included in the process are more likely to be motivated and committed to achieving the organization’s objectives and targets and overall environmental goals. Likewise, the limited requirements for communication with external parties are designed to foster a more understanding and cooperative relationship between the organization and stockholders, community groups. regulatory agencies. and environmental groups. Communication of the environmental policy will also form an important part of internal communication, as a key part of the communication program will involve making sure employees understand the environmental policy. In order to develop effective processes for internal and external communication. it is useful to have an understanding of what is encompassed by the terms “Internal communication” and “external communication” and what the ultimate goal is of such processes.

1. Internal Communication

The organization needs to establish a communication process “internally communicate information relevant to the environmental management system among the various levels and functions of the organization” but does not state what specifically about the EMS must be communicated. The intent behind the clause requirement for an internal communication procedure is that through the communication of the environmental policies; environmental aspects; objectives; environmental management programs; procedures; roles and responsibilities. and authorities: and other components of the EMS. an organization’s employees will be able to successfully complete their assigned tasks and contribute to the process of developing and implementing these components. The goals of internal communication are to:

• make employees aware of the environmental policy and any  other environmentally related procedures necessary to conduct  their work;
• inform employees about the overall performance of the EMS;
• provide employees with an opportunity and mechanism to  voice their concerns about environmental issues; and
• a report back to employees on the results of EMS monitoring and audit and management reviews.

The key to achieving the goals of internal communication in an EMS is to develop a two-way communication pathway—“top-down”  communication from top management, and “bottom-up”  communication from line workers who are most familiar with environmental issues at the organization. Top management must act to support environmental policies and procedures and the overall EMS. if employees are to believe in them. As in any new corporate program,  the substance must be in turn generated from below, at the front lines of the company’s business. In order for this “bottom-up”  communication to take place. employees must be capable of, and supported in, sharing their front-line expertise and experience regarding environmental issues and potential improvement.

Establish Internal Communication Programs

The internal communication requirement of this clause requires that  you establish a process at your facility “for internal communication  between the various levels and functions of the organization.” This is a very general statement and the clause provides virtually no other guidance as to what this means. There are advantages and disadvantages to this: on the one hand. you are free to develop communication pathways in any way you see fit, but, on the other hand, it is difficult to know where to begin when the clause provides no suggestions as to how to develop the process.  We do not recommend a formal documented procedure that addresses internal communication. More important than a documented procedure is demonstrating that the internal communication process at your facility is active. This requires that programs. regular meetings, committees. and other processes be in place and operational at your facility. There are a variety of approaches to developing good, value-added communication programs for environmental issues. The most common practices involved in internal communication include the following:

• New employee briefing programs: New employees entering the system are introduced to the environmental policy and various components of the EMS as part of the new employee training program. Note that such an employee briefing program can be used to provide the EMS training.
• Policies posted on bulletin boards throughout the facility:. The environmental policy is required to be communicated to all employees and high visibility of the policy strengthens internal communication. Posting the policy is one method of increasing visibility. Posting does not, however, substitute for effective. continuing communication of the policy’s meaning and importance.
• Regular departmental and team meetings: Meetings are an excellent forum for sharing information on EMS performance and introducing and discussing new ideas. Periodic meetings can be valuable communication pathways between employees and management, allowing environmental concerns or known EMS  nonconformance (regulatory or nonregulatory) to “bubble up to the surface” and be addressed by management. Meetings are an important process for identifying improvement opportunities and catching potential EMS problems before they become larger problems and are identified as nonconformance during EMS audits or management reviews. Such meetings can also provide a forum for management to communicate the results of compliance and EMS audits and areas of needed improvement.
• Interdepartmental environmental committees: Many companies have had success with committees established specifically to address environmental issues and take the lead for the dissemination of EMS  performance information. An environmental committee of this sort should include members from many different departments (including  Safety, manufacturing. engineering. purchasing. shipping, and receiving) and have the mission of keeping the company focused on its environmental goals and delivering on its commitments. Such committees are also the ideal forum for the development of environmental management programs to ensure achievement of environmental objectives.
• Company publications: Using company publications to present environmental and EMS issues is another popular method of internal communication. Feature articles can highlight the successful environmental projects being accomplished throughout the company and the employees who made them possible. Upcoming initiatives and opportunities to get involved in environmental committees can also be publicized in this manner.
• Environmental conferences: In larger organizations with multiple facilities, environmental conferences have proved successful as a  means of gathering together in one place employees with primary responsibilities for environmental issues at the different facilities.  Conferences are often used as a means to transfer knowledge between various facilities and to deal with common problems and concerns.  Conferences also provide a forum for speakers from regulatory authorities, national environmental groups, community advisory panels, as well as your own executives and in-house experts. If you do organize a conference, it is important to include small group discussions. This allows participants time to discuss common issues and learn from each other.
• Reward and award programs: Reward and award programs provide incentives for innovative ideas from all employees. For example, one company offers a quarterly award for the most creative and value-added suggestion to address an environmental issue. The winners receive a small financial reward or gift and more importantly, they get internal recognition for their idea because it is published in the quarterly newsletter. This process has given rise to several projects that resulted in significant cost savings and improvement in the company’s environmental performance.
• Computer systems: Internet and intranet applications including company Web sites, e-mail. electronic bulletin boards. and discussion databases are powerful tools that can be used to communicate with employees and link geographically disparate locations. If your company already has such a computer networking infrastructure, such tools can be a very cost-effective way to maintain environmental communication pathways as they provide electronic availability of documents and interactive question and answer capabilities.

When developing your internal communication programs, you should  bear in mind the following:

• Top management support is critical. Management must be prepared to not only communicate the importance of environmental policies and meeting objectives and targets. but also provide the appropriate resources to sustain internal communication efforts.
• The most effective communication is face-to-face. Face-to-face communication can involve informal “get-togethers”, formal periodic meetings. and internal conferences. Be sure to include regular meetings or conferences in your communications program.
• Changes in internal communication within an organization can take several years to truly become effective. Therefore, do not be discouraged if the communication pathways you establish do not immediately bear fruit. Be prepared to discard the methods that don’t work at your facility and expand those that do.

2 External Communication

The organizations need to have a process to “externally communicate information relevant to EMS” Neither “relevant communication“ nor “external communication” are defined in ISO 14001. External communication, from an ISO 14001 perspective, broadly refers to any communication between an organization and external interested parties regarding environmental issues at the organization. Interested parties could include regulators, customers, suppliers, vendors, public interest groups, and neighbors. “Relevant communication“ is interpreted by practitioners and certification bodies as communication that relates directly to environmental aspects (i.e. potential environmental impacts or hazardous situations) or compliance obligations including Regulatory Compliance. Individual organizations must decide what such relevant communication is “Communication” from external interested parties will typically be in the form of inquiries. The inquiries could be from regulators in the form of a letter or a site visit, from members of the general public through a telephone call or letter, or from a stockholder group. For example. an oil refinery may get inquiries from the public regarding odors that occur at certain times of the day. It is intended to ensure that inquiries from external interested parties are addressed in a systematic manner. An effective. systematic external communication procedure will ensure that:

1. the only correct information is sent out to external parties
2. the information has been appropriately reviewed;
3. the information is delivered by appropriately trained and qualified staff.

When external communication is conducted in this manner. it often leads to increased goodwill from external parties towards the organization. It is interesting to note that the language of the clause does not require an actual response to inquiries received. The clause merely requires that the organization have a procedure that describes how it will respond and record that the inquiry occurred. The intent of this clause is that the organization would respond to external inquiries. The aim is to increase the level of communication between an organization and people outside the organization who may have questions or concerns about environmental impacts and other issues. Typically, external communication beyond regulatory-related communication, if it is conducted at all, is most often handled by a communications or public relations department. To successfully implement, a closer working relationship between the EH&S manager and the communications or public relations department will be required to ensure that a response is given that is technically correct and properly communicated.

Establish External Communication Programs

The intent of this Clause has two specific requirements for external communication. You are required to:

• establish a procedure that covers how your facility will receive. the document, and respond to a communication from external interested parties; and
• decide whether, and how, to communicate your facility’s significant environmental aspects to interested parties.

In support of the external communication requirements for this clause, we do recommend that you develop a documented procedure. Such a  documented procedure should be managed as part of your documented Information control system. A documented procedure is a good way of providing evidence that you have covered the specific requirements of the clause. A documented procedure is also a good idea when presenting potentially sensitive information outside the company. This written procedure should be reviewed appropriately by your Top Management or legal counsel. as appropriate for your facility.

(a). Communication from External Interested Parties

In order to meet the clause requirements of receiving. documenting  and responding to external communication, your procedure should  describe:

• the roles, responsibilities. and authorities with respect to external communication‘ (i.e., who the inquiry should be directed to, who will respond to the inquiry, and who documents the inquiry and response); and
• the types of records that should be maintained.

To “document” external communication, as required by the clause, you must develop a method of tracking external communications efforts. This typically involves keeping records of the communication received by your facility and records of responses. External communication tends to arrive from two sources: regulatory and non-regulatory. Roles,  responsibilities, and authorities must be established for receiving documents. and responding to both types of external communication.

(i) Regulatory Communication
Most regulatory communication will arrive in written form, typically a letter or some other paperwork. Somebody at your facility must be assigned to review the information, take appropriate action, and file the communication and any responses, written or verbal, made by your facility.  For in-person visits from regulatory authorities, such as site inspections or audits, the EH&S/Administration manager will usually take the lead. For this type of assignment process to work, the EH&S/Administration manager must supervise on-site inspections by regulatory agencies. It is also important to have a back-up person assigned to this role in case of unavailability of EH&S/Administration manager at the time of inspection. The types of records resulting from regulatory communication will consist of any paperwork received or, in the case of an on-site inspection, any notes you made during the inspection or records of follow-up tasks. Such records should be retained and managed in  accordance with the documented information management system

(ii) Non-regulatory Communication
The process for dealing with non-regulatory external communication like inquiries from stockholders, neighbors, environmental groups, or other members of the general public. This tends to be more complicated than that for regulatory communication, for two reasons. First, external communication from non-regulatory entities is generally less common than regulatory communication. Second, because these inquiries are less common, facility systems are generally ill-equipped to deal with them. In general, the EH&S/Administration manager or an on-site community relations or public relations person will be assigned to handle inquiries from these parties. Keep in mind that inquiries of this sort, especially from the public, are often not directed to the facility EH&S manager. Members of the public, not knowing whom to contact specifically, may call a  general telephone number for a facility or address a letter to the general manager of the facility. Such written or telephone inquiries are then typically intercepted by a receptionist or mailroom supervisor, or even a guard at the facility gate, who may not even know who the EH&S manager is! To avoid this problem at your facility. you should make sure that employees who may receive such telephone calls and letters know to whom they should direct the call or letter. One approach is to distribute a memo describing the procedure for routing such inquiries to EH&S or Administration department(in case there is no separate EH&S department). Irrespective of who is assigned to handle nonregulatory inquiries, there are several general guidelines that should be adhered to when providing responses to this type of inquiry. These  include the following:

• responses should be understandable and adequately explained—avoid technical jargon;
• any information provided should be verifiable; consistent in format (using similar units of measure facilitates comparisons between different time periods) and consistent in content (this can be achieved by making sure that all responses are coordinated between knowledgeable and authorized personnel).
• facility environmental performance should always be accurately presented.

An additional element of your response to such inquiries could involve directing the external parties to other resources that can provide additional information. an industry or trade association, for example, at larger organizations, where inquiries from external interested parties are common, it is useful to prepare information sheets (which have been appropriately reviewed by both technical and public relations personnel and where appropriate, legal personnel) that address the most common questions posed. These sheets should contain information about the processes or activities at a facility and the measures that the organization is taking to minimize the environmental impacts.  The types of records that should be maintained will include any letters and paperwork received from the external parties along with the response or follow-up from your facility. For telephone inquiries, it is a good idea to create a telephone conversation record form that includes details about the communication. including who made the inquiry (name and organizational affiliation, if any), the subject of the communication, and what action was taken. If no action was necessary or warranted, this can be noted on the record. Just as for regulatory inquiries. records of external nonregulatory communication should be retained and managed in accordance with the documented information management system.
The process of tracking nonregulatory inquiries from external parties through the receiving, responding. and record-keeping phases described above is not simply a bureaucratic task designed to increase the amount of paperwork at your facility. Such inquiries should be taken seriously and viewed as learning opportunities. It is not uncommon for a facility to decide to elevate an environmental aspect to a significant environmental aspect on the basis of these communications. For example. a certain mining operation receives several letters and telephone calls a month inquiring about the large amounts of steam produced by the operation. The letters typically express concern about the release of toxic gas or fume emissions visible from the roadway.  Because this facility receives so many inquiries about its steam emissions. management may want to seize this obviously negative public relations issue and address it by elevating the steam emissions to a significant environmental aspect, even though the steam is just water vapor and is not hazardous. Having reclassified it as a significant environmental aspect, they can then take steps to reduce the steam emission (or reclaim it in some way). not because the steam causes an actual environmental impact, but because the public perceives it as an issue. Thus, your external communication process can be a valuable way to involve interested parties, increase your facility’s goodwill. and perhaps serve as the catalyst for innovative ideas.

b. Communication of Significant Environmental Aspects

Organizations can consider ways in which they could communicate their significant environmental aspects. but the clause does not require that such communication be implemented.  Your organization is free to make its own decision on whether or not to communicate information about its significant environmental aspects and impacts. It is worth noting that the only specific requirement to communicate information to external interested parties under 1SO 14001 is contained in the environmental policy clause and not the communication clause. ln the policy clause, the organization is required to ensure that the environmental policy is “available to the interested parties”, which can be interpreted as made available upon request. Therefore. there is not even a requirement to be proactive about distributing the environmental policy. The decision on whether or not to make your facility’s significant environmental aspects available to the public has to be made by top management. External communication of environmental issues has always been a “hot button“ issue for corporations. This is a real dilemma—is it better to reveal your environmental aspects or is it better to manage these potentially sensitive issues behind closed doors under legal privilege? On the one hand, open communication can lead to public trust and increased customer goodwill. On the other hand, by voluntarily disclosing potentially sensitive issues, you may be needlessly attracting the attention of regulatory authorities and open yourself up to additional liabilities. When considering proactive external communication. you should weigh the costs and benefits. At present, there are few legal incentives to disclose environmental information in most countries.  If top management at your facility does decide to communicate the facility’s significant environmental aspects to external parties there are a variety of methods available for achieving this. These include:

• placing the information in the company annual report;
• preparing a separate environmental annual report;
• publishing the aspects in industry association publications;
• distributing the information during an open house at the facility; and
• publishing the aspects on the company’s Internet Web site.

If you make this information available to the public. it is also wise to not only provide a list of significant environmental aspects but also provide some additional information or context to adequately explain the information and make it understandable. Such additional  information may include:

• environmental objectives that have been developed to reduce the environmental impacts of the aspects
• environmental management programs that have been designed  to address the aspects; and
• opportunities for mitigation of the significant environmental aspects.

The key to creating a successful communication program is to involve as many employees as possible in the EMS process. This will require initial and continued outreach by you, top management, but will often result in considerable rewards through innovative and cost-saving measures forwarded by employees. Reward, award, and recognition programs, as described above, can play an important role in developing an enthusiasm for this program.