ISO 14001:2015 clause 8 Operation

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ISO 14001:2015 clause 8 Operation.

ISO 14001:2015 clause 8 Operation deals with the execution of the plans and processes that enable the organization to meet its environmental objectives. There are specific requirements that relate to the control or influence exercised over outsourced processes and the requirement to consider certain operational aspects consistent with a life-cycle perspective. This means giving serious consideration to how actual or potential environmental impacts happening upstream and downstream of an organization’s site-based operations are influenced or (where possible) controlled. Finally, the clause also covers the procurement of products and services, as well as controls to ensure that environmental requirements relating to design, delivery, use, and end-of-life treatment of an organization’s products and services are considered at an appropriate stage. The “Operation” clause has two sub-clauses i.e

• Clause 8.1 Operational planning and control
• Clause 8.2 Emergency preparedness and response

8.1 Operational planning and control

The organization must establish, implement, control, and maintain the processes needed to meet environmental management system requirements. and to implement the actions to address risk and opportunity as identified in 6.1 and implement actions to meet Environmental objectives as identified in 6.2. This can be done by establishing operating criteria for the processes and implementing control of the processes, in accordance with the operating criteria.
Controls can include engineering controls and procedures. Controls can be implemented following a hierarchy (e.g. elimination, substitution, administrative) and can be used individually or in combination.
The organization must control planned changes. In case the changes are unintended, the organization must review the consequences of unintended changes and must take action to mitigate any adverse effects, as necessary. The organization must also ensure that outsourced processes are controlled or influenced. The type and extent of control or influence to be applied to the processes must be defined within the environmental management system.
Operation planning and control should be inconsistent with a life-cycle perspective. Inconsistent with a life-cycle perspective the organization must establish controls, as appropriate, to ensure that its environmental requirements are addressed in the design and development process for the product or service, considering each life cycle stage. The organization must also determine its environmental requirements for the procurement of products and services as appropriate. It must communicate its relevant environmental requirements to external providers, including contractors. It must consider the need to provide information about potential significant environmental impacts associated with the transportation or delivery, use, end-of-life treatment, and final disposal of its products and services.
The organization must maintain documented information to the extent necessary so as to have confidence that the processes have been carried out as planned.

As per Annex A (Guidance on the use of ISO 14001:2015 standard) of ISO 14001:2015 standard it further explains:
The type and extent of operational controls depend on the nature of the operations, the risk and opportunities, significant environmental aspects, and compliance obligations. An organization has the flexibility to select the type of operational control methods, individually or in the combination that is necessary to make sure the processes are effective and achieves the desired results. Such  methods can include:
a) designing processes in such a way as to prevent error and ensure consistent results;
b) using technology to control  processes and prevent adverse results (i.e. engineering controls);
c) using competent personnel to ensure the desired results;
d) performing  processes in a specified way;
e) monitoring or measuring  processes to check the results;
f) determining the use and amount of documented information necessary.
The organization decides the extent of control needed within its own business processes (e.g. procurement process) to control or influence outsourced processes or providers of products and services. its decision should be based upon factors such as:

• knowledge, competence, and resources, including the competence of the external provider to meet the organization’s environmental management system requirements and the technical competence of the organization to define appropriate controls or assess the adequacy of controls.
• the importance and potential effect the product and service will have on the organization’s ability  to achieve the intended outcome of its environmental management system
• the extent to which control of the process is shared;
• the capability of achieving the necessary control through the application of its general  procurement process;
• improvement opportunities available.

When a process is outsourced, or when products and services are supplied by external providers the organization’s ability to exert control or influence can vary from direct control to limited or no influence. In some cases, an outsourced process performed onsite might be under the direct control of an organization. in other cases, an organization’s ability to influence an outsourced process or external supplier might be limited. When determining the type and extent of operational controls related to external providers, including  contractors, the organization may consider one or more factors such as:

• environmental aspects and associated environmental impacts;
• risks and opportunities associated with the manufacturing of its products or the provision of its  services;
• the organization’s compliance obligations.

An outsourced process is one that fulfills all of the following:

• it is within the scope of the environmental management system;
• it is integral to the organization’s functioning;
• it is needed for the environmental management system to achieve its intended outcome;
• liability for conforming to requirements is retained by the organization;
• the organization and the external provider have a relationship where the process is perceived by interested parties as being carried out by the organization.

Environmental requirements are the organization’s environmentally-related needs and expectations that it establishes for, and communicates to, its interested parties (e.g. an internal function, such as procurement; a customer; an external provider).  Some of the organization’s significant environmental impacts can occur during the transportation,  delivery, use, end-of-life treatment, or final disposal of its Product or service. By providing information,  an organization can potentially prevent or mitigate adverse environmental impacts during these life cycle stages.

Explanation:

To ensure that your environmental policy is followed and that your objectives are achieved, certain operations and activities must be controlled. The methods defined to ensure operational control will be dependent on the organization’s activities, legal obligations, and significant operational controls. Therefore, an organization must decide how to construct and combine processes to ensure that total operational control of its environmental aspects is achieved. These methods of defining and implementing controls must include constructing processes to ensure consistent results. It must consider the life cycle of a product when establishing controls and using technology to ensure results. It must ensure personnel is competent. It must monitoring and measuring results. It must decide on the amount of documented information required to support the above. Where an operation or activity is complex and/ or the potential environmental impacts are significant, these controls should take the form of documented procedures. Determining which operations should be covered by documented procedures and how those operations should be controlled is a critical aspect of developing an effective EMS. Therefore, it is clear to see that while organizations are given the scope to decide on the best practice for ensuring operational control, there are other vital elements. It is also vital that you consider what parts of your operational control process you need to record as documented information. Training methods and records are mandatory, and it may well be that processes of any complexity may need to be documented to ensure you can maintain necessary operational control to provide a consistent product or service.

In deciding which activities need to be controlled, look beyond routine production on the shop floor. Activities such as maintenance, management of on-site contractors, and relationships with suppliers or vendors could affect your organization’s environmental performance significantly. The standard requires the identification of operations and activities that are associated with the action to address risk and opportunities and identified significant environmental aspects of the organization in line with the environmental policy and its objectives. In effect, the organization is required to control and verify all functions, activities, and processes that have or could have, if uncontrolled, a significant impact direct or indirect on the environment. Control can include engineering controls and procedures. the following hierarchy can be established for executing control

• Elimination
• Substitution
• Administrative

As part of managing change, the organization should address planned and unplanned changes to ensure that the unintended consequences of these changes do not have a negative effect on the intended outcomes of the environmental management system. Examples of change include:

• planned changes to products, processes, operations, equipment or facilities;
• changes in staff or external providers, including contractors;
• new information related to environmental aspects, environmental impacts, and related technologies;
• changes in compliance obligations.

For life cycle perspective click here

ISO 14001:2015 has introduced the requirement for a “life cycle perspective” in environmental management systems (EMS). The new standard does not require a formal life cycle analysis, or quantification, but does require organizations to look upstream and downstream of the processes performed on-site and try to reduce environmental impacts. Specifically, the life cycle perspective is related to the organization’s environmental aspects and impacts. It requires careful consideration of the life cycle stages that the organization can control or influence, including the acquisition of raw materials, production and transportation, use and maintenance, and recycling or disposal. In doing this, the organization needs to create records as evidence that they have considered each lifecycle stage. The standard also requires the organization to provide information to its external service providers and contractors about the potentially significant environmental impacts of its products and services. It must also consider the need to provide this information to transporters, end-users, and disposal facilities.  By providing this information, the organization can potentially prevent or mitigate adverse environmental impacts during these life cycle stages.

The life cycle perspective can be applied in choosing, for example:

• raw materials (environmental impacts of their production, distance transported and mode of transport)
• products to manufacture and offer for sale (same considerations as well as disposal or recycling options at end-of-life)
• services used by the organization (environmental credentials, chemicals used, waste generated)
• equipment purchases (distance transported, options for recycling at end-of-life, waste generated in their use).

Why has this life cycle requirement been added to the standard? The introduction to the new standard explains that a life cycle perspective can be used to benefit the environment in areas where the organization has “control or influence” and also “prevents environmental impacts from being unintentionally shifted elsewhere within the life cycle”. Life cycle considerations were largely ignored by the old standard. Now they’re central. ISO 14001 now expects you to use a life cycle perspective to “identify the environmental aspects and associated environmental impacts of its activities, products, and services that it can control and those that it can influence”.

Environmental impacts of the organization’s suppliers come under the controls exercised under ISO 14001-Clause 8.1, as do those of contractors coming on-site or contractors used by the implementing organization. This is especially so if the supplier’s or contractor’s methods of working are known to conflict with the organization’s environmental policy. Contractors may not be aware of the environmental consequences of certain actions, for example, dumping their waste into skips without segregation, or operating noisy drills in the evening when the organization may, in fact, have come to some arrangement with their neighbors not to do so. Many organizations have induction sessions for contractors as a matter of course for example, on health and safety issues so environmental awareness could be included in this existing mechanism. However, the principle of significance should be considered when deciding what controls to put in place. For example, the contractor who comes on-site to clean office windows should receive less attention than the contractor who is laying new cables or drainage pipes on-site.

 So, what do we need to examine, define, and take action on to control in terms of outsourced processes? Well, given that the organization remains responsible for all activities and impacts of the outsourced provider, the 14001:2015 standard informs us that we must assess, define, and maintain control over the following elements – as well as recording them in “documented information”:

• resources knowledge, and, training/competence
• the ability of the provider to meet the stated EMS objectives
• the technical competence of the organization to define and assess the controls
• the potential effect of the product or service on environmental aspects
• how the control is shared between the parties
• how control is achieved via a procurement process
• opportunities for improvement

If an outsourced service provider is geographically close to the organization, then it stands to reason that the organization’s control over environmental impacts may be great. Conversely, if a service provider is in a remote location, then direct control over the resulting impacts may often be lessened. This is recognized by the standard; however, the following elements must be defined and actions put in place to control:

• environmental aspects and impacts
• risks and opportunities related to the organization’s goods or services
• compliance and legal obligations

Lastly, the standard reminds us that “interested parties” must be considered, as well as the environmental impact found during delivery, disposal, and end-of-life of product as well as general use. The standard allows an organization to define an action its own operation controls according to the industry it operates in and the aspects that arise from the resulting product or service. Despite that, there are certain elements of operational control that the ISO 14001:2015 standard insists be assessed, controlled, and captured as documented information, whether in the environmental policy itself or as separate documents:

• Legal and compliance requirements must be met.
• Environmental objectives must be assessed and set.
• Internal processes must be defined.
• External and outsourced processes must be defined and controlled.
• Training and competence needs must be assessed, implemented, and reviewed.
• Analysis and improvement measures must be undertaken.

Start by looking at the environmental aspects and potentially significant impacts which you identified earlier. Identify the processes from which these significant impacts arise, and consider what types of controls might be needed to prevent or manage these impacts. If you have flowcharts of these processes, identify the points in each process where some type of control may be appropriate. Review them with the people who will need to implement them. This will help to ensure that the Controls are accurate and realistic. Look at Controls you already have in place to comply with environmental and health & safety regulations. Some of these may be adequate to control significant impacts or could be modified to do so. Develop a chart to keep track of what is needed. The more highly skilled and trained your employees are, the less critical controls will be. The more complex the work or the greater the potential impact on the environment, the more important these controls will be. Once you have identified operations that require control, consider what kinds of maintenance and calibration may be appropriate. However, the need for maintenance on equipment that could have significant environmental impacts should be obvious, and the need to plan and control such maintenance should not be overlooked. This does not mean that an elaborate preventive or predictive maintenance program is needed in all cases. Assess your existing maintenance program and its effectiveness before making significant changes. Some of your identified environmental aspects may be related to the chemicals, raw materials, or other goods and services you obtain from vendors/suppliers. Likewise, the activities of your contractors can affect your environmental performance. Communicate your expectations including any relevant controls to these business partners.

Example of Operation control Measures

Processes	Significant Environmental Aspects (Considering a Life cycle Perspectives)	Example of controls  (Considering a Life cycle Perspectives)
Timber milling and sawing line Input – raw timber and energy Output – finished timber, cut to specification	Timber sourcing General energy use (petrol & electricity) Temperature-controlled storage (electricity) Machine coolant use and disposal Chemical use and disposal for wood treatment Offcut and sawdust collection/ storage	Management: Purchasing policy, custody chain certificates, procedures and policies Operational: Process flow charts, work instructions, signage, training, inspections Equipment: Automation, designated storage areas, spill kits, metering, drain coding
Design office Input – paper, inks, IT equipment, energy, customer specification Output – design drawings and support material	Procurement (Inks/paper/IT Equipment) Energy use (Electricity) Energy use (Gas – for space heating)	Management: Purchasing policy, procedures, and policies Operational: Process flow charts Training, IT procedures, draft reviews Equipment: Default settings on printers, IT equipment, metering

Obviously, the standard itself must be consulted to ensure that all requirements are met, but considering the elements above will ensure that your operational control is defined, planned, and executed properly. In A new approach to documented information in ISO 14001:2105, we looked at the change in requirements that the 2015 standard brought, but you need to carefully consider what parts of your process need to be documented, and what the risks of not having documentation might be, according to your activities and their impacts. It may be that documented processes increase your chances of consistent behavior and, therefore, objectives being achieved.  Similarly, considerations on what level of control and documented information need to be made in regard to how your outsourced product or service is managed – the key thing is that you need to realize that your organization retains responsibility at all times. Strong and accurate reporting of your outsourced services from the organization’s service providers is the key to ensuring that the environmental objectives can be met and the significant impacts dealt with. Treat your planning, definition, and implementation of operational controls with the utmost importance, and your EMS performance will benefit.

Examples of operational control procedures

1. Waste management

Procedures should state who is responsible for ensuring legal compliance when waste is removed from the site. The procedure should reference how the appropriate documentation is completed correctly and filed away for the prescribed period of time. Locations for the storage of waste should be described and instructions as to how segregation of waste is to be carried out described. Procedures should detail further whether certain waste skips need to be protected from high winds and rain – which could blow or dissolve and wash some waste materials down surface water drains. Inspections of waste skip on-site should be inspected for rust. Such deterioration could decrease their load-bearing capacity or integrity, which could allow waste materials to fall onto public roads when being transported to the landfill site. The best practice is to also conduct audits of waste carriers and landfill sites. This can range from a desktop review of waste carrier and landfill licenses to a physical audit of tracing an actual waste removal from the site to the landfill site. Such an audit trail would also involve checking records and documentation, such as waste transfer notes. Landfill site licenses generally are very specific in describing what is accepted at each site, and detailed requirements for generating and maintaining records of waste. This can be further extended to inspection of the waste carrier’s transport, i.e. lorries and wagons for roadworthiness and whether the driver has a spillage kit and is trained to use it in the event of spillage onto a public road. These are all the best practical steps to prevent pollution and also avoid adverse publicity from the media and unwanted attention from the regulatory body.

2. Packaging waste

The European Directive on packaging waste places requirements on companies to recover certain percentages of waste and recycle set amounts. Companies can administer this themselves or join a compliance scheme. A procedure for the operational control of this waste should detail the responsible person who collects the data on packaging waste. Additionally, details of the prescribed time intervals for submission of this data to the regulatory authority should be included.

3. Contractors coming on site

The procedure should detail the requirements for contractors working on the site. A good practice is to show a brief video presentation of the organization’s environmental procedures, followed by a test of understanding.  Additionally, information packs should be issued containing for example:

• Site contact names and internal phone numbers (for environmental issues)
• What to do in an emergency
• list of actions which would be unacceptable such as disposal of waste into the site drainage system, burning of waste and not leaving the engine of vehicles running unnecessarily

Sub-contractors should sign a document as evidence they have understood the above.

4. Suppliers

A procedure for the purchasing department could include a list of the environmental responsibility criteria required of the organization’s suppliers. Meeting such criteria would be a part of purchasing negotiations between the organization and the supplier. The objective would be to stipulate grades of material that have low environmental impacts in production, use, and disposal. Of course, the organization cannot merely use environmental criteria and nothing else. As stated earlier, the purpose of the Standard is not to prevent a business from being successful. The commercial activities of the organization are paramount and must always come first in any decision-making event. If the business closes down then there is no environmental management system! For example, the procedure could detail that all existing suppliers be sent a questionnaire about their environmental probity as a first objective to obtain initial information. The procedure would then be written along the lines previously described.

5. Bunding inspection

Although bunding is built around storage vessels with the purpose of preventing leakage of the contents and, therefore, avoiding an environmental incident, in reality, it may create a false sense of security. Maintenance may not be carried out because of this misplaced sense of security. The operational control procedure should be in the form of an inspection program, and details of what action to take in the event of any damage to a bund wall.

6. Pipework inspection

Procedures for the inspection and maintenance of pipework and especially pipe joints should be implemented. It would be beneficial to identify which sections of pipe joints etc. could have the most significant environmental impact in the event of a failure and program in extra inspections in these areas.

7. Monitoring for compliance with site licenses

Although the regulatory authorities may periodically sample emissions or effluent, they would probably only issue a report or a concern in the case of non-compliance. Near misses or trends would not be a part of their reporting structure. Clearly to only rely on such reports creates environmental risks for the organization and it would, therefore, be best practice to have an operational control in place to periodically measure the parameters and note if there are any adverse trends emerging.

7. Future/Planned work

The Standard requires that any planned or new developments are considered and planned in advance so that the environment will not be compromised. Thus procedures need to be in place to give guidance in the instances of.

8. Construction work:

Procedures should detail the forward planning and investigations necessary prior to any construction work on site. For intended excavations, operational controls should detail the responsibility for carrying out surveys not only for buried pipelines and any contaminated land, but also any ancient monuments or historic sites. The procedure should detail contacts and experts who could assist in identifying any protected species, trees, and hedgerows, SSSI sites, marine habitats, or controlled waters. This could include the names of agencies to be contacted if wildlife habitats are to be disturbed and any local liaison groups if the construction is in a built-up or residential neighborhood.

9. Demolition work

Procedures should include some of the above considerations and if old buildings are the subject of demolition, then an asbestos survey should be carried out first. Such operational controls should also detail the steps to take in the event of discovering asbestos and the appropriate abnormal or emergency plans.

10. Housekeeping

In the context of ISO 14001, housekeeping is taken to mean ‘the visual appearance of the site’. Procedures should focus on defining locations for movable items, defining locations for redundant equipment, where tools should be stored, locations for discarded items and waste, etc. Housekeeping inspections should be detailed as to frequency and measures of compliance. Measuring the compliance of housekeeping can be subjective, and best practice involves the use of photographs to define the level of housekeeping required, area by area. With the advent of digital photography, this method of measurement is becoming widespread. Given that poor levels of housekeeping can contribute to the cause of accidents in the workplace, then some effort should be put into developing robust procedures. The certification bodies give this aspect of ISO 14001 what may seem too much attention but it is a visible sign of environmental improvement and sends a positive message to all stakeholders.

8.2 Emergency preparedness and response

The organization shall establish, implement and maintain the processes needed to prepare for and respond to potential emergency situations identified in clause 6.1.1. The organization must be prepared to respond by planning actions to prevent or mitigate adverse environmental impacts from emergency situations. The organization must respond to actual emergency situations and take action to prevent or mitigate the consequences of emergency situations, appropriate to the magnitude of the emergency and the potential environmental impact. It must periodically test the planned response actions, where practicable. It must periodically review and revise the processes and planned response actions, in particular after the occurrence of emergency situations or tests. It must provide relevant information and training related to emergency preparedness and response, as appropriate, to relevant interested parties, including persons working under its control.  The organization should maintain documented information to the extent necessary to have confidence that the processes are carried out as planned. 

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

It is the responsibility of each organization to be prepared and to respond to emergency situations in a manner appropriate to its particular needs. When planning its emergency preparedness and response processes, the organization should consider:

1. the most appropriate method for responding to an emergency situation.
2. internal and external communication processes
3. the actions required to prevent or mitigate environmental impacts
4. mitigation and response action to be taken for different types of emergency situations;
5. the need for post-emergency evaluation to determine and implement corrective actions;
6. periodic testing of planned emergency response actions;
7. training of emergency response personnel;
8. a list of key personnel and aid agencies including contact details (e.g. fire department, spillage clean-up services);
9. evacuation routes and assembly points;
10. the possibility of mutual assistance from neighbouring organizations.

Explanation:

Despite an organization’s best efforts, the possibility of accidents and other emergency situations still exists. Effective planning and preparation can reduce injuries, protect employees and neighbors, reduce asset losses and minimize production downtime. An effective emergency preparedness and response program should include provisions for assessing the potential for accidents and emergencies, preventing incidents and their associated environmental impacts, plans/processes for responding to incidents, periodic testing of emergency plans/processes and, mitigating impacts associated with these incidents. Consistent with your organization’s focus on continual improvement, it also is a good idea to review emergency response performance after an incident has occurred. This review can help determine if more training is needed or if emergency plans/processes should be revised. In the new standard Procedures are replaced by the phrase ‘processes needed to prepare for and respond to potential emergencies. This broader phrasing is however given a specific focus: to prepare for and take action to prevent or mitigate the consequences of an emergency. In addition, there is now an explicit requirement to now periodically review and revise process/plans after tests (as well as after the occurrence of accidents/situations).  Actions to plan for removal or mitigation of risk relating to emergency situations are required, as is a plan to respond to actual emergency situations themselves. Also, there is an addition to the clause regarding prevention and mitigation of risk, where the phrase “appropriate to the magnitude of the emergency and potential environmental impact” is used. The implication that a perfunctory “emergency response” plan in a “one size fits all” format will not be acceptable, but rather the risks and aspects that an organization has identified must be assessed and weighed up, and the emergency plan must, therefore, be proportionally related to the aspects themselves. Clearly, the emergency plan and procedure being formulated according to the risks that you have identified have its basis in risk-based thinking. Periodic review and revision of emergency preparedness procedures and plans are required. Testing the plan itself is also required, and there is a statement regarding reviewing the process “especially after the occurrence of emergency situations and tests.” Again, clearly, this statement is aimed at ensuring risk-based thinking is used in the general review of the plan, and just as importantly, any lessons that can be learned from incidents or testing can be recorded and actioned to support the continual improvement cycle. Perhaps if your EMS (Environmental Management System) doesn’t have a “Lessons Learned Log” or equivalent, now is the time to establish one? After all, documentation to ensure that confidence can be sustained in the integrity and effectiveness of the whole emergency preparedness system is naturally required.

The Standard requires that three components be addressed by the organization:

1. The organization shall establish, implement and maintain the processes needed to prepare for and respond to potential emergency situations
2. Review and revise the importance of learning from incidents.
3. It must periodically test the planned response actions, where practicable.

1. Establish, implement and maintain the processes

An organization is well advised to draw up an ‘Emergency Plan’ and to consider different levels of disaster – including the worst-case scenario. The worst-time scenario should also be evaluated which can occur at times of shift change, weekends, and holiday periods when staff may be reduced. The emphasis of such a plan will be placed upon ensuring that the business survives – that there will be the minimum of disruption of service, or supplies of product, to customers. Safety of individuals, staff, and others will naturally be paramount but of course, the environmental impact must be considered to address ISO 14001-Clause 8.2  The two factors safety and environmental impact can, of course, be interrelated for eg large volumes of toxic gases will cause environmental damage whilst posing a safety hazard at the same time. A suitable plan could cover:

• Identifying critical assets – usually major items of plant
• Defining the disaster team and describing responsibilities
• Emergency services – how to contact them
• Enforcement agencies – how to contact them
• Listing communications – including out-of-hours phone numbers
• Holding regular exercises – to test the system
• Setting up a media response team – details of who is responsible for contacting the media

Examining the function of the media response team further is worthwhile. It is tempting in the event of an environmental incident to offer no comment to the press. However, other parties, who may be hostile to the organization, will comment. This could be disgruntled neighbors, competitors, and others who will take the opportunity to repeat rumors or provide media with exaggerated accounts of the incident. The media will find out, despite efforts to deter them. An attempt to hide issues will usually be uncovered later and will ultimately reduce the credibility of future communications. If, for example, there is a large spillage to a local stream or river with a high amenity value and the organization does not control the media input, the information any interested party receives may be inaccurate at best and hostile at worst. This could influence future relationships with the media. The news-gathering media work to strict deadlines and information is required from whatever source. It is best, therefore, that this source is the organization itself. Possible emergencies will most certainly have been identified during the preparatory environmental review and suitable responses formulated. At the simplest level of response, this may include a list of competent personnel who can be contacted with alternatives in the event of an emergency situation. Provision should also be made for off-site availability of the information needed to contain the disaster in case access to the site is denied on the grounds of safety. The main objectives of the fire service are to control the fire and/or chemical spillage and save lives. They may cordon off the site and prevent access to staff who require telephone numbers to make contact with other personnel, access to records or emergency procedures, etc. It is worthwhile noting that even if a fire situation is handled correctly by the fire service, environmental problems can be caused by contaminated water used by the fire services. Such water, contaminated by combustion products, may enter canals, streams, and drains, and emergency plans should take this into consideration. It is also important to remember that just because risks are low, it does not mean that emergency plans are unnecessary. Without an emergency plan, minor incidents can escalate into major ones.

2. Review and revise the importance of learning from incidents

In the case of near misses, it is important that such potential incidents are recorded and reviewed and not hidden away or merely forgotten. Such incidents indicate areas of risk which on other occasions may turn into environmental accidents.

3. Testing of emergency plans

There may be situations where full-scale testing is not practical and thus consideration should be given to desk-top exercises that can be played out. Examples of such testing include:

• Can key individuals be contacted in an out-of-hours situation?
• If staff is injured can relatives be contacted?
• Are keys to certain areas (for example, solvent stores) available out of hours?
• Are vacations or absence due to sickness covered by alternative personnel?
• Can emergency services access the site – day or night?
• If there is ice on the road during winter would this prevent heavy vehicle access – fire-fighting equipment for example?
• Do the organization’s fire hydrants function correctly? Are they maintained and tested?
• Does the fitment on the hydrant fit the fire services hoses?
• Toxic gases may be released during a fire. If so, what are these gases? In which direction is the prevailing wind? What is the likely area that will need to be evacuated for safety as well as environmental reasons? What information will be given to the local police in such an event?

Test emergency scenarios at the shift change from day to night shift for example. During such shift changes, there is an overlap as incoming staff comes in early so that the outgoing staff may brief them as to events that have happened, etc. Thus, for a short period of time, there could be double the number of people on-site, causing extra congestion of roads, and lines of command may become blurred during this period. Some organizations ban the use of cellular phones during normal operations because of safety issues. Would staff be able to use them in an emergency?
If so, this should be written into the emergency procedure. Some organizations have wind direction indicators on-site so that in the event of an emergency (fire or noxious fumes escaping), staff can move away in the safest direction. Test scenarios should ascertain whether such indicators can be seen visually from all points of the site. Some organizations have an incident center that would reasonably be expected not to be influenced by a disaster i.e. underground or remote from flammable areas. Test scenarios should check whether this isolation is still valid. The time to put an emergency plan to the acid test and seek the answers to the above is not the day of the real event. Therefore, an organization should evaluate its risks of environmental emergencies and evaluate the extent to which it should carry out testing of its procedures.

Several environmental and health and safety regulatory programs require emergency plans and/or procedures. Look at what you have in place now and assess how well it satisfies the items discussed above. One area where additional work is often needed is on identifying the potential for accidents and emergencies. A team of site personnel from example from engineering, maintenance, and Environmental Health and Safety) can identify most potential emergencies by asking a series of “what if” questions related to hazardous materials, activities, and processes employed at the site. In addition to normal operations, the team should consider the start-up and shutdown of process equipment and other abnormal operating conditions. Does everyone including new employees know what to do in an emergency? How would contractors or site visitors know what to do in an emergency situation? Communicate with local officials (fire department, hospital, etc.) about potential emergencies at your site and how they can support your response efforts. Mock drills can be an excellent way to reinforce training and get feedback on the effectiveness of your plans/procedures.  Post copies of the plan (or at least critical contact names and phone numbers) around the site and especially in areas where high hazards exist. Include phone numbers for your on-site emergency coordinator, local fire department, local police, hospital,  rescue squad, and others as appropriate.

Steps to set up Emergency Plan

Step 1: Identification. You have to identify the specific potential accident related to your circumstances and type of activity. If you run an office, a fire may be your only potential risk. Some types of accident and emergency:

• fire
• chemical explosion
• spillage or release of materials that are corrosive, toxic, flammable, or carcinogenic

Step 2: Prevention. You have to brainstorm with your personnel for preventive measures related to every type of accident. ISO 14001 states that emergency plan(s) shall include actions to prevent and mitigate associated environmental impacts. Preventive measures depend upon your specific situation and may include e.g.:

Type of Accident	Preventive Measures
Fire, explosion	Regular testing and maintenance of fire extinguishers Providing free access for fire trucks Posting labels and warning signs Training the staff Supervising activities
Spillage or release of materials that are corrosive, toxic, flammable, or carcinogenic	A waterproof concrete storage area (bonds) for collecting spilled fuel from the tank Storage of oil only on waterproof surfaces with controlled drainage system via the system for wastewater treatment Periodic inspection and testing tightness of bunds, reinforcement and drainage systems Training the staff Supervising activities

Step 3: Emergency plan. Depending on complexity and needs, the organization should establish one or more emergency plans. An emergency plan aims to:

• define the types of accident and environmental impacts (step 1)
• define preventive measures (step 2)
• provide contact information to key personnel (on-site & off-site)
• identify the location of appropriate technical data and emergency equipment (site layout)
• highlight any special instructions or actions
• identify and provide names of people trained in first aid

Make sure that all your staff knows about the plan, where to find it, and what it contains.  It is important that they know how to prevent accidents and what to do in case an accident occurs. You should, as stated in ISO 14001, review and revise your emergency plan where necessary, particularly after the occurrence of accidents or emergency situations The Emergency Plan is not intended to be a comprehensive instruction with all background information. It is a clear and simple operational procedure for dealing with accidents.

Step 4: Training and drills (testing for training effectiveness). You have to train your employees about preventive measures and your emergency plan, and you should include in the training plan all necessary background information. Unfortunately, this is not enough, because, in a real emergency situation, people’s behavior is unpredictable. To be sure that personnel will react according to the emergency plan, you have to, as stated in ISO 14001, perform periodic drills based on predefined scenarios. How often? That depends on the risk. For example, atomic submarines have daily or weekly drills. The frequency of testing should be related to the environmental risk of your site, staff turnover, the introduction of new processes or materials, and conclusions from any previous exercises or incidents. For the average SME, yearly drills will usually be satisfactory.

Step 5: Evaluation and improvement. Drill reports have to take into consideration the gaps between the emergency plan and the drill result. The output of the drill report should focus on closing gaps and any other recommendations related to the improvement of the emergency plan. For example, you may notice during the drill that free access for fire trucks is blocked by pallets for raw materials. You have to highlight this in the report, followed by, as stated in ISO 14001, corrective actions for eliminating the cause of incidents in order to prevent a recurrence. What does that mean? You have to find out why free access was blocked, e.g., due to the lack of warning labels, or employee training, or something else, followed by actions to prevent it from happening again in the future. With this approach, you will continue to improve your performance over time, which is one of the fundamental requirements of ISO 14001.

Even with the best preparation and prevention, accidents still happen. When they do, you will be prepared and ready for a fast reaction to minimize injury, environmental damage, equipment loss, and eliminate unnecessary calls to public emergency services.