Clause 10 Improvement

ISO 9001:2015 Clause 10, Improvement, has three sub-clauses:

10.1 General
10.2 Nonconformity and Corrective Action
10.3 Continual Improvement

10.1 General

10.2 Nonconformity and corrective action

ISO 14001:2015 Clause 9 Performance evaluation is all about measuring and evaluating your EMS to ensure that it is effective and it helps you to continually improve. You will need to consider what should be measured, the methods employed, and when data should be analyzed and reported on. As a general recommendation, organizations should determine what information they need to evaluate environmental performance and effectiveness. Once the EMS is implemented, ISO 14001 requires permanent monitoring of the system as well as periodic reviews to:

• evaluate the effectiveness of the implemented EMS
• objectively evaluate how well the minimal requirements of the standard are fulfilled
• verify the extent to which the organizational, stakeholder and legal requirements have been met;
• review the suitability, adequacy, effectiveness, and efficiency of the EMS;
• demonstrate that planning has been successfully implemented;
• assess the performance of processes;
• determine the need or opportunities for improvements within the environmental management system.

Internal audits will need to be carried out, and there are certain “audit criteria” that are defined to ensure that the results of these audits are reported to relevant management. Finally, management reviews will need to be carried out, and “documented information” must be kept as evidence.

Clause 9 Performance evaluation has three subclause

• 9.1 Monitoring, measurement, analysis and evaluation
  • 9.1.1 General
  • 9.1.2 Evaluation of Compliance
• 9.2 Internal audit
  • 9.2.1 General
  • 9.2.2 Internal Audit Programme
• 9.3 Management Review

9.1 Monitoring, measurement, analysis and evaluation

9.1.1 General

The organization must monitor, measure, analyze and evaluate its environmental performance. It must determine what needs to be monitored and measured and as applicable the methods for monitoring, measurement, analysis, and evaluation to ensure valid results. It must determine the criteria against which environmental‘ performance and its appropriate indicators will be evaluated. It must also determine when the monitoring and measuring shall be performed and when the results from monitoring and measurement will be analyzed and evaluated. The organization must ensure that calibrated or verified monitoring and measurement equipment is used and maintained, as appropriate. The organization must also evaluate its environmental performance and the effectiveness of the environmental management system. The organization must communicate relevant environmental performance information both internally and externally, as identified in its communication processes and as required by its compliance obligations. The organization must retain appropriate documented information as evidence of the monitoring, measurement analysis, and evaluation results.

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

When determining what should be monitored and measured, In addition to progress on environmental objectives, the organization should take into account its significant environmental aspects, compliance obligations, and operational controls. The methods used by the organization to monitor and measure, analyze and evaluate should be defined in the environmental management system, in order to ensure that:

1. the timing of monitoring and measurement is coordinated with the need for analysis and evaluation results;
2. the results of monitoring and measurement are reliable, reproducible and traceable;
3. the analysis and evaluation are reliable and reproducible and enable the organization to report trends.

The environmental performance analysis and evaluation results should be reported to those with responsibility and authority to initiate appropriate action.

Explanation:

An EMS without effective monitoring and measurement processes is like driving at night without the headlights on — you know that you are moving but you can’t tell where you are going. Monitoring in the sense of ISO 14001 means that the organization should check, review, inspect and observe its planned activities to ensure that they are occurring as intended. Monitoring generally means operating processes that can check whether something is happening as intended or planned. In some respects auditing processes address this, but also operational control procedures will apply. Thus if an operational control states that housekeeping audits will occur twice weekly then this is a monitoring process, i.e. the site is checked weekly for ‘good housekeeping practices. This could also involve ‘visual’ checking of the integrity of bunding around solvent storage tanks for example. Measurement tends to mean that the size or magnitude of an event is measured, calculated, or estimated with a numerical value assigned. This could include procedures for weighing wastes sent to landfill; the amount of gas or electricity consumed per week, measuring noise levels at the site boundary, etc. Additionally, any equipment used to calculate or estimate such numbers should be suitably calibrated so that a high level of confidence is gained that the numbers are indeed a true representation of the facts.  Monitoring and measurement help you:

• evaluate environmental performance;
• analyze the root causes of problems;
• assess compliance with legal requirements;
• identify areas requiring corrective action, and,
• improve performance and increase efficiency.

In short, monitoring and measurement help you manage your organization better. The results of pollution prevention and other efforts are easier to demonstrate when current and reliable data are available. These data can help you demonstrate the value of the EMS to top management. Your organization should develop means to:

• Monitor key characteristics of operations and activities that can have significant environmental impacts and/or compliance consequences;
• Track performance (including your progress in achieving objectives and targets);
• Calibrate and maintain monitoring equipment; and,
• Through internal audits, periodically evaluate your compliance with applicable laws and regulations.

Example of Links between Significant Aspects, Objectives, Operational Controls, and Monitoring and Measurement

Monitoring Key Characteristics

Many management theorists endorse the concept of the “vital few” — that is, that a limited number of factors can have a substantial impact on the outcome of a process. The key is to figure out what those factors are and how to measure them.

Most effective environmental monitoring and measurement systems use a combination of process and outcome measures. Select a combination of process and outcome measures that are right for your organization.

• Outcome measures look at the results of a process or activity, such as the amount of waste generated or the number of spills that took place.
• Process measures look at “upstream” factors, such as the amount of paint used per unit of product or the number of employees trained on a topic.

Tracking Performance

To have a successful EMS, it is important to determine program measurement criteria. Determining measurement criteria, also called performance indicators, will help you evaluate the success of your overall EMS program. Performance indicators measure overall success, while key characteristic indicators measure progress against EMS objectives for specific SEAs.These performance indicators focus on how well the overall system for improving environmental management is functioning. Select performance indicators that will help you and your employees decide whether success has been achieved or whether improvement in procedures needs to be made. It is easier for management and staff to understand how things are going if they have benchmarked as guidelines. You will need performance indicators that describe how well your environmental policy is being implemented. In addition, you will need performance indicators for all of the various components of your EMS. The measurement criteria selected for each component of your EMS will probably be different. For example, how will you measure the success of communication, documentation, stakeholder outreach, or training programs?
One approach is to measure the actions, for example, the number of meetings held with stakeholders, the number of documents created, the number of employees trained, or the number of hours of training. Action, however, does not always mean results. Consider the objective of each EMS component and define a way to measure results so that you would feel satisfied that the objectives are being achieved. Here are some examples of EMS results Performance Indicators for your EMS or various program components that can be tracked over time:

• number of SEAs included in environmental projects plan
• number of environmental objectives and targets met
• pounds of hazardous waste generated per unit of production
• employee sick leave absences related to the work environment
• percentage of employees completing environmental training
• average time for resolving corrective action
• energy or water use per unit of production
• percentage of solid waste recycled/reused
• number of complaints from the community; the number of responses to complaints
• number of pollution prevention ideas generated from employees
• resources used per unit of product or service
• pollution (by type) generated per unit of product or service
• percentage of products for which life cycle assessment has been conducted
• number of products which have a recycling program
• number of instances of non-compliance

It is the results shown by these environmental performance indicators that will become the basis for your plans for next year and for documenting continuous improvement. Measuring pollution prevention achievements is part of tracking performance, but maybe different from, and often more difficult than, measuring environmental achievements in general. Simply measuring the reduction in a waste stream might mean only that the waste has been transferred to another medium, not reduced. It is therefore important to measure the reduction at the source of waste generation. It may also be important to measure the activities that your company directs towards pollution prevention. The following sources of information may help you track pollution prevention:

• Permit applications
• TRI reports
• Purchasing records
• Utility bills
• Hazardous waste manifests
• Material Safety Data Sheets

In addition, administrative procedures can be established to support pollution prevention activities. Your facility should consider:

• Establishing procedures in each facility area for identifying pollution prevention opportunities.
• Having a chemical or raw material inventory system in place.
• Assessing how many objectives have been met through pollution prevention.

Sample of Environmental Performance Indicators Log

Types of Environmental performance indicators (EPIs)

• Management performance indicators (MPIs): policy, people, planning activities, practice, procedures, decisions, and actions in the organization
• Operational performance indicators (OPIs): inputs, the supply of inputs, the design, installation, operation and maintenance of the physical facilities and equipment, outputs and their delivery
• Environmental condition indicators (ECIs): Provide information about the local, regional, national or global condition of the environment It help an organization to better understand the actual impact or potential impact of its environmental aspects and assist in the planning and implementation of the EPE

Examples of performance indicators and metrics

Checklist for creating Monitoring and measurement element of your EMS

Calibrating Equipment

A component of monitoring and measurement is equipment calibration. Your facility should identify process equipment and activities that affect your environmental performance. As a starting point, look at those key process characteristics you identified earlier. For monitoring and measurement you can:

1. measure the equipment itself (for example, measuring the paint flow rate through a flow gun to see if it is within the optimal range for transfer efficiency) or
2. you can add measurement equipment to a process to help measure the key characteristic (for example, a thermometer on a plating bath to make sure that the temperature is within the optimal range for plating quality to reduce the need for replating which causes significant waste through product rework).

Some organizations place critical monitoring equipment under a special calibration and preventive maintenance program. This can help to ensure accurate monitoring and make employees aware of which instruments are most critical for environmental monitoring purposes. Some organizations find it is more cost-effective to subcontract calibration and maintenance of monitoring equipment than to perform these functions internally. An illustration of how calibration needs are tied to SEAs, operational controls, key characteristics of the operation, and monitoring and measurement methods is presented below a sample of Calibration Log

Step involved in Monitoring and Measurement

• Monitoring and measuring can be a resource-intensive effort. One of the most important steps you can take is to clearly define your needs. While collecting meaningful information is clearly important, resist the urge to collect data “for data’s sake.”
• Review the kinds of monitoring you do now for regulatory compliance and other purposes (such as quality or health and safety management). How well might this serve your EMS purposes? What additional monitoring or measuring might be needed?
• You can start with a relatively simple monitoring and measurement process, then build on it as you gain experience with your EMS. It is better to measure fewer items consistently than to measure many items inconsistently.
• Regulatory compliance: Determining your compliance status on a regular basis is very important. You should have a procedure to systematically identify, correct, and prevent violations. Effectiveness of the compliance assessment process should be considered during the EMS management review.
• Operational performance: Consider what information you will need to determine whether the company is implementing operational controls as intended
• 
• Progress on meeting objectives: You should measure progress on achieving objectives and targets on a regular basis and communicate the results of such measurement to top management. To measure progress in meeting objectives, select appropriate measurements of the key characteristics which apply to that objective.

• Selecting performance indicators: Performance indicators can help you to understand how well your EMS is working overall. Start by identifying a few performance indicators that are:
  • simple and understandable;
  • objective;
  • measurable;
  • relevant to what your organization is trying to achieve (i.e., its objectives)

  Data collected on performance indicators can be quite helpful during management reviews. So, select indicators that will provide top management with the information it needs to make decisions about the EMS. Make sure you can commit the necessary resources to track performance information over time. It is OK to start small and build over time as you gain experience in evaluating your performance. Keep in mind that no single measurement will tell your organization how it is doing in the environmental area.

• Communicating performance: People respond best to information that is meaningful to “their world.” Putting environmental information in a form that is relevant to their function increases the likelihood they will act on the information. Be sure to link your measurement program with your communications program and other elements of the EMS.
• Assessing regulatory compliance: Determining your compliance status on a regular basis is very important. You should have a process to systematically identify, correct, and prevent violations. Performance of the compliance management program should be considered during the EMS management review Elements of Compliance Management Program are:

• Organization policies and standards that describe how employees are to meet the regulations.
• Assignment of responsibility for compliance oversight.
• Processes to systematically ensure that policies and standards are carried out (e.g., monitoring and auditing).
• Appropriate incentives and disciplinary procedures.
• Prompt disclosure of findings.
• Prompt and appropriate correction of problem

  Sample Form for Compliance Tracking Log

•  Make sure you can commit the necessary resources to track this information over time. It is OK to start small and build over time as your company gains experience in evaluating its performance. Keep in mind that no single measurement will tell your organization how it is doing in the environmental area. People respond best to information that is meaningful to “their world.” Putting environmental information in a form that is relevant to their function increases the likelihood they will act on the information. Be sure to link your measurement program with your communications program and other elements of the EMS such as management reviews.
• The distinction between audits and environmental performance evaluation can be confusing. The figure below is intended to explain the two concepts. Both are important to your EMS.

9.1.2 Evaluation of Compliance:  For evaluation of Compliance please click here

9.2 Internal Audit

9.2.1 General

The organization must conduct internal audits at planned intervals to provide information on whether the environmental management system conforms to the requirements of ISO 14001:2015 standards, its own requirements for its environmental management system, and also to check whether the environmental management system is effectively implemented and maintained.

9.2.2 Internal audit program

The organization must establish, implement and maintain an internal audit program, including the frequency, methods, responsibilities, planning requirements, and reporting of its internal audits. When establishing the internal audit program. the organization shall take into consideration the environmental importance of the processes concerned, changes affecting the organization, and the results of previous audits. The organization must define the audit criteria. and scope for each audit. The organization must select auditors and conduct audits to ensure objectivity and the impartiality of the audit process; It must ensure that the results of the audits are reported to relevant management. The organization must retain documented information as evidence of the implementation of the audit program and the audit results.

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

Auditors should be independent of the activity being audited, wherever practicable, and should in all cases act in a manner that is free from bias and conflict of interest. Nonconformities identified during internal audits are subject to appropriate corrective action. When considering the results of previous audits, the organization should include:

1. previously identified nonconformities and the effectiveness of the actions taken;
2. results of internal and external audits.

Explanation:

Internal audits have always been a key element of ISO 14001 in helping to assess the effectiveness of the environmental management system. An audit program needs to be established to ensure that all processes are audited at the required frequency, the focus is on those most critical to the business. To ensure that internal audits are consistent and thorough, a clear objective and scope should be defined for each audit.  This will also assist with auditor selection to ensure objectivity and impartiality. To get the best results, auditors should have a working knowledge of what is to be audited, but management must act on audit results. This is often limited to corrective action relating to any nonconformities that are found, but there is also needs to be consideration of underlying causes and more extensive actions to mitigate or eliminate risk. Follow-up activities should be performed to ensure that the action taken as a result of an audit is effective.

EMS Audit can be defined as “ A systematic and documented verification process of objectively obtaining and evaluating evidence to determine whether an organization’s environmental management  system conforms to the system audit criteria environmental management set by the organization, and for communication of the results of this process to management.” Once your organization has established its EMS, verifying the implementation of the system will be critical. To identify and resolve EMS deficiencies you must actively seek them out. In a small organization, audits are particularly relevant since managers are often so close to the work that they may not see problems or bad habits that have developed. Periodic EMS audits will establish whether or not all of the requirements of the EMS are being carried out in a specified manner.

In compliance with the 14001:2015 standard, your Management Team will have identified environmental risks, set targets based on environmental legislation, and set key performance indicators to meet and eventually be improved upon – all designed to ensure that your organization’s environmental impact is as positive as it can be. The internal audit is now your chance to ensure that not only are these targets met, but that they are relevant, and meet all the needs of current legislation and internal needs. Before embarking on an internal audit on your environmental management system, it is advisable to carefully examine the targets and standards you are trying to meet, and whether you have a risk register, aspect register, or whatever way you record your results. Part of your internal audit should be assessing the accuracy and relevance of your objectives. Are they current in terms of legislation? Do any newly apparent risks exist that have not been formally identified? Has the management team considered all stakeholders when setting objectives and targets? It’s not uncommon for operators downstream to be able to identify environmental risks on a day-to-day basis that are not always apparent at a higher level. If you can find these, for example, your audit will be effective. You are identifying areas that can be improved, and aspects that may not be considered. Providing constructive suggestions for improvement is at the very core of any effective audit process. With opportunities for improvement and constructive suggestions found, you can now continue with auditing the system properly. Seek feedback on the results and process your audit. Are the set targets achievable? Are they still relevant? Are there barriers in the way to achieving them? Remember, if you can find barriers that do exist, you are one step away from finding improvement. Is legislation being met? Is your Legal Register up to date? Work collaboratively with the people who design, use, and depend on your Environmental Management System. See the internal audit process as a chance to use your combined knowledge and ability to improve performance, rather than a one-way channel where an auditor asks questions and the auditee responds defensively. Ensure you follow through on your improvements. Your company and the environment will surely see the benefits. For your EMS audit program to be effective, you should:

• develop audit procedures and protocols;
• establish an appropriate audit frequency;
• train your auditors; and,
• maintain audit records.

The results of your EMS audits should be linked to the corrective action system. While they can be time-consuming, EMS audits are critical to EMS effectiveness. Systematic identification and reporting of EMS deficiencies to management provide a great opportunity to:

• maintain management focus on the environment,
• improve the EMS, and
• ensure its cost-effectiveness.

Audit Methodology

The two methodologies for conducting audits are Compliance auditing and Performance Auditing. Compliance auditing is more of the style of ‘traditional’ auditing, i.e. ensuring that procedures are being followed in order to comply with the requirements of ISO 14001. This type of audit ensures that personnel is following procedures: i.e. taking measurements when and where they should; reviewing and updating the legislation register; generating the appropriate records, etc. Such auditing methodology will be second nature to an organization that already has a documented quality assurance system meeting the requirements of ISO 9001. It is important that the internal auditors can identify ‘environmental’ nonconformances during the audit. A compliance non-conformance is, for example, when a member of personnel neglects either due to an oversight to log onto a register the daily amounts of one waste stream going to landfill. The action is taken but not recorded. An environmental non-conformance could be a measurable target (such as the monthly figure for use of recycled paper not increasing as planned). If this has not been identified by operatives and management, for whatever reason, and corrective action not taken, then this may affect the objectives set. It may jeopardize a statement within the environmental policy and constitute a potential environmental non-compliance.

Audit Frequency:

In determining the frequency of your EMS audits, some issues to consider are:

• the nature of your operations,
• the significant environmental aspects/impacts
• the results of your monitoring program, and
• the results of previous audits.

As a rule of thumb, all parts of the EMS should be audited at least annually. You can audit the entire EMS at one time or break it down into discrete elements for more frequent audits.

Auditor qualifications :

You will need to be trained in EMS auditors. Auditor training should be both initial and ongoing. Some organizations use existing and available quality systems auditors from an existing ISO 9001 system for the compliance auditing but for Performance audit, the auditor would need to have a grasp and understanding of the Standard and the EMS, and a broad understanding of environmental issues. Such requirements can certainly be achieved through an independent learning process with a combination of formal training and direct experience. EMS auditors should be trained in auditing techniques and management system concepts. Familiarity with environmental regulations, facility operations, and environmental science is a big plus, and in some cases may be essential to adequately assess the EMS. Some auditor training can be obtained on-the-job. Your organization’s first few EMS audits can be considered part of your auditor training program but make sure that an experienced auditor takes part in those “training” audits. If your company is registered under ISO 9000, consider using your internal ISO 9000 auditors as EMS auditors. Although some additional training might be needed, many of the required skills are the same for both types of audits.  Auditors should be reasonably independent of the area or activity that is being audited. An auditor, auditing his own area of competence, is hardly likely to be impartial – especially if faced with a potential nonconformity directly traceable to their error!

Reporting back to management

Management can use EMS audit results to identify trends or patterns in EMS deficiencies. The organization must also make sure that any identified system gaps/deficiencies are corrected in a timely fashion and that the corrective actions are documented. As noted initially, the Standard calls for some form of feedback to management on the results of the audits. In truth, this is common sense, because if the results of the audits demonstrate major discrepancies in what was planned through objectives and targets and what is actually being achieved, then management needs to reconsider the effectiveness of the whole system in order to fulfill its obligations as set out in the environmental policy.

Auditing procedure

The methodology for performing the audits should be established within written procedures. How else can an internal auditor know how to conduct the audit? Frequencies of auditing should be specified written in a schedule, plan or even a chart and this should take into consideration the results of previous audits. Many non-conformities raised at the last audit should trigger off a more frequent re-audit until it is established that the corrective and preventive measures have worked. Finally, other types of audits used by organizations include external site audits,  housekeeping (litter, etc.), the visual impact from the outside, odors, dust. These additional audits can only add to the effectiveness of the compliance and performance audits. Your EMS audits should focus on objective evidence of conformance. If you cannot tell whether or not a particular procedure has been followed, then you should consider revising the procedure. During the actual audit, auditors should resist the temptation to evaluate why a procedure was not followed, that step should come later. During the course of the audit, auditors should discuss identified deficiencies with the people who work in the area. This will help the auditors verify that their understanding is correct. It can also serve as refresher training on EMS requirements for employees.  If possible, train at least two people as internal auditors. This allows your auditors to work as a team. It also allows audits to take place when one auditor has a schedule conflict. Before you start an audit, be sure to communicate the audit scope, schedule, and other pertinent information with the people in the affected area(s). This will help avoid confusion and will facilitate the audit process. Consider linking your EMS audit program to your regulatory compliance audit process. But keep in mind that these audit programs have different purposes, and while you might want to communicate the results of EMS audits widely within your organization, the results of compliance audits might need to be communicated in a more limited fashion.

The process to conduct Internal audit can be as follows

1) The Audit Schedule
Just as with any good internal audit process for any management system, the first important thing is to have an overall schedule of when you are planning to audit each process that will be audited for system conformance. The cycle for this is often a year but can be whatever you like, and the frequency of audits on any given process is linked to criteria like the environmental importance of the process and past audit conformance. If you have a process that has critical environmental aspects associated with it, you may want to look at this process more often than one that can have only a minor impact on the environment. The audit schedule should be available to employees and managers because you don’t want to have surprise audits.

2) Process Audit Planning
After confirming the audit with the process owner, the auditor can start to make preparations for the audit itself. Review of the process is critical for this – in particular, understanding the environmental aspects associated with the process. This is the key difference between an internal audit for a QMS and an internal audit for an EMS. While a QMS audit will look at a process and how well it is performing against the plans for the product or service of the company, and EMS audit will look at how well the process is performing against the plans for the environmental aspects associated with the process. A good audit plan will make sure you look for all the right data to support these process plans.

3) Performing the Audit
Probably the first thing to remember about performing the audit is that you are not using the internal audit to judge the legal compliance of the process. While a compliance audit is a good idea, and sometimes a legal requirement, this is not the goal of the internal audit program. This process is identified elsewhere in section 4.5.2 of the ISO 14001 standard. The internal audit is looking at the process against the environmental plans that the company outlined for the process. Are the environmental aspects monitored when applicable? Are any required environmental operational controls in place and maintained? Are nonconformities, corrective actions, and preventive actions against the process being addressed? In short, you are evaluating if the process meets the planned conditions with respect to how it can interact with the environment.

4) Audit Reporting
Like all audits, an EMS process audit is almost valueless if it is not properly reported. If the employees engaged in the process are doing well, they need to know this. Conversely, if there are problems, employees need to understand what these are so that they can be addressed and corrected. Opportunities to improve that are identified in the audit need to be presented to the process employees to consider their value in making their process better. These are the main ways that a company can gain value from the internal audit process, and if they are not well reported you can lose this value.

5) Follow Up on the Audit Issues and Improvements
Just as with corrective and preventive action, follow-up is one of the least well-done parts of the internal audit process. If there is no closed loop to follow up on the actions and opportunities presented by the audit, then the value of identifying them in the first place is lost. Making sure that a problem that was previously identified is actually fixed can prevent the futile reporting of the same problem again and again. Use follow up to make your internal audits better.

9.3 Management review

Top management must review the organization’s environmental management system, at planned intervals, to ensure its continuing suitability, adequacy, and effectiveness. The management review must include consideration of the status of actions from previous management reviews. It must also include changes in external and internal issues that are relevant to the environmental management system, the needs and expectations of interested parties, including compliance obligations; its significant environmental aspects; risks and opportunities; the extent to which environmental objectives have been achieved. The Management review must take into consideration the adequacy of resources and relevant communication from interested parties, including complaints. The management review must include  information on the organization’s environmental performance, including trends in

•  nonconformity and corrective actions;
• monitoring and measurement results;
• fulfilment of its compliance obligations; 
• audit results; 

It must also take into consideration the opportunities for continual improvement. The outputs of the management review must include 

• conclusions on the continuing suitability, adequacy, and effectiveness of the environmental management system;
• decisions related to continual improvement opportunities;
• decisions related to any need for changes to the environmental management system, including resources; 
• actions, if needed, when environmental objectives have not been achieved;
• opportunities to improve integration of the environmental management system with other business processes, it needed;
• any implications for the strategic direction of the organization.
• The organization must retain documented information as evidence of the results of management reviews.

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

The management review should be high-level; it does not need to be an exhaustive review of detailed information. The management review topics need not be addressed all at once. The review may take place over a period of time and can be part of regularly scheduled management activities, such as board or operational meetings; it does not need to be a separate activity. Relevant complaints received from interested parties are reviewed by top management to determine opportunities for improvement. “Suitability” refers to how the environmental management system fits the organization its Operations, culture, and business systems. “Adequacy” refers to whether it meets the ISO 14001:2015 requirements and is implemented appropriately. “Effectiveness” refers to whether it is achieving the desired results.

Explanation:

ISO 14001 requires that the organization’s top management shall, at planned intervals that it determines, review the environmental management system to ensure its continuing suitability, adequacy, and effectiveness. Again, common sense dictates that once a system is implemented, there should be a review process to test whether what was planned does happen in reality. Just as a person should have periodic physical exams, your EMS must be reviewed by management from time to time to stay “healthy.” Management reviews are the key to continual improvement and to ensuring that the EMS will continue to meet your organization’s needs over time. Management reviews also offer a great opportunity to keep your EMS efficient and cost-effective. For example, some organizations have found that certain procedures and processes initially put in place were not needed to achieve their environmental objectives or control key processes. If EMS procedures and other activities don’t add value, eliminate them. The key question that a management review seeks to answer is: “Is the system working? i.e., is the EMS suitable, adequate, and effective, given our needs?”

ISO 14001:2015 standard sets out what is required from an organization in terms of management review, and what input and output criteria need to be satisfied to demonstrate the organization’s commitment to continual improvement. As you would expect, defining targets and objectives is also a staple of this initial management review process, and an organization’s top management team should play a key role in this, but the increased emphasis on leadership in the 2015 standard means that top management will be expected to understand and be able to talk about how the EMS is measured and improved, and how effective this has been. Therefore, an increased focus on having accurate, meaningful, and sustainable targets and objectives will arise. An increased expectation of demonstrable and measurable leadership will be expected from the ISO 14001:2015 auditor. An organization’s top management team must now take extra care in setting out its environmental targets, objectives, and authorities within the business. Can the team demonstrate leadership throughout the process, from target setting, through communication to delivery and review of performance, finally ensuring that continual improvement is possible and indeed delivered? Are all employees and stakeholders aware of the objectives and what must be done to achieve them? Formalizing these processes by recording them at your management review will help you. Sharing your management review minutes with your team and stakeholders will also help you. Everyone can then be aware that the top management team is clear on its objectives, clear on its responsibility toward achieving them, clear in providing the support and resources for the organization to achieve them, and clear in providing an EMS and support system where continual improvement can be achieved via an established review and feedback channel.

There is no correct way to perform an environmental management review – it must suit the organization’s culture and resources. As the Standard refers to ‘top’ management, this does indicate that a certain level of seniority of personnel should be present at such reviews, to demonstrate commitment. There are two kinds of people who should be involved in the management review process: people who have the right information/knowledge and people who can make decisions. Determine the frequency of management reviews that will work best for your organization. Some organizations combine these reviews with other meetings such as director’s meetings while other organizations hold “stand-alone” reviews. For ISO 9000 purposes, management reviews are typically held once or twice per year. Regardless of what approach your organization takes, make sure that someone takes notes on what issues were discussed, what decisions were arrived at, and what action items were selected. Management reviews should be documented. The management review should assess how changing circumstances might influence the suitability, effectiveness, or adequacy of your EMS. Changing circumstances may be internal to your organization i.e., new facilities, new materials, changes in products or services, new customers, etc. or may be external factors such as new laws, new scientific information, or changes in adjacent land use

There are certain minimum areas to be reviewed and one option, used by most organizations, is to have a standard agenda for each meeting. The first point on the agenda should be a review of the Environmental Policy. This is the ‘driver’ for the whole system. Senior management should be able to examine it and say with confidence that what was planned (say 12 months ago) as stated in the policy, has occurred or that substantial progress has been made. Thus a typical agenda could be:

• Are the objectives stated in the Environmental Policy being met?
• Does the organization have the continuing capacity to identify environmental aspects?
• Does the system allow the organization to give a measure of significance to these aspects?
• Have the operational controls that were put in place achieved the desired levels of control?
• Are effective corrective actions taking place to ensure that where objectives are in danger of slippage, extra resources ensure a return to the planned time-scale?
• Are internal audits effective in identifying non-conformances?
• Is the environmental policy sufficiently robust for the forthcoming 12 months?

So, your top management team has set out its objectives, hopefully after a degree of employee consultation. The communication channel has been established; your stakeholders understand where the responsibilities lie and know that the support is in place to work toward achieving these goals. Many organizations have one management review per year. Is this sufficient to ensure targets are achieved and continual improvement is seen? As long as you have a defined vehicle to ensure all the vital aspects are reviewed, actioned, and improved, the answer is “yes.” This may be a weekly or monthly EMS meeting, and you can formally record what you discuss and decide to action there. This will keep you true to the targets and objectives you set up at that management review meeting. But, we are all human and sometimes forget things. Many companies choose to show their environmental performance results in their foyer or reception areas, whether on noticeboards or electronically. These KPIs are usually formulated at your management review meeting – why not summarize the management review minutes accordingly, and display them too? Sometimes everyone needs reminding of what they are actually trying to achieve, and having a summary of these minutes is a very effective way of doing so – and maintaining everyone’s focus on them. It could be argued that during the early months of the implementation period (perhaps prior to certification) these cyclical reviews are not appropriate and they should focus on just the progress of the implementation of the system. This is a reasonable viewpoint but, as the system approaches maturity, a review as above is beneficial at intervals of 6 to 12 months. It would be prudent for the organization to perform one full management review, following the procedure, prior to the on-site audit, to demonstrate evidence of implementation to the certification body. If it is concluded that the set objectives are being met, the organization is well on its way to minimizing its significant environmental impacts and thus complying with the requirements of the Standard.

Questions to Ponder During Management Reviews

1. Did we achieve our objectives? (if not, why not?) Should we modify our objectives?
2. Is our environmental policy still relevant to what we do?
3. Are roles and responsibilities clear and do they make sense?
4. Are we applying resources appropriately?
5. Are the procedures clear and adequate? Do we need others? Should we eliminate some?
6. Are we monitoring our EMS (e.g., via system audits)? What do the results of those audits tell us?
7. What effects have changes in materials, products, or services had on our EMS and its effectiveness?
8. Do changes in laws or regulations require us to change some of our approaches?
9. What stakeholder concerns have been raised since our last review?
10. Is there a better way? What else can we do to improve?

Once you have documented the action items arising from your management review, be sure that someone follows-up. Progress on these items should be tracked. As you evaluate potential changes to your EMS, be sure to consider your other organizational plans and goals. Environmental decision-making should be integrated into your overall management and strategy

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

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.:

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.

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. 

7 Support

ISO 14001:2015 Clause 7 Support is all about the execution of the plans and processes that enable an organization to meet its EMS. Simply expressed, this is a very powerful requirement covering all EMS resource needs. Organizations will need to determine the necessary competence of people doing work that, under its control, affects its environmental performance, its ability to fulfill its compliance obligations, and ensure they receive the appropriate training. In addition, organizations need to ensure that all people doing work under the organization’s control are aware of the environmental policy, how their work may impact this, and the implications of not conforming with the EMS. Finally, there are the requirements for ‘documented information’ which relate to the creation, updating, and control of specific data.

Clause 7, Support, has five sub-clauses.

• 7.1 Resources
• 7.2 Competence
• 7.3 Awareness
• 7.4 Communication  is a separate article
  • 7.4.1 General
  • 7.4.2 Internal communication
  • 7.4.3 External communication
• 7.5 Documented Information is a separate article
  • 7.5.1 General
  • 7.5.2 Creating and updating
  • 7.5.3 Control of documented information

7.1 Resources

The organization should provide the resources needed for the establishment, implementation, maintenance and continual improvement of the environmental management system.

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

Resources are needed for the effective functioning and improvement of the environmental management system and to enhance environmental performance. Top management should ensure that those with environmental management system responsibilities are supported with the necessary resources. Internal resources may be supplemented by external providers. Resources can include human resources, natural resources, infrastructure, technology, and financial resources. Examples of human resources include specialized skills and knowledge. Examples of infrastructure resources include the organization’s buildings, equipment, underground tanks, and drainage system

Explanation:

Clause 7.1 requires that organizations “provide resources need for the establishment, implementation, maintenance and continual improvement of the environmental management system..” The term “resource” is most often used to imply human or financial resources, but there are many types of resources. Resources can also include equipment, materials, specialized skills, and facilities. Resources in this clause mean all of the human, financial, and material resources necessary to implement your EMS. Ensuring adequate resources for your EMS involves three general steps: i) identifying resource needs; ii) preparing a budget that addresses the needs, and iii) tracking EMS costs on an ongoing basis to ensure that resources continue to reflect current needs.
As a first step in ensuring that appropriate resources are available for the EMS, top management must be made aware of, and understand. the resource needs of the organization. You must identify what resources the EMS will require for proper functioning since you would be most familiar with EMS requirements. To identify EMS resource requirements. you will need to assess the level of effort your facility’s current environmental tasks require, as well as the effect of corporate plans, forecasts, new product development plans, production plans. and capital expenditure plans. It is important to consider business forecasting and new development plans when evaluating required resources because they can have a significant impact on environmental issues. For example. the top management of a semiconductor fabrication facility may be considering doubling the size of the facility’s operations. From an environmental management perspective. this has important implications for resources because such an expansion will typically increase the “regulatory footprint” of the facility. This might involve more environmental operating permits (e.g., air permits, wastewater permits. etc.) and increased use of hazardous materials and generation of hazardous waste, which might trigger additional regulatory requirements. To manage this increase in regulatory requirements, additional resources, personnel. and skills might be required. It may also require new capital expenditures. such as a new air scrubber and a continuous air emission monitor, or result in a change to the maintenance requirements for existing equipment because of the increased load on pollution control equipment.

Once the required resources have been identified. you should then develop a budget based on the current level of required resources. Most companies formulate resource budgets covering a one- to five- year period. An EMS budget should include all labor, capital expenses, and other items (such as specialized consultants) required to run your EMS. In addition to preparing a budget for the EMS. you should develop a system for keeping track of EMS costs on an ongoing basis. In many organizations, EMS activities are often charged to overhead and the costs may be difficult to identify among all of the other overheads. This creates a problem because unless you can identify what you spent on activities such as EMS auditing or management review you will find it difficult to allocate sufficient resources for future programs. One practical way of tracking required resources and costs associated with the proper functioning of your EMS is to assign cost codes to each category of environmental-related work at your facility, making sure to include management and auditing (internal and external) activities among these. Employees involved in environmental activities can then track the hours and resources they spend on various tasks and charge the time spent to the various job codes. By evaluating such information you can. over the course of several years, develop a clear understanding of the time and resources required for tasks within your EMS. Allocating and tracking costs does not prevent you from moving resources around to resolve immediate or unforeseen needs and gives you more effective control of costs. Tracking EMS costs over the course of several years will also enable you to determine whether the system is operating efficiently and provide benchmarking information with which to determine if your system is being “continually improved“. Clause 7.1 does not require any type of resource forecasting or documenting. The clause simply requires that resources be provided, and you are free to address this in whatever way best suits your particular situation.  Using the cost code approach would facilitate record keeping because the accounting records generated would in effect “‘document“ the resource requirements of the EMS. Without such documentation, it will be difficult to demonstrate to a certification auditor that your facility has allocated adequate resources to implement the EMS.

7.2 Competence

The organization must determine the necessary competence of persons doing work under its control that affects its environmental performance and its ability to fulfill its compliance obligations. The organization must ensure that these persons are competent on the basis of appropriate education, training, and experience. They must determine training needs associated with its environmental aspects and its environmental or management system and where applicable, take actions to acquire the necessary competence, and evaluate the effectiveness of the actions taken. The organization must retain appropriate documented information as evidence of competence.  Applicable actions can include the provision of training to, the mentoring of employees, reassignment of currently employed persons, or the hiring or contracting of competent persons.

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

The competency requirements of this International Standard apply to persons working under the organization’s control who affect its environmental performance, including persons:

1. whose work has the potential to cause a significant environmental impact;
2. who are assigned responsibilities for the environmental management system, including those who:
3. respond to emergency situations;
4. perform internal audits;
5. determine and evaluate environmental impacts or compliance obligations;
6. contribute to the achievement of an environmental objective;
7. perform evaluations of compliance.

Explanation:

This Clause requires that “ . . . persons are competent on the basis of appropriate education, training and/or experience.” Your overall goal is to produce knowledgeable, skilled, and aware employees who assist your facility in achieving its stated goals and objectives. You have the responsibility as part of your EMS, to develop an approach to judge the competence of employees to accomplish their assigned tasks. This can be achieved through establishing minimum levels of education and experience for specific positions or tasks and/or through competency testing after training or other methods such as mentoring, reassigning of employees to ensure employee knowledge. Tests may be written or oral quizzes or may involve demonstrations (e.g.. putting on personal protective equipment, or responding to a mock emergency). If written or oral quizzes are selected as the test method, it‘s important that the reading and education level of all participants be determined ahead of time so as not to introduce test bias. Whatever the testing mechanism selected, you must have some means of documenting test results. This will become part of your record-keeping process. Further, if an employee is conducting an inspection or monitoring program or is conducting an EMS audit and you find that the employee is not competent to conduct his or her job. you are required to take appropriate corrective action. Until that corrective action (such as retraining or any other means) is taken. you must ensure that the employee is appropriately supervised so that his or her lack of competence does not damage the effective implementation of the EMS.

This Clause requires the organization to:

• identify the knowledge and skills necessary to achieve environmental objectives (i.e., training needs analysis);
• implement training to provide the appropriate knowledge and skills; and
• ensure that employees doing work that may have a significant impact on the environment are competent.

The Standard requires that the organization shall identify training needs and this clause requires that all personnel whose work may create a significant impact upon the environment have received appropriate training. There are two excellent reasons for training employees about environmental management and your EMS:

• Every employee can have an impact on the environment.
• Any employee can have good ideas about how to improve environmental management efforts.

Although it is not specifically stated as a requirement, it also addresses regulatory-required and regulatory-derived training. Organizations conforming to ISO 14001 have committed to complying with applicable Compliance obligation which includes environmental laws and regulations, and this commitment includes implementing any training required by the regulations or required to implement the procedures necessary to achieve compliance. The specific training requirements that apply to an organization will be a function of that organization’s activities, products, and services, and consequently, the elements of that organization’s EMS. That is the training requirements are driven by an organization’s significant environmental aspects, compliance obligations, Operations, objectives and targets, environmental management programs, etc.

Training Requirements within an IS0 14001 EMS

The specific training requirements are driven by the general EMS elements, the significant environmental aspects, and any legal requirements that apply. Training for an individual employee will also be determined by that person’s roles and responsibilities within the EMS and by any environmental objectives and targets with which he or she is involved. Prior to assuming their roles within the EMS and being granted operating autonomy, employees must be judged competent to perform their roles successfully. The result of this training is, hopefully, knowledgeable, skilled, and aware employees. Practitioners and auditors have interpreted the training requirements into

• Job-specific training; and
• Regulatory-required training.

1.Job-specific Training

Job-specific training includes training required for specific jobs that are directly related to operations or equipment within an organization that can have an impact on the environment. The intent of job-specific training is to ensure that employees who have such jobs are knowledgeable about the environmental issues involved in their day-to-day activities. and what specifically they must do to ensure that the environment is protected in accordance with the environmental policy. Job-specific training will normally apply to operational-level employees. Those employees with “front-line” responsibilities who are involved in operating equipment or machinery. monitoring environmental indicators, and maintaining environmentally-related machinery (e.g., air scrubbers and water treatment equipment) must be trained in the appropriate procedures for performing these work activities. In addition, job-specific training may be conducted for those employees with specific EMS responsibilities. For instance, in order to fulfill the requirements of Compliance obligations which deals with legal and other requirements the person designated as being responsible for ensuring that the organization has identified the applicable regulatory requirements may require job-specific training.  Likewise. personnel involved in emergency response or conducting  EMS audits may also require training. Job-specific training includes training on:

• significant environmental aspects associated with specific job  tasks;
• established environmental objectives and targets and operational control involved with specific  job tasks;
• specific roles and responsibilities for job tasks related to  environmental issues;
• established operational procedures (and potential  consequences of departure from them); and
• emergency preparedness and response requirements.

This type of training is generally very practical in nature and specific to particular groups of employees and their assignments. For example,  employees operating metal plating equipment must understand how to operate the equipment in an environmentally sensitive manner (e.g..  how to avoid spilling plating solutions and how to operate plating baths to reduce the amount of hazardous waste generated) and how to meet permit-specific compliance requirements. They must also understand what to do when equipment fails and how to address environmental releases or other incidents. This includes knowledge of whom to contact within the organization when things go wrong or when they have questions. Job-specific training provides the training necessary to achieve the competence required by this Clause and may be used to periodically refresh existing employees‘ knowledge as well as to provide new employees with a baseline level of knowledge. Usually. regulatory-  required and regulatory—derived training involves job-specific tasks and is incorporated into job-specific training.

To identify job-specific training needs, you should focus on the identification of job titles or roles associated with the four primary drivers of job-specific training:

• significant environmental aspects;
• established environmental objectives and targets and established operational procedures, and
• associated environmental management programs;
• assignments of responsibility within the EMS itself.

(i) Significant Environmental Aspects

ln identifying job-specific training needs associated with significant environmental aspects. you should start with the significant environmental aspects and determine which of the related job functions and duties influence EMS performance. Some significant environmental aspects involve job activities that have very obvious environmental components. For example. the operation, maintenance, and repair of environmental abatement equipment such as air scrubbers or wastewater treatment equipment, by a maintenance worker, has very obvious implications with respect to the environment. If done incorrectly, there is the potential for a very real and direct impact on the environment in the form of water or air pollution. However, there are other job activities related to significant environmental aspects that have no direct impact on the environment but do have a potentially significant impact on overall environmental performance. An example of this type of job activity is the operation of equipment (e.g.. metal plating equipment) that uses hazardous materials and generates hazardous waste—the amount of hazardous waste generated by poorly conducted operations affects environmental performance. ln addition there are job activities that have no direct involvement with operations. but that involves actions or decisions that can significantly affect environmental performance. For example, activities performed by engineers, such as the design of equipment and selection of operating processes, can be beneficial or detrimental to environmental performance, depending on the choices made. Similarly, the job activities of purchasing agents, whose work involves the selection of raw materials and other product inputs, also have varying degrees of environmental impact.

(ii) Objectives

You should review your environmental objectives and management programs to determine what training and skills are necessary to accomplish them and who should be trained. In some cases, no additional training will be required. For example. an objective of lowering energy usage by replacing older less-efficient lighting with new lighting will require little if any, staff training. However. in other cases. job-specific training may be essential. Waste reduction programs often involve new processes that require the retraining of workers to be effective.

(iii) Operational Procedures

You should also review your documented operational procedures to determine what training and skills are necessary to accomplish them and who should be trained. In some cases, no additional training will be required. However, in some instances. detailed instrument calibration procedures, for example, training may be required. Often the documented operational procedure itself will serve as the primary training tool in that the training will involve going through the steps of the procedures in an “on-the-job” setting.

(iv) EMS Duties

The final driver for job-specific training in an EMS is assignments of responsibility within the EMS itself. As mentioned above, certain duties specifically required by your EMS may require training. Depending on the size and complexity of your facility. personnel at your facility may require training to ensure that they are competent to conduct activities in your EMS. For example, personnel involved in EMS audit programs will need to be trained in how to conduct and document the audits.

2. Regulatory-required Training

Regulatory-required training is training that is specifically required by federal, state (or provincial), and local regulations. For example, many countries have specific training requirements for employees who handle, use, or store hazardous materials. The intent of this training is to ensure that employees who are involved in job activities required by laws or regulations know how to conduct their work tasks in compliance with these laws and regulations. This type of training would apply to all employees at an organization who have duties that are required by the federal. state (or provincial). or local laws or regulations.

Criteria for EMS training

Each person and function within your organization can play a role in environmental management. For this reason, your training program should cast a wide net. Everyone in the organization should be trained on the environmental policy, significant environmental impacts of their work activities, key EMS roles and responsibilities, procedures that apply to their activities, and the importance of conformance with EMS requirements. All personnel should receive appropriate training. However, training is just one element of establishing competence, which is typically based on a combination of education, training, and experience. For certain key roles which include tasks that can cause significant environmental impacts, you should establish criteria for measuring the competence of individuals performing those tasks.

 Thus the organization must satisfy the following four criteria:

1. Ensure that training needs are identified:

This can be performed via appraisals. In most companies, this is an annual event – at the very least for salary review purposes. From this training needs will be identified and a plan of either internal or external training planned. All individuals will need some level of training in the requirements of the environmental policy and background to the requirements of ISO 14001. Some individuals will need specific training in emergency response. Others may need their roles to be changed and defined. An internal quality assurance auditor may well need to be ‘converted to an environmental systems auditor via an external training course.

2. Ensure that these planned needs are met:

There must be a system to ensure that such individual training plans are carried out as intended. Procedures will be needed to describe such mechanisms, as well as including a broader description of how the organization’s training strategy is structured. In addition to specific external courses or seminars, internal workshops and briefings are an acceptable vehicle for training. Internal environmental newsletters are also part of the range of tools available.

3. Verify that the training has achieved its purpose i.e. increased awareness:

This verification can be performed via feedback from training sessions: either a written report from the individual or a simple questionnaire to complete. Some organizations will ask personnel to undertake simple ‘tests’ to measure the effectiveness of the training. Other ways of verifying ‘awareness’ could be through the internal audit system. Asking questions of personnel during such audits will give an indication of their knowledge. One of the challenges can be the measurement of ‘continuous improvement’ within the training. Clearly, measurable targets can be set for delivering the training, i.e. records of attendance would show who has attended such sessions. However, how can an organization ‘measure’ whether the knowledge (awareness) of personnel has ‘improved’ compared with their knowledge of say, 12 months ago?

4. Verify that following training, the individual is competent at applying the awareness gained to their particular job:

This can be achieved by monitoring an individual’s work, noting any improvements in work, or, conversely, monitoring any persistent failure to absorb such training for example, by not being aware of the consequences of departure from a specific work instruction. Contractors, working on behalf of the organization, must also be subject to training requirements and this must be addressed in the training procedures. The employees of the contractor should have a certain level of training, that level to be determined by the organization. For both contractors and the organization itself, it must be kept in mind that the concept of significance must be applied to any training plans or program. The individual who is in an environmental front-line position – whose actions have the potential to cause a major impact on the environment – should have priority in environmental training followed by more intensive scrutiny of awareness and competence than the individual whose actions have little potential to impact on the environment. Further, if for example an individual is trained to operate a pH meter to check effluent pH, clearly both awareness and competence can be verified by giving the individual a sample of liquid of known pH and asking him to test it. If the results are correct it would tend to demonstrate that the training was successful.

A critical first step in developing your training program is assessing your training and skill needs. In assessing these needs, you should consider both general and specific aspects. For e.g., What EMS procedures affect Operator’s daily work, and what happens if they aren’t followed? What environmental impacts might Operator’s work cause? What broader understanding of environmental issues and our EMS does the Operator need? Look at the training you conduct already, for compliance with environmental and health and safety regulations and other purposes. You may find that your existing training efforts go a long way towards satisfying the requirements for the EMS. Because of the level of effort involved in a training program, this is one EMS area where you don’t want to start from scratch. Many employees may already be qualified on the basis of their experience and previous training. All training should be documented. Since some employees may require training on how to run a process safely, on-the-job training certainly plays a role. Plan and schedule training opportunities carefully.  While finding enough time for training can be a challenge, there may be creative ways to make “more time”. Use venues like safety meetings, staff meetings, and toolbox meetings to provide “training” and reinforce key messages. New employees can pose a significant training challenge. Consider developing an EMS training package for new employee orientation. Even better, videotape one of your current EMS training courses to show new employees. In reviewing training needs, don’t forget to consider the qualifications and training needs of your environmental manager and your trainers. Professional certification programs may be appropriate for certain functions.  Factor your EMS skills requirements into your recruiting, selection, and new employee orientation efforts. Establishing competency for various tasks can be a challenge. Competency criteria for jobs that can cause significant environmental impacts should be as objective as possible. Consider “job aids” to supplement training or help establish competence. Examples of job aids include written or pictorial job procedures, decision tables, or flow charts.

Key Steps in Developing a Training Program

Step 1: Assess training needs requirements
Step 2: Define training objectives
Step 3: Select suitable programs and methods
Step 4: Prepare training plan (who, what, when, where, how)
Step 5: Implement training program
Step 6: Track training (and maintain records)
Step 7: Evaluate training effectiveness
Step 8: Improve training program (as needed)

Evaluation of Training

ln order for your training program to be effective and improve your facility’s environmental performance,  you must periodically evaluate your EMS training. To get a true sense of how effective your training is, you should consider the evaluation of EMS training on several levels:

• Are the trainees happy with the training?
• Does the training teach the required skills or concepts?
• Are the skills and concepts used on the job?
• Does the application of the skills and concepts have positive effects?

The first two items can be evaluated through employee interviews, course or training evaluations, and testing employees‘ knowledge of the required activities as part of the training. The second two items are a little more difficult to evaluate. Evaluation of whether the skills and concepts are actually used on the job should be addressed as part of your EMS audit program. The audit of training will typically involve inspections and interviews to determine that the skills learned in training are actually applied. The effect of the training on your facility’s performance should be evaluated as part of your management review process. The ideal training is liked by trainees, is effective, provides the skills that are used on the job. and provides skills that have a positive impact on an organization‘s environmental performance.

7.3 Awareness

The organization must ensure that persons doing work under the organization’s control are aware of the environmental policy, the significant environmental aspects and related actual or potential environmental impacts associated with their work. They must be aware of their contribution to the effectiveness of the environmental management system, including the benefits of enhanced environmental performance and the implications of not conforming with the environmental management system requirements including not fulfilling the organization’s compliance obligations.

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

Awareness of the environmental policy should not be taken to mean that the commitments need to be memorized or that persons doing work under the organization’s control have a copy of the documented environmental policy. Rather, these persons should be aware of its existence, its purpose and their role in achieving the commitments, including how their work can affect the organization’s ability to fulfill its compliance obligations.

Explanation:

The intent of this Clause is to ensure that employees at all levels of the organization understand the Policy and principles of the EMS and the ways in which their job activities impact the environment and the achievement of EMS goals which obviously includes meeting compliance obligations. All personnel within the organization should have at least a basic understanding of the environmental issues associated with the organization’s operations, while personnel whose work may directly affect environmental performance should be trained and competent to complete their assigned tasks. Employees can only assist the organization in achieving its environmental objectives and improving environmental performance if there is adequate awareness and they possess the appropriate knowledge and skills. This leads to one of the central themes of IS0 14001: by informing employees of the impact that each facility operation has on the environment and their roles in the successful management of those impacts, improved environmental performance is inevitable. Employees who understand the consequences of their actions will individually make more environmentally friendly decisions. Employees must understand how to perform their responsibilities consistent with the EMS and understand how incorrect performance of their job activities will affect the environment.

Everyone in your organization must have a very basic awareness of the EMS. Therefore, all personnel at your facility should receive EMS awareness training. EMS awareness training includes basic training that addresses an organization’s EMS focusing on the environmental policy, the importance of conforming with EMS requirements, and general roles, responsibilities, and authorities within the EMS. The intent of this type of training is to ensure that all employees have a base level of understanding regarding the environmental issues associated with the organization’s operations and how these issues are being addressed. EMS awareness training should include:

• presentation of the environmental policy and general continual improvement, prevention of pollution, and compliance obligations ;
• presentation of the organization’s significant environmental aspects;
• discussion of the programs, practices, and procedures involved in the EMS; and
• identification of key personnel and departments involved with the EMS and their functions.

EMS awareness training is typically provided when the organization initially introduces its EMS and periodically thereafter. All new employees should be given EMS awareness training as part of their introduction to the organization. Because EMS awareness training involves all employees, it will likely involve the greatest number of people within an organization. The clause requires that the training results in employee awareness of:

• the importance of conforming with EMS requirements;
• significant environmental aspects associated with work activities within the organization;
• specific roles and responsibilities involved in the EMS; and
• potential consequences of not following established EMS procedures.

The goal of EMS awareness training is to ensure that employees:

• are aware that the organization has an environmental policy and is committed to the prevention of pollution, continual improvement, and compliance obligations;
• are aware that the organization has identified certain environmental aspects as targets for improvement (i.e. significant environmental aspects), and
• understand the goals and principles of the EMS and the ways in which their job activities impact the environment and the achievement of the established objectives.

ENVIRONMENTAL RISKS AND OPPORTUNITIES

ISO 14001:2015 Clause 6 Planning ensures the organization has the building blocks in place to determine that the EMS can achieve its intended outcome(s) through the inclusion of specific requirements around risk identification and analysis. This builds on and extends much existing practice related to ISO 14001:2004’s requirements about the identification and evaluation of aspects and impacts. However, even here, the extent of the required working practice changes depends on the nature and extent of existing evaluation techniques. The new ISO 14001 standard are grouped around five key areas: leadership, strategic context, interested party analysis and communication, risks and opportunities, and life cycle perspective. These changes are designed to increase corporate resilience and competitive advantage. Risk management is vital for every organization in every sector. It is intrinsic to compliance, reputation, growth, and profitability, and its proper handling within the health, safety, and environmental arena can be a major contributor to overall success. Now, organizations not only need to think about the impact they have on the environment and people, but also consider the impact that a changing environment, for example, climate change and resource scarcity, will have on them. In addition, organizations will need to consider other internal and external issues that can help or hinder them from having successful management systems. These could be related to the organization’s own internal systems and processes, for example, finance or procurement, or external factors such as government policy and incentives.  While on the one hand it can be considered more onerous, this broader approach will help organizations better pinpoint the success (or otherwise) of their management systems and their impact on the business as a whole.

ISO 14001:2015 identifies three possible sources that present risks and opportunities to the business 1) environmental aspects, 2) compliance obligations, and 3) issues and requirements from the context review. One of these is the new requirement that the organization determines the risks and opportunities that need to be addressed to give assurance that the environmental management system can achieve its intended outcomes so as to prevent, or reduce, undesired effects, including the potential for environmental external conditions to affect the organization; and achieve continual improvement. These are all laid out with the aim of ensuring the EMS can meet its intended expectations, reducing the risk of any external conditions affecting the EMS, and ensuring continual improvement is seen and that any emergency situations are assessed and action is taken to address them.

• Risks may turn into problems. We can reduce or avoid future problems by reducing their consequences or their probabilities. This can be done by changing the way we work to replace a high-risk activity with a low-risk activity and remove the risk if possible. Also, we can add remove the risk by adding risk avoidance activities to the way we work. It is defined by two parameters
  The consequences(C). What will happen if the risk becomes a problem?
  The probability( p). What is the probability that the risk will become a problem?
  The risk(R) is  R = C*p
• Opportunities may turn into benefits. We can increase future benefits by increasing their probabilities. This can be done by changing the way we work i.e replace a low opportunity activity with a high opportunity activity and adding opportunity enabling activities to the way we work. It is defined by two parameters
  The value(V). What will happen if the opportunity becomes a reality?
  The probability(p). What is the probability that the opportunity will be realized?
  The opportunity(O) is  O = V*p
• Both risk and opportunity are defined by probability. Experience and data are important for two reasons. They can be used to estimate values and probabilities. They serve as an anchor for assessment – e.g. “How bad can it get?”. Remember the “opportunity” element and give it due importance. Every risk presents an opportunity to improve and, in effect, if you can mitigate risk before it turns into an incident, then you will guarantee continual improvement for the EMS.
• Examples of possible risks could be the threat of increasing energy prices due to carbon taxation, making a company uncompetitive – or an organization being noncompliant with legislation which could lead to a loss of custom due to negative publicity. A risk to the success of the management system could be presented from an organization’s own financial processes that do not allow easy investment in emerging technologies.
• Examples of an opportunity might be an organization capitalizing on energy efficiency measures which cut production costs, leading to an increase in competitiveness – or positive publicity surrounding environmental initiatives which result in new customers. Stakeholder perceptions, financial impact or potential prosecution are all vital and the best systems truly get to the heart of what the business is and what it needs.
• The standard now requires that documented information shall be kept of the risks and opportunities and the processes required to ensure that the process meets expectations; therefore, it may be good practice to create a formal Risk Register within the EMS where identification, discussion, actions, outcome, and monitoring can all be listed and results clearly evaluated.
• Ensure there is both leadership commitment and employee involvement. Both parties may well have unique views of what constitutes environmental risk within the business, to ensure both are sought and considered and that the communication channel up and down exists.
• Consider establishing a “risk and opportunity” forum or monthly meeting. Given that businesses change swiftly, it is important that focus is kept on the environmental risk and the resulting action required to mitigate that risk. Document the outcome as suggested above.
• Ensure your monitoring, measuring, analysis, and evaluation are accurate and frequent. This process forms the basis for assigning values to the effectiveness of your risk and opportunity process and can provide you with the foundation for improving future performance.

“Risks and opportunities” is defined in ISO 14001:2015  as potential adverse effects (threats) and potential beneficial effects (opportunities). The rationale behind this definition is to have organizations primarily focus their attention on the results related to risk determinations, including both positive and negative effects, rather than simply the uncertainty related to the occurrence of events. The key thing to remember about these new requirements is that not every risk (that is, threat) and opportunity an organization faces is required to be included in this risk determination. First, there must be a nexus, or connection, to the environmental management system. For example, hazardous waste disposal risks would have a nexus to the EMS; credit card fraud risks would not. According to ISO 14001, the organization needs to consider the relationship a particular risk has to:

• the organization’s important environmental issues that are its “context”.
• the organization’s EMS requirements, including its compliance obligations
• the defined scope of the organization’s environmental management system.

This determination of risk (threats and opportunities) is intended to be subjective. It is to be based on the opinions, interpretations, and judgment of those within the organization. It does not have to be an objective determination. It does not have to be based on numbers, calculations, or spreadsheets—although it can be if an organization so chooses. The determination of which risks and opportunities will be addressed in the EMS is the organization’s decision. It is not required to be based on what any particular interested party or management system auditor thinks the decision should be.

Planning process

The “Planning” clause has two sub-clauses i.e.

• Clause 6.1 Actions to address risks and opportunities
  • 6.1.1 General
  • 6.1.2. Environmental aspects
  • 6.1.3 Compliance obligations
  • 6.1.4 Planning action
• Clause 6.2 Environment Objectives and Planning to Achieve Them
  • 6.2.1 Environmental objectives
  • 6.2.2 Planning actions to achieve environmental objectives

6.1 Actions to address risks and opportunities 

6.1.1 General 

The organization should establish, implement and maintain the processes needed to meet the requirements of Clause 6.1 (Actions to address risks and opportunities). When planning for the environmental management system, the organization shall consider issues referred to in Understanding the organization and its context (4.1), the requirements referred to in Understanding the needs and expectations of interested parties(4.2), and the scope of its environmental management system; The organization should also determine the risks and opportunities, related to its environmental aspects, compliance obligations, and other issues and requirements, issues referred to in Understanding the organization and its context (4.1), the requirements referred to in Understanding the needs and expectations of interested parties(4.2) so as to assure that the environmental management system can achieve its intended outcomes; It can prevent or reduce undesired effects, including the potential for external environmental conditions to affect the organization and achieve continual improvement.  Within the scope of the environmental management system, the organization shall determine potential emergency situations, including those that can have an environmental impact. The organization should maintain documented information about its risks and opportunities that need to be addressed. Documented information is also to be maintained to the extent necessary to have confidence that the process has 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 overall intent of the processes established in 6.1.1 is to ensure that the organization is able to achieve the intended outcomes of its environmental management system, to prevent or reduce undesired effects, and to achieve continual improvement. The organization can ensure this by determining its risks and opportunities that need to be addressed and planning action to address them These risks and opportunities can be related to environmental aspects, compliance obligations, other issues, or other needs and expectations of interested parties. Environmental aspects can create risks and opportunities associated with adverse environmental impacts, beneficial environmental impacts, and other effects on the organization. The risks and opportunities related to environmental aspects can be determined as part of the significance evaluation or determined separately. Compliance obligations can create risks and opportunities, such as failing to comply (which can damage the organization’s reputation or result in legal action) or performing beyond its compliance obligations (which can enhance the organization’s reputation). The organization can also have risks and opportunities related to other issues, including environmental conditions or needs and expectations of interested parties, which can affect the organization’s ability to achieve the intended outcomes of its environmental management system, e.g.
a) environmental spillage due to literacy or language barriers among workers who cannot understand local work procedures;
b) increased flooding due to climate change that could affect the organization’s premises;
c) lack of available resources to maintain an effective environmental management system due to economic constraints;
d) introducing new technology financed by governmental grants, which could improve air quality:
e) water scarcity during periods of drought that could affect the organization’s ability to operate its emission control equipment.
Emergency situations are unplanned or unexpected events that need the urgent application of specific competencies, resources, or processes to prevent or mitigate their actual or potential consequences. Emergency situations can result in adverse environmental impacts or other effects on the organization. when determining potential emergency situations (e.g. fire, chemical spill, severe weather), the organization should consider:

• the nature of onsite hazards (e.g. flammable liquids, storage tanks, compressed gasses);
• the most likely type and scale of an emergency situation;
• the potential for emergency situations at a nearby facility (e.g. plant, road, railway line).

Although risks and opportunities need to be determined and addressed, there is no requirement for formal risk management or a documented risk management process. it is up to the organization to select the method it will use to determine, its. risks and opportunities. The method may involve a simple qualitative process or a full quantitative assessment depending on the context in which the organization operates. The risks and opportunities identified are inputs for planning actions and for establishing the environmental objectives.

Explanation:

To conform to the ISO 14001 standard, an organization simply needs to be able to show that it considered the nexus factors listed above when it made its EMS risk determinations.  Just as the determination of the organization’s context, its aspects, and its compliance obligations are inputs into its determination of risks and opportunities, the determination of risks and opportunities is input into other EMS processes. The requirements in clause 6.1.1 are expressly linked to the additional planning requirements in clause 6.1.4. The planning requirements are then linked to operational control requirements in clause 8.1. Taken together, these clauses require the organization to plan and then take action to address the risks and opportunities that have been identified. In other words, clause 6.1.1 requires a risk determination; clause 6.1.4 requires the development of risk action plans, and clause 8.1 requires that these risk action plans be implemented. ISO 14001:2015 also requires that organizations check whether the management system processes they have established to address risk are effective. Clause 6.1.4 requires the organization to plan how it will evaluate the effectiveness of the actions taken to address risk. Clause 8.1 requires the organization to establish operating criteria for its risk control processes. Clause 9.1.1 requires the organization to monitor, measure, analyze, and evaluate its environmental performance. In summary, the plan-do-check-act (PDCA) focuses on addressing significant aspects that were embedded in ISO 14001:2004 now apply to environmental risks and opportunities as well. Assessing risk and opportunity within an EMS is of crucial importance, with prevention being better than cure in environmental terms, where there is often no way of repairing the damage an incident does after the occurrence. Having a team that is focused on risk and prevention can go a long way towards mitigating environmental risk, but only supported by the correct processes within the EMS. Ensure compliance terms are always met and a great portion of risk will be reduced. Ensure that all risk assessments are recorded, actioned, measured, and improvement action is taken. Make risk and opportunity a staple of the mindset of the team. A team that is focused on risk and opportunity is a team that can preside over continual improvement, and that result will be of benefit to your organization and the EMS.

It’s tempting to want to capitalize on or mitigate all possible opportunities and risks identified, but by doing so the most important will lack the attention they require – a risk assessment process is therefore required. Under ISO 14001: 2015, organizations are free to choose the process used to assess the risks and opportunities that need to be addressed. The standard just requires that there is an approach in place to address risks and opportunities in order to ensure a successful EMS and that the intended outcomes of the EMS are achieved – with unintended effects either avoided or reduced.

6.1.2. Environmental aspects

Within the defined scope of the environmental management system, the organization should determine the environmental aspects and their associated environmental impact of its activities, products, and services that it can control and also those that it can influence.  While determining environmental aspects and their associated environmental impact the organization must take into consideration a life cycle perspective.
When determining environmental aspects, the organization should take into account:
a) change, including planned or new developments. and new or modified activities, products, and services;
b) abnormal conditions and reasonably foreseeable emergency situations.
The organization should determine those aspects that have or can have a significant environmental impact, i.e. significant environmental aspects. by using established criteria. The organization shall communicate its significant environmental aspects among the various level and functions of the organization. as appropriate. The organization should maintain documented information on its environmental aspects and associated environmental impacts. The organization also should maintain documented information of the criteria used to determine its significant environmental aspects and significant environmental aspects. Significant environmental aspects can result in risks and opportunities associated with either adverse environmental impacts (threats) or beneficial environmental impacts (opportunities).

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

An organization determines its environmental aspects and associated environmental impacts and determines those that are significant and, therefore, need to be addressed by its environmental management system. Changes to the environment, either adverse or beneficial, that result wholly or partially from environmental aspects are called environmental impacts. The environmental impact can occur at local, regional and global scales, and also can be direct, indirect, or cumulative by nature. The relationship between environmental aspects and environmental impacts is one of cause and effect. When determining environmental aspects, the organization considers a life cycle perspective. This does not require a detailed life cycle assessment: thinking carefully about the life cycle stages that can be controlled or influenced by the organization is sufficient. Typical stages of a product (or service) life cycle include raw material acquisition, design. production, transportation/delivery, use, end-of-life treatment, and final disposal. The life cycle stages that are applicable will vary depending on the activity, product, or service.
An organization needs to determine the environmental aspects within the scope of its environmental management system. it takes into account the inputs and outputs (both intended and unintended) that are associated with its current and relevant past activities, products, and services; planned or new developments; and new or modified activities, products, and services. The method used should consider normal and abnormal operating conditions, shutdown and start-up conditions. as well as the reasonably foreseeable emergency situations identified in 6.1.1. Attention should be paid to prior occurrences of emergency situations.  An organization does not have to consider each product, component, or raw material individually to determine and evaluate their environmental aspects; it may group or categorize activities, products, and services when they have common characteristics. When determining its environmental aspects, the organization can consider: 

• emissions to air
• releases to water
• releases to land
• use of raw materials and natural resources
• use of energy
•  the energy emitted e.g. heat, radiation, vibration (noise), light),
• generation of waste and/or by-products;
• use of space.

In addition to the environmental aspects that it can control directly, an organization determines whether there are environmental aspects that it can influence. These can be related to products and services used by the organization which is provided by others, as well as products and services used by the organization which are provided by others, including those associated with outsourced processes. With respect to what the organization provides to others, it can have limited influence on the use and end-of-life treatment of the products and services. in all circumstances, However, it is the organization that determines the extent of control it is able to exercise, the environmental aspects it can influence, and the extent to which it chooses to exercise such influence. Consideration should be given to environmental aspects. related to the organization’s activities, products, and services, such as:

• design and development of its facilities, processes, products, and services,
• acquisition of raw materials, including extraction
• operational or manufacturing processes, including warehousing
• operation and maintenance of facilities, organizational assets, and infrastructure
• environmental performance and practices of external providers,
• product transportation and service delivery, including packaging,
• storage, use and end-of-life treatment of products;
• waste management, including reuse, refurbishing, recycling, and disposal.

There is no single method for determining significant environmental aspects, however, the method and criteria used should provide consistent results. The organization sets the criteria for determining its significant environmental aspects. Environmental criteria are the primary and minimum criteria for assessing environmental aspects. Criteria can relate to the environmental aspect (e.g. type, size, frequency, etc) or the environmental impact (e.g. scale, severity, duration, exposure). Other criteria may also be used. An environmental aspect might not be significant when only considering environmental criteria. It can, however, reach or exceed the threshold for determining significance when other criteria are considered. These other criteria can include organizational issues, such as legal requirements or interested party concerns. These other criteria are not intended to be used to downgrade an aspect that is significantly based on its environmental impact. A significant environmental aspect can result in one or more significant environmental impacts, and can, therefore, result in risks and opportunities that need to be addressed to ensure the organization can achieve the intended outcomes of its environmental management system.

Explanation:

Identification and evaluation of significant environmental aspects, especially in the planning phase, is the most fundamental part of ISO 14001. Understanding the environmental aspects and impacts is one of the key success factors of implementing an ISO 14001 EMS. In the language of ISO 14001, “an environmental aspect is an element of an organization’s activities, products, or services that has or may have an impact on the environment.”An environmental aspect is a way your activity, service, or product impacts the environment. The activity can be defined as “A Task or Operation general occurring within the Organization. Environment impact can be defined as “Any change to the  environment, whether adverse or beneficial, wholly or partially resulting from an  organization’s activities,  products, or services.” An environmental impact is a change in the environment. Environmental impacts are caused by environmental aspects. In the following steps, you will find a basic, systematic approach to identifying, evaluating, and managing environmental aspects.

1.Definition of the EMS scope

Before you start dealing with environmental aspects and impacts, you should first define the scope of the EMS. You can choose to apply ISO 14001 to the entire organization, or only to a specific unit, location, or product. Once you have made this decision you have defined the EMS scope. Henceforth, all activities, services, and products that fall within your defined scope have to be taken into consideration when you identify environmental aspects and impacts.

2. Identification of environmental aspects

First, let’s explain the terms activity, service, and product. An activity is a part of the core business (e.g., production process steps). Service means an auxiliary service that supports core activities (e.g., boilers, heating & cooling, maintenance). A product is the goods you offer for the market. An environmental aspect of the product could be, e.g., excessive packaging of the product, or the level of recyclability of the product at the end of its lifecycle. As ISO 14001 states, “The organization shall establish a procedure to identify environmental aspects and determine those aspects that have or can have a significant impact on the environment.” You should also keep a register of the environmental aspects, which is kept up to date and takes into account planned new or modified activities, products, or services. Aspects can be divided into direct and indirect. Direct environmental aspects are associated with activities, products, and services of the organization itself, over which it has direct management control (e.g., how you manage waste on your site). However, for non-industrial organizations, the focus will often be on indirect environmental aspects of their activities (e.g., how your subcontractor manages waste on your site, chain controlled aspects, customer-controlled aspects). In order to identify the environmental aspects, you need to study how your organization’s activities, products, and services affect the environment. The identification of environmental aspects often considers, e.g., emissions to air, releases to water and land, use of raw material, waste, and natural resources, impacts on biodiversity, etc. When identifying environmental aspects, all parts of the company’s operations in the defined scope have to be considered, not just the obvious core manufacturing or service activities. For example, most facilities have a maintenance department, offices, a canteen, heating and cooling systems, vehicle parking, and contractor and supplier activities – each of which may have an impact on the environment. Various techniques can be used to compile a comprehensive listing of environmental aspects and impacts at a facility – e.g., Value chain method, Process flow method, materials identification, method of compliance with legal requirements, etc. A good practice is to involve a cross-functional team from key areas of the operation. For each type of activity, product, or service, you need to list your unique environmental aspect – this will result in an overall list or matrix of aspects and impacts.

3. Evaluation of significant environmental aspects

The purpose of the evaluation of environmental aspects is to focus on what matters the most (e.g., 20-80 rule). You do not need to manage all environmental aspects – only the ones that are, according to your own criteria, declared significant. Significant environmental aspects are the main focus of your organization’s environmental management system. Depending on the type, nature, and complexity of an organization, there are many techniques available for conducting an evaluation to determine the significance of environmental aspects. In assessing the significance you should consider the potential to cause environmental harm, importance to the stakeholders of the organization, requirements of relevant environmental legislation, size, and frequency of the aspect. Each organization must establish its own criteria for significance based on a systematic review of its environmental aspects and their actual and potential impacts.

4. Managing significant environmental aspects

Every significant aspect should be brought under control by establishing one or more of the following controls:  responsible person, training plan, or procedure, checklist, and/or maintenance schedule. The level of control should be appropriate to the nature and risk of the significant aspect.  Each of the above is a part of the everyday work routine. An EMS can often be more complicated than needed. The key to any effective EMS is getting the environmental aspects right at the very beginning.  Identifying the environmental aspects properly will not only save you time but also enable you to achieve great benefits with your EMS once it is implemented.

Example of Relation between Activity, aspects, and Impact

To plan for and control its significant environmental impacts, an organization must first know what these impacts are. But knowing what the impacts are is only part of the challenge, you also should know where these impacts come from. The identification and management of environmental aspects can (1) have positive impacts on the bottom line and (2) provide significant environmental improvements. The relationship between aspects and impacts is one of cause and effect. The term “aspects” is neutral, so keep in mind that your environmental aspects could be either positive such as making a product out of recycled materials or negative such as discharge of toxic materials to a stream. Your organization is not expected to manage issues outside its sphere of influence. For example, while your organization probably has control over how much electricity it uses, it likely does not control the way in which the electricity is generated. Once you have identified the environmental aspects of your products, activities, and services, you should determine which aspects could have significant impacts on the environment. These environmental aspects should be considered when you set your environmental objectives and define your operational controls.

In identifying aspects and impacts, you should look at activities including activities controlled by applicable laws and regulations. But because many of your aspects/impacts may be addressed by legal requirements, your compliance program might yield some valuable information. Permits, audit reports, and other such documents can serve as useful inputs. Beyond regulations, look at issues such as land, energy, and other natural resource use. Once you have identified environmental aspects and related significant impacts, use this information in setting your objectives and targets. This does not mean that you need to address all of your impacts at once. There may be good reasons such as cost, availability of technology, and scientific uncertainty for addressing some impacts now and deferring action on others. Keep in mind that managing environmental aspects could have positive business impacts.  Remember to look at services as well as products.  While the need to examine your on-site operations might be obvious, you should also consider the potential impacts of what you do off-site such as servicing equipment at customer sites. Similarly, the environmental aspects of the products, vendors, and contractors you use may be less obvious, but should still be considered. Identifying significant environmental aspects is one of the most critical elements of the EMS and can be one of the most challenging. Decisions you make in this task can affect many other system elements such as setting objectives and targets, establishing operational controls, and defining monitoring needs. Careful planning and conduct of this activity will pay dividends in later steps.

Understanding your environmental aspects helps to understand the processes by which you generate products and services. A flow chart of your major processes might help you understand the inputs and outputs of your processes and how materials are used. You may also want to consider the views of interested parties — some organizations have found external parties to be a good resource to help you identify your organization’s environmental aspects. There are many readily-available sources of information to help you perform your assessment. For starters, look at your permits, various regulations that apply to your operations, audit reports, and monitoring records. Trade associations, regulatory agencies, your customers, and suppliers also might provide useful information to support your assessment.

Things to Consider in Evaluating Environmental Aspects:

• Air Emissions
• Water Effluents
• Solid and Hazardous Wastes
• Land Use
• Contamination of Land Raw Material
• Resource Use
• Local Issues Normal and Abnormal Conditions such as noise, odor, dust, traffic, appearance, etc.

6.1.3 Compliance obligations

Compliance obligation is a separate article, For more on Compliance obligations click here

6.1.4 Planning action

The organization should plan to take action to address its significant environmental aspects, compliance obligations, and its identified risks and opportunities. The organization must integrate and implement the actions into its environmental management system processes, or other business processes. The organization evaluates the effectiveness of these actions. While planning these actions, the organization shall consider its technological options and its financials, operational, and business requirements. 

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

“The organization plans, at a high level, the actions that have to be taken within the environmental management system to address its significant environmental aspects, its compliance obligations, and its identified risks and opportunities identified that are a priority for the organization to achieve the intended outcomes of its environmental management system. The actions planned may include establishing environmental objectives (see 6.2) or may be incorporated into other environmental management system processes, either individually or in combination. Some actions may be addressed through other management systems, such as those related to occupational health and safety or business continuity, or through other business processes related to risk, financial, or human resource management. When considering its technological options, an organization should consider the use of the best available techniques, where economically viable, cost-effective and judged appropriate. This is not intended to imply that organizations are obliged to use environmental cost-accounting methodologies.”

HOW TO IDENTIFY AND EVALUATE RISKS AND OPPORTUNITIES

Approach to evaluate risk and opportunities:

Option 1: Single path Approach

This process begins by identifying the context of the organization, taking into account environmental conditions and issues (4.1), and needs and expectation of interested parties (4.2) according to the scope of the Environmental Management System (4.3). After this step, the criteria are applied to assess risks and opportunities associated with environmental aspects by considering the likelihood and severity of impacts, environmental conditions and issues, and requirements of interested parties. The results of the risks and opportunities assessments are significant environmental aspects that can be addressed by the organization through actions such as setting an objective and environmental improvement program, operational control, emergency plan or other plans as appropriate.

Option 2: Dual Aspect Approach

After applying the same process of addressing the context of the organization, option 2 uses the criteria to assess “organizational” aspects (aspects of environment interacting with the organization) and environmental aspects (aspects of organization interacting with the environment). From both these processes, a list of significant organizational aspects and significant environmental aspects will be created. From the identified significant “organizational” aspects and environmental aspects, the next process is to assess risks and opportunities that need to be addressed that are relevant to the EMS. These risks and opportunities are then followed up by the organization through actions such as setting an objective and environmental improvement program, operational control, emergency plan or other plans as appropriate as in option 1.

Option 3: Parallel process Approach

Option 3 utilizes information on business risks and opportunities identified through an enterprise risk management system/process. Depending on the organization this process may or may not exist. Business risks and opportunities relevant to EMS are then compiled with significant environmental aspects generated from the process similar to option 1 to determine actions that need to be planned by the organization in the EMS such as setting an objective and environmental improvement program, operational control, emergency plan or other plans as appropriate.

Example: A family-owned company, manufacturing wooden outbuildings for domestic and commercial use. The organization’s purpose is to provide both retail and bespoke sectional buildings to individuals and organizations. (same example as taken previously from Clause 4.1 Understanding the Organization and its context )

1. Risk /Opportunities for internal Issues

2. Risk /Opportunities for External Issues

3. Risk /Opportunities for Compliance obligations

4. Risk /Opportunities for Significant Aspect

6.2 Environmental objectives and planning to achieve them

6.2.1 Environmental objectives

The organization should establish environmental objectives at relevant functions and levels, taking into account the organization’s significant environmental aspects and associated compliance obligations and considering its risks and opportunities. The environmental objectives should be consistent with the environmental policy, measurable (if practicable), and monitored. The environmental objectives should be communicated and updated as appropriate. The organization should maintain documented information on environmental objectives.

6.2.2 Planning actions to achieve environmental objectives

When planning how to achieve its environmental objectives, the organization should determine what will be done, what resources will be required,  who will be responsible, when it will be completed and how the results will be evaluated, including indicators for monitoring progress toward achievement of its measurable environmental objectives. The organization should consider how actions to achieve its environmental objectives can be integrated into the organization’s business processes.

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

Top management may establish environmental objectives at the strategic level, the tactical level, or the operational level. The strategic level includes the highest levels of the organization and the environmental objectives can be applicable to the whole organization. The tactical and operational levels can include environmental objectives for specific units or functions within the organization and should be compatible with its strategic direction. Environmental objectives should be communicated to persons working under the organization’s control who have the ability to influence the achievement of environmental objectives. The requirement to “take into account significant environmental aspects” does not mean that an environmental objective has to be established for each significant environmental aspect, however, these have a high priority when establishing environmental objectives. “Consistent with the environmental policy” means that the environmental objectives are broadly aligned and harmonized with the commitments made by top management in the environmental policy, including the commitment to continual improvement.
Indicators are selected to evaluate the achievement of measurable environmental objectives. “Measurable” means it is possible to use either quantitative or qualitative methods in relation to a specified scale to determine if the environmental objective has been achieved. By specifying “if practicable”, it is acknowledged that there can be situations when it is not feasible to measure an environmental objective, however, it is important that the organization is able to determine whether or not an environmental objective has been achieved.

Explanation:

The Standard requires that the organization shall establish and maintain documented environmental objectives at each relevant function and level within the organization. Objectives help you translate purpose into action — they should be factored into your strategic plan and can facilitate the integration of environmental management with other business management processes. Objectives should be the longer-term goals derived naturally from the environmental policy. It should be understood that each identified significant aspect will have an associated objective or objectives in some cases. Quantification can take place through measurement in order to meet such goals. You determine what objectives and targets are appropriate for your organization. These goals can be organization-wide or applied to individual units or activities. Of course, all objectives should be realistic. Objectives should be related to significant environmental impacts and can be couched in fairly broad terms i.e. to reduce energy use. Each objective should have a measurable target to demonstrate that the objective is being attained. Targets are more specific, more easily measurable detailed performance requirements that evolve from the objectives and allow an organization to verify whether the stated objectives will be achieved. Early warning mechanisms for targets not being met should be in place. The process of regular reviews and audits should address this adequately. In setting objectives to consider your environmental policy, significant environmental aspects, from its compliance obligations including applicable legal and other requirements, the views of interested parties, your technological options, and financial, operational, and other business requirements. There are no “standard” environmental objectives that fit all organizations. Your objectives should reflect what your organization does and what it wants to achieve.

Objectives should be set by the people in the functional area involved — they will be best positioned to establish, plan for, and achieve these goals. Involving people in the area will help to build commitment. Objectives should be consistent with your overall business mission and plan and the key commitments established in your policy (pollution prevention, continual improvement, and compliance). Be flexible in your objectives. Define the desired result and let the people responsible determine how to achieve the result. Keep your objectives simple initially, gain some early successes, and then build on them. Communicate objectives (as well as your progress in achieving them) across the organization. Consider a regular report on progress at staff meetings. To obtain the views of interested parties, consider holding an open house or establishing a focus group with people in the community. These activities can have other payoffs as well. Make sure your objectives and targets are realistic. Determine how you will measure progress towards achieving them. Keep in mind that your supplier’s service or materials) can help you in meeting your objectives and targets (e.g., by providing more environmentally friendly products).

Setting of Objectives

Some objectives will be dictated by the requirements of its compliance obligations and therefore are set from outside of the organization. That apart if an organization has identified that solid waste to landfill is a significant impact, what should be the target to aim for to reduce this amount of waste? First and foremost, quantification of what is actually sent to the landfill needs to be obtained. As stated above this could probably be obtained from weighbridge tickets, waste transfer notes, and other records. If, from these records, it is discovered that in the previous year 100 tonnes were sent to landfill, how does the organization derive a meaningful figure for reduction? Is a 1%, 10%, or 50% reduction a reasonable figure? Upon examination of these options, an improvement of 1% is meaningless as far as environmental significance is concerned. It will probably be difficult to measure this ‘amount’ with confidence. There is also the fact that the costs of the controls for this small reduction may outweigh any financial considerations – always an issue in any organization. The improvement of 50% would appear at first glance to be commendable and worthy of environmental attention, however, on closer examination, it is probably somewhat unrealistic.  Thus 10% appears to be a starting point and an achievable target – with measurable associated cost savings. If, as the system matures, this proves to be too difficult, then it could be adjusted to 8% or 9% as appropriate. Obviously, only running a production line at 50% capacity, due to poor customer demand, will reduce waste by a roughly corresponding amount. Unless this is taken into consideration in the calculations, errors in the figures will occur.

Some Examples of Objectives

• Reduce electricity use by 10%   Target date  March 2016
• Reduce natural gas use by 10%  Target date March 2015
• Eliminate the use of CFC’s by March 2015
• Reduce use of high-VOC paints by 25% in 2015
• Reduce chrome wastes in the plating area by 50% in 2015
• Zero permit limit violations by March 2015
• Train 100% of employees to improve employee awareness of environmental issues by end of year

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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.

5.1 Leadership and commitment

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.

Explanation:

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.

5.2 Environmental policy

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.”

Explanation:

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.

Sample environmental policy.

5.3 Organizational roles, responsibilities and authorities

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.”

Explanation:

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:

1. ensures that the EMS is established and implemented
2. reports on its performance over time; and
3. 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?

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.

One of the most significant changes to the 2015 standard is the introduction of an entirely new clause in the context of the organization. Context of the Organization makes it a formal requirement for organizations to consider:

• Your direct environmental impacts
• How environmental conditions can affect your business, customers and supply chain.
• External social and economic factors (e.g. beliefs and norms of society and its expectation of the organization, environmental performance of peers and competitors) and
• Internal capabilities (e.g. the organization’s ability to implement new technologies and influence behavior changes in its employees).

This significantly increases the planning work you need to do to maintain your ISO 14001 certification but the enhanced approach gives you a much better view of the risks and opportunities for your organization and will help develop a more robust corporate strategy. Past revisions of ISO 14001 required organizations to define the scope—the activities, processes, and buildings, and property within their EMS. The organization’s environmental policy included commitments to comply with applicable environmental regulations, reduce pollution, and continually improve its environmental performance. Context of the Organization is the first auditable part of ISO 14001:2015 and may be audited toward the beginning of the EMS audit. The auditor will be looking for and documenting high-level issues and available documentation that demonstrates the effective implementation of an organization’s EMS system.

Context of the Organization

One of the objectives of ISO 14001:2015 is the pulling together of an organization’s environmental internal issues, external issues, and interested parties that make up the firm’s business environment or the Context of the Organization. In the past, top management was never required to define the firm’s business environment as it related to internal and external issues or any interested parties. Internal issues might be air quality, waste hauling, and its costs. External issues might include customers and legal requirements. Interested parties could be the organization’s adjoining neighbors, and various local, state, federal environmental agencies. Customers also are interested parties as a result of their requirements for certain chemical use and other materials. Through the identification of the Context of the Organization, top management can focus on being more environmentally friendly and ensure that the organization remains in compliance with all regulations. Top management’s focus does not require documentation; however, most organizations will document the internal and external issues plus interested parties in the environment. It is also aimed at defining the EMS scope as it relates to the business operation. This scope could include additional items to the organization’s boundaries. An example might be air quality issues in the surrounding area of the facility, if important. This clause also defines in general terms an organization’s EMS system. This would include necessary processes for the organization to be successful. Some processes will be documented and others undocumented. Properly identifying the Context of the Organization will assist in the building of a complete EMS system that meets top management’s needs. While many ISO 14001-certified organizations included initiatives such as replacement of toxic materials, recycling activities, and reduction of fossil fuel use, the majority of the environmental programs fostered by certified organizations were “reactive” in nature. The new clauses of ISO 14001:2015, Understanding the organization and its context and Understanding the needs and expectations of interested parties, challenge organizations to analyze their operations and environmental impact from a more holistic, proactive vantage point.

With regard to the context of the organization, depending on the organization’s business model and environmental impact, there may be opportunities to have programs with a positive, proactive impact: air emissions related to climate change, improvement in soil quality of adjacent land or neighboring waterways, and supporting biodiversity (local flora-fauna) initiatives. The organization should be able to explain, within the context of its operations, what opportunities exist. A company producing machined parts or electronic components may have limited options; a large chemical plant, oil refinery, or paper mill may have many opportunities. In a similar fashion, in response to the expectations of interested parties, the organization should analyze how its activities and products may have an environmental impact on its customers, community, and neighbors. Examples could be end-of-life product disposal, voluntary labeling on products, reduction of unregulated materials, sustainable resources, and commitments to maintain adjacent community land or waterways. A key focus of ISO 14001:2015 is “life-cycle thinking,” considering each stage of a product or service, from development to end of life. Organizations producing consumer products may have many opportunities (but also challenges) to have an impact on product disposal, while manufacturers of components for sale to the industry may be limited in this regard. Organizations providing components for sale to the industry can demonstrate their commitment to life-cycle thinking by reducing or eliminating the use of environmentally challenged materials and maximizing recycle initiatives. Consumer product manufacturers can support life-cycle thinking by moving to “zero- landfill” disposal via waste-to-energy disposal options (waste is burned to produce electricity). ISO 14001:2015 requires organizations to put a policy in place that promotes environmental protection specific to the context of their business. Previous versions of ISO 14001 placed environmental protection in a somewhat reactive mode, where proactive initiatives included recycle programs and pollution prevention directly related to the organization’s manufacturing processes. With ISO 14001:2015, the organization is required to understand the important issues that can affect, either positively or negatively, the way it manages its environmental responsibilities. Examples include:

• Reduction of air emissions related to climate change
• Use of sustainable resources
• improvements in soil quality of adjacent land or neighboring waterways
• Support of biodiversity (local flora-fauna) initiatives

In addition to understanding the context of the organization, ISO 1400l:2015 requires the organization to understand the needs and expectations of interested parties The organization needs to review who are the interested parties related to its environmental compliance obligations: customers, neighbors, and community. The organization can then consider establishing voluntary compliance requirements that could impact the environment. Once it “volunteers,” the organization needs to live up to that commitment. Examples include life-cycle considerations related to product disposal, voluntary labeling on products, and environmental commitments to reduce unregulated materials (e.g., Styrofoam) or to maintain adjacent community land or waterways. The context of the organization and expectations of interested parties will be more applicable to large, multi-site organizations with transportation-related air releases- environmental impact or consumer products implication. Many organizations under ISO 14001:2004 considered greenhouse gases and climate change as part of their commitment to the prevention of pollution. External factors such as legacy issues (e.g., prior site ownership soil or water contamination responsibility) should always be part of the organization’s responsibility to ensure environmental controls are in place. At a minimum, the organization needs to present documented evidence that the context of the organization and expectations of interested parties were considered when establishing its EMS.

The “Context of Organization” clause has four sub-clauses ie

Clause 4.1 Understanding the Organization and its context
Clause 4.2 Understanding the needs and expectations of interested parties
Clause 4.3 Determining the scope of the environmental management  system
Clause 4.4 Environmental management system

Clause 4.1 Understanding the Organization and its context

The organization should determine external and internal issues that are relevant to its purpose and affects its ability to achieve the intended outcomes of its environmental management system. Such issues should include environmental conditions which are affected by or have capable of affecting the organization.

• Here determine means to find out or establish.

• The purpose of the organization can be expressed through statements such as an organization ‟s vision, mission, policies, and improvement objectives.
• The term “intended outcome” means what the organization intends to achieve by implementing its EMS, which includes at a minimum the:
  • enhancement of environmental performance,
  • conformance to compliance obligations,
  • fulfillment of environmental objectives, and
  • protection of the environment
• An environmental condition can be defined as the “state or characteristic of the environment as determined at a certain point.” Environmental conditions can include: the climatic, air quality, water quality, and availability, and land use characteristics of a site, existing levels of contamination, pollution and environmental degradation, natural resource availability, and biodiversity, that can either affect the organization or be affected by the organization.
• Issues are those internal or external characteristics that can either positively or negatively affect the way the organization manages its environmental responsibilities and the ability of the organization to achieve the intended outcomes of the EMS.
• External issues can amongst others include local, regional and global environmental conditions, the views or positions of interested parties, or external cultural, social, political, legal, regulatory, financial, technological, and economic factors.
• Internal issues can amongst others include the level of management commitment and support, the competitive context and the availability of resources, including knowledge, organizational processes, and systems, and the nature of the organization’s activities, products and services, its strategic direction, and corporate culture.

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

“The intent here is to provide a high-level, conceptual understanding of the important issues that can affect, either positively or negatively, the way the organization manages its environmental responsibilities. issues are important topics for the organization, problems for debate and discussion, or changing circumstances that affect the organization’s ability to achieve the intended outcomes it sets for its environmental management system.
Examples of internal and external issues which can be relevant to the context of the organization include:
a) environmental conditions related to climate, air quality, water quality, land use, existing contamination, natural resource availability and biodiversity, that can either affect the organization’s purpose or be affected by its environmental aspects;
b) the external cultural, social, political, legal, regulatory, financial, technological, economic, natural, and competitive circumstances, whether international, national, regional, or local;
c) the internal characteristics or conditions of the organization, such as its activities, products, and services, strategic direction, culture, and capabilities (i.e. people, knowledge, processes, systems).
An understanding of the context of an organization is used to establish, implement, maintain and continually improve its environmental management system. The internal and external issues that are determined can result in risks and opportunities to the organization or to the environmental management system. The organization determines those that need to be addressed and managed.”

Clause 4, the “Context of the Organisation” requires:

1. a high-level and conceptual understanding of the context of the organization,
2. an understanding of the needs and expectations of interested parties and
3. the determination of the scope of the EMS.

Clause 4.1, “Understanding the Organization and its context” calls for the determination of internal and external issues:

• That is relevant to the purpose of the organization;
• That affects the ability of the organization to achieve the intended outcomes of the EMS;
• That is related to those environmental conditions
  • that can affect the organization and
  • that can be affected by the organization.

Clause 4.1 calls for a high-level and conceptual understanding of the organization and its context. This understanding can be gleaned from a high-level or strategic determination and analysis of the internal and external issues that are:

• relevant to the purpose of the organization and
• that can affect the ability of the organization to achieve the intended outcomes of the management system.

The qualifier ‘relevant to the purpose of the organization is primarily a quality management concept, but in terms of the EMS, it means that any issues that are not relevant to the purpose of the organization can be readily discarded.
The issues that can affect the ability of the organization to achieve the intended outcomes of the EMS are issues that can either enhance or impede the achievement of these intended outcomes. This is quite important, as Clause 6.1.1 requires the determination of risks and opportunities that are posed by these issues. The issues capable of enhancing the ability of the organization to achieve the intended outcomes of the EMS are leveraged as enabling opportunities, while those capable of impeding the achievement of intended outcomes are managed as risks. The organization often does not have any control over these risks. The mitigation of and adaptation to the effects of these external conditions are often the only response strategies available to organizations. Also note that the term “affect‟ is used in this standard to refer to the potential changes caused by these issues, while the changes caused by the organization ‟s activities, products, and services to the environment are referred to as “impacts‟. These issues can originate from inside the organization as well as from outside the organization. The issues that originate from within the organization can range from matters such as leadership commitment, the organizational culture, and the availability of resources such as skills, infrastructure, information, etc. Those issues that originate from without the organization can be caused by environmental conditions as well as the regulatory, political, infrastructural, service delivery, social and cultural dimensions within which the organization operates. External environmental conditions that can affect the organization include impeding factors such as climate change (on a global scale), the availability of natural resources, weather conditions, flooding, fires, and seismic events (on a local scale), and enhancing characteristics such as location relative to natural resources and markets. Being situated outside the impact zones of natural disasters or existing in a stable and democratic socio-political system with a skilled and reliable workforce can offer opportunities that can be leveraged by organizations

Internal and External issues

The issues contemplated under clause 4.1 also include the effects on environmental conditions that are caused by the organization. These effects are actually synonymous with the environmental impacts caused by an organization’s activities as contemplated in clause 6.1.2. If the identification of the environmental aspects and impacts are required in terms of clause 6.1.2, the question is what then is required in terms of clause 4.1? The determination of the effect of the organization on environmental conditions differs from the identification of environmental aspects and impacts insofar that the former is performed at a high, strategic or conceptual level, while the latter is a more detailed and operational-level analysis.
The output of clause 4.1 includes a conceptual and high-level overview of:

• External issues that are relevant to the purpose of the organization and that affect its ability to achieve the intended outcomes of the EMS;
• Internal issues that are relevant to the purpose of the organization and that affect its ability to achieve the intended outcomes of the EMS;
• Environmental conditions that are affected by the organization; and
• Environmental conditions that can affect the organization.

Example of internal and external issues.

Example: A family-owned company, manufacturing wooden outbuildings for domestic and commercial use. The organization’s purpose is to provide both retail and bespoke sectional buildings to individuals and organizations.
Example internal issues:

• Transport and site erection costs/service
• The culture within the organization/governance and succession issues
• Opportunities to move from product to service e.g. leasing and maintenance of buildings
• Relationship with supply chain (timber traceability etc.)
• Potential sustainable material replacement program (products/packaging)
• Material consumption (recycled, durable, reusable, recyclable, biodegradable)
• Energy management
• Wastage of raw material/waste disposal/developing market for by-products
• Structure of the organization
• Roles within the organization
• Business growth strategy
• Return on investment
• Product/service quality
• Capital expenditure
• Solvency
• Debt and interest
• Liabilities (e.g. Public)
• FairTrade/Ethical trading
• Availability of reliable, qualified and competent workforce
• Stability of workforce/HR practices
• Impact of unionization
• Staff training levels
• Contractual arrangements with customers
• Payment terms from customers
• Solvency of customers
• Expansion of customer base
• Cash flow
• The overall strength of business to support funding needs
• Resilience of infrastructure
• Relationship with investors (including Bank)
• Credit rating and availability
• Health and Safety on-site and on client site
• Design for Environment

Example of external issues:

• Political, economic.social, technological, legal and regulatory
• Supply chain resilience
• Market sensitivity to habitat loss and biodiversity issues
• Overall economic performance in the country
• Economic plans for future
• Market conditions (customer demographic/market confidence etc.)
• Customer expectation
• Standardization and certification within the industry
• Impacts of climate volatility
• Changes to the local environmental setting (development/designation of Conservation areas/development of flood defences etc.)
• Fuel/raw material prices – international pressures, domestic market pressures government taxation regime, etc.
• Regulation within the industry generally
• Trade associations and lobbying powers
• Impact on neighbours

Clause 4.2 Understanding the needs and expectations of interested parties. 

The organization should determine the interested parties that are relevant to the environmental management system and their relevant needs and expectations (i.e. requirements). The organization should also determine these needs and expectations become its compliance obligations.

• An “interested party” (also known as “stakeholder”) is any individual or organization that can affect, be affected by, or perceive itself to be affected by your organization’s decisions or activities. Interested parties may include, for example, customers, communities, suppliers, regulators, NGOs, investors, employees and trade unions.
• The phrase “compliance obligations” replaces the phrase “legal requirements and other requirements to which the organization subscribes” used in prior editions of this International Standard. The change is considered simpler to understand and does not change the intent of the previous standard ie ISO 14001:2004.

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

“An organization is expected to gain a general (i.e high-level, not detailed) understanding of the expressed needs and expectations of those internal and external interested parties that have been determined by the organization to be relevant. The organization considers the knowledge gained when determining which of these needs and expectations it has to or it chooses to comply with, i.e. its compliance obligations.
In the case of an interested party perceiving itself to be affected by the organization’s decisions or activities related to environmental performance. the organization considers the relevant needs and expectations that are made known or have been disclosed by the interested party to the organization.
Interested party requirements are not necessarily requirements of the organization. Some interested party requirements reflect needs and expectations that are mandatory because they have been incorporated into laws, regulations, permits, and licenses by governmental or even court decisions. The organization may decide to voluntarily agree to or adopt other requirements of interested parties (e.g entering into a contractual relationship. subscribing to a voluntary initiative). Once the organization adopts them, they become organizational requirements (i.e. compliance obligations) and are taken into account when planning the environmental management system. A more detailed-level analysis of its compliance obligations is performed in  clause 6.1.3″

This sub-clause requires that interested parties relevant to the EMS are determined. This is a step up from the 2004 version of the standard, in which the determination of interested parties was not explicitly required. The general interpretation of the 2015 requirement is that evidence of this determination is required. Once the interested parties have been identified, the organization is required to determine their needs and expectations. Once all the needs and expectations of interested parties have been determined, the organization needs to make a decision about which of these needs and expectations it will adopt and manage. Once adopted, these needs and expectations become compliance obligations requiring management by the organization. Responding to and addressing these adopted compliance obligations are obligatory. What are your organization’s requirements with respect to interested parties?

1. Determine who are the interested parties relevant to your environmental management system (EMS). Incidentally, an organization that “perceives itself to be affected” by your decisions or activities obviously needs to make that perception known to your organization before being listed as an interested party. It would be good practice to create a “register of interested parties”.
2. Determine the relevant needs and expectations of these interested parties
3. Decide which of these needs and expectations are to be “compliance obligations”. Any needs and expectations that are mandatory (eg. legal obligations, contract requirements or court decision outcomes) are automatically compliance obligations. Beyond these, only needs and expectations that you consider relevant and that you choose to adopt become compliance obligations. So, you can choose to ignore some non-mandatory interested party needs and expectations.
4. Make available to interested parties the “scope” of the EMS (ie. the organization’s activities that are included in the EMS), and the environmental policy. Ensure communication with interested parties meets their needs, is understandable by them, and enables them to participate. Keep records of such communications.
5. Provide, to appropriate interested parties, relevant information and training related to emergency preparedness and response.
6. And be mindful of the needs and expectations of interested parties when developing or reviewing environmental aspects.
7. In the case of an interested party “perceiving itself” to be affected by your organization’s decisions or activities related to environmental performance, your organization must consider the relevant needs and expectations that are made known or have been disclosed by the interested party and then make a decision whether to adopt them

CLASSIFYING INTERESTED PARTIES AND THEIR RELATIONSHIPS

Simply listing suppliers, customers, communities, etc. is not enough to meet the requirements of the standard i.e. understanding the needs and expectations of relevant interested parties. Make the information more meaningful by grouping interested parties based on their relationship with the organization. This is advised in ISO 14004 – EMS Guidelines for Implementation, which provides examples of interested parties based on their relationship with the organization, by their:

• Responsibility – investors, etc.
• Influence – pressure groups, etc.
• Proximity – neighbours, etc.
• Dependency – employees, etc.
• Representation – trade unions, etc.
• Authority – regulators, etc.

Some categories may contain sub-categories, which require a different management approach. For example, customers may include key accounts which have different needs and expectations to transactional customers. Now you know who your interest parties are, it is time to identify their needs and expectations which are relevant to your management system. The operative word here is relevant.  Depending on the size and complexity of your organization, it is very likely that you or your colleagues will have a good feel for the interested parties you have regular contact with. However, it is worth formalizing this knowledge and, where needed, confirming assumptions and closing knowledge gaps with research. The scale of research again depends on the size and complexity of your organization. For example:

• A two-person gardening firm may be able to complete research within a few phone calls to clients, suppliers, local council, etc.
• A multi-national pharmaceutical company may require a range of research methods (quantitative and qualitative, primary and secondary).

This relates two important relationship variables:

• How much interest do they have in your decisions and activities? This could be interpreted as the strength of their relevance.
• How much power or influence do they have over your decisions and activities? This could be interpreted as their significance or risk.

Plotting interested parties help to prioritize the effort required to meet their needs and expectations:

Process for mapping interested parties 

• Identify relevant interested parties. Compile a categorized list of your interested parties.
• Determine their needs and expectations. Use different research methods as necessary to confirm your knowledge of each group or significant stakeholder.
• Rank them in terms of power and interest: Consider their strength of interest and level of influence over your decisions and actions. Plot them in the Power/Interest Matrix to determine their rank.
• Set objectives and priorities. Define what results are necessary to deliver to those relevant interested parties to reduce the risk that their needs and expectations are not met.

You should end up with something like this example – but create a framework that suits your own needs:

Example of  interested parties and potential needs/ expectations ( – to be verified in practice):

Example: A family-owned company, manufacturing wooden outbuildings for domestic and commercial use. The organization’s purpose is to provide both retail and bespoke sectional buildings to individuals and organizations. (same example as taken previously from Clause 4.1 Understanding the Organization and its context )

External Interested parties and potential needs/expectations

Internal Interested Parties and potential needs/expectations

4.3. Determining the scope of the environmental management system

The organization should determine the boundaries and applicability of the environméital management system to establish its scope. When determining this scope, the organization should consider its organizational units, functions,  physical boundaries, activities, products, services, authority, and ability to exercise control and influence. The organization should also consider its external and internal issues referred and their compliance obligations. 

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

“The scope of the environmental management system is intended to clarify the physical and organizational boundaries to which the environmental management system applies, especially if the organization is a part of a larger organization. An organization has the freedom and flexibility to define its boundaries. it may choose to implement this international Standard throughout the entire organization, or only in specific parts of the organization, as long as the top management for those parts has authority to establish an environmental management system. In setting the scope, the credibility of the environmental management system depends upon the choice of organizational boundaries. The organization considers the extent of control or influence that it can exert over activities, products, and services considering a life cycle perspective. Scoping should not be used to exclude activities, products. services, or facilities that have or can have significant environmental aspects. or to evade its compliance obligations. The scope is a factual and representative statement of the organization’s operations included within its environmental management system boundaries that should not mislead interested parties. Once the organization asserts it conforms to this International Standard, the requirement to make the scope statement available to interested parties applies.”

Once the scope is defined. all activities, products, and services of the organization within that scope need to be included in the environmental management system. The scope shall be maintained as documented information and be available to interested parties. Making the scope available to interested parties is a passive duty as the requirement is not to actively distribute the documented scope of the EMS. The requirement to make the EMS scope available to interested parties is an attempt to counter concerns that organizations misrepresent the actual scope of their EMSs.

An example of how a scope could be derived

1. Organization’s purpose and strategic direction

• Purpose: As one of India’s leading providers for sheetfed and heat set lithographic printing services, our reason for’being’ is a combination of our vision, mission, and values.
• What is our vision? To become the most trusted provider for print services within India and Europe.
• What is our mission? To expand our operations by consistently meeting customers’ expectations and our legal requirements; which includes the enhancement of customer satisfaction, and protection of our environment. through the effective application of our processes for continual improvement and environmental performance.
• What are our values? Sustainable business, social economic and environmental impacts, responsible governance and equal opportunity. These are re-enforced through sustainability principles and workforce integrity throughout all business operations. Cooperation and collaboration are expected norms within the organization’s management, with recognition provided for all through regular appraisals. We encourage and embrace any values which support the behaviours that employees cherish.
• Strategic Direction:  To open a new office in Germany and New Delhi this year bringing together the technology and expertise in India with the market needs of Europe and beyond. To implement and gain accredited certification to ISO9001 and ISO14001 in these new offices, within a year of the offices opening. To employ a motivated workforce that will embrace the organization values, and complement the cooperation and collaboration needed to achieve the effective application of our processes for continual improvement.

2. Organization’s intended outcome(s) of its EMS

From the’1 Scope’ of the Standard: 

• To provide value for the environment, our organization, and our interested parties
• To enhance our environmental performance
• To fulfil our compliance obligations; and
• To achieve our environmental objectives

Specific to our organization:

• A more sustainable product, with the smallest possible carbon and resource footprint;
• Financial benefit through the effective application of improvement and operational processes
• Effective control/influence over interested parties, within our product life cycle, thereby improving our overall environmental performance

3. External issues

Site Orientation

• Honey Printers Pvt. Ltd is situated in Khopate, a medium-sized town of some 60,000 inhabitants. The Good Prospect factory is a three-floor complex that comprises both the print works and offices of Honey Printers, taking up nearly 50,000sq feet of space in total. The rest of the site is shared with other office-based companies who occupy the remaining floors of the complex which consists of a 16 story high rise building. (Issue: Noise vibration odour interested party complaints.)
• The entire complex is situated west of the tunnel, just off the main Uran-Panvel Road, overlooking JNPT Harbour, a major trading port area. Like most places on the island, its position is tightly constrained by neighbouring buildings in a mixed business and residential area. (Issue: Carbon footprint increase and contribution to traffic congestion and emissions through vehicle fleet noise, odour, interested party complaints)

Site Context

• The company operates a prescribed process using regulated substances in accordance with a license issued under Regional Regulations. (Issue: Legal Compliance)
• In addition, it is required to comply with a discharge permit from the MPCB EPD via the Water Pollution Control Ordinance in respect of process wastewater discharges to receiving water bodies. (Issue: Legal Compliance)
  MPCB EPD regularly inspects operators, responds to complaints and, after an uncertain enforcement record in the late ’90s, has a strong and growing record of successful prosecution. (Issue: Fines and legal cost)
• Navi Mumbai is generally very hilly and particularly so in the Northern area where the Panvel sits on a relatively narrow ledge of rock between hillsides and the sea. In common with the rest of the island, the underlying geology of the site comprises volcanic rock and granite. (Issue: Potential flood zone raised sea level from Climate Change)
• To the rear of the site, the Sai Laxmi Park acts as home to the Upper and Lower reservoirs (capacity 266 million imperial gallons/1,210,000m³ ). A nature trail runs through the tops of the hills immediately overlooking the site. (Issue: continuity of process water supply, VOC emissions, and effect on biodiversity)
  In addition, to the front of the site, the concrete flyover feeds the tunnel, the main access point to the area known as ‘MHADA colony’ a prime residential location. (Issue: odour complaints from the influential interested party/interested parties)
• The nearby JNPT Harbours continues to be the focus of development for the Navi Mumbai Harbour Area Treatment Scheme (NMATS) into which, traditionally, most of Sewage and effluent had been ejected. However, the declining quality of the marine environment prompted an urgent program lead and funded by, the State Government. (Issue: Contribution to local water pollution, legal compliance)
• Navi Mumbai can experience very heavy rainstorms during Monsoon. The annual average rainfall is about 245 cm. During particularly heavy rainstorms, flooding in the rural low-lying areas and natural flood-plains in the northern part of the territory and in parts of the older urban areas may occur. The Panvel is a formally identified flooding hotspot. (issue: Flooding)

Market Pressures

• In recent years, the company has had an increase in requests from customers for environmental information concerning the company’s products and activities, particularly in the areas of paper sourcing, energy use and CO₂  emissions from transport.Key customers appear to be implementing procedures to include environmental performance in supplier selection criteria and Honey Printers Pvt. Ltd has been unable to respond adequately to requests for information. (Issue: Interested party complaints, evaluation of compliance with customer requirements)
• Guidance documents on environmental responsibilities have been published by relevant local industrial trade associations and the Maharashtra Pollution Control Board (MPCB) and the company is beginning to make use of those. (Issue: Interested party complaints, legal compliance)
• In response to international market pressures and to ensure that the company’s interested party expectations were being met, the management of the company authorized the implementation of an Environmental Management System. The company decided not to acquire a third-party certification of the system. (Issue: Loss of interested party confidence, demonstrable corporate responsibility open to question)

History

• The company was formed 40 years ago and has always operated at the Good Prospect Factory.Early production focused on servicing local and regional customers. Original print runs (number of copies printed) were high due to the fact that even relatively small jobs were printed in two or three different language versions, including English, Hindi, and Marathi. (Issue: Contaminated land from previous operations.)
• With the increasing demand for the short run, lower volume and better quality printing, Honey Printers Pvt. Ltd invested heavily in new sheet-fed lithographic printing equipment to extend their printing capabilities into the international market for ‘on demand’ and bespoke the catalog printing.(Issue: Higher resource use from cleaning between the high number of low print runs, high potential emissions and hazardous waste from solvent based cleaning materials larger carbon footprint from international distribution of finished product greater concern on ROI from earlier technology investment leads to less funding for environmental projects )

4. Internal issues

• Honey Printers Pvt. Ltd prints collate and bind publications for a variety of customers. It also arranges transportation of the finished publications either direct to customers’ warehouses (due to the lack of bulk storage on their own site), or straight to the client’s target audience in India and the rest of India through a direct mailing system.(Issue: Energy use, resource and material use)
• The site is taken up mainly by the Good Prospect Factory of which the bottom floor is entirely occupied by the primary print production facility (the 4sheet fed lithographic presses as well as associated paper holding bays, ink stores). There is very little space to spare and stores on site are kept to a minimum, relying on just in time delivery of materials. (Issue: Energy use resource and material use hazardous substances, carbon management)
• There is also a bindery area comprising 4 saddle stitch and 4 perfect binder lines where signatures (individual pages of the publications) from the presses are collated together and bound. A small holding bay also exists for finished publications. (Issue: Energy use, air emissions resource, and material use)
  The remainder contains the following operations:
  2^nd floor; Prepress preparation area (scanners, proofers and plate managers) secondary print area (2 high-speed photocopying machines) Includes a small area for General Stores. There is also a Direct Mail Unit, including stores for packaging, a small area for progress checking. (Issue: Energy use resource and material use hazardous substances)
  3rd-floor Offices for Production Administration, Sales and Purchasing, Executive functions, Staff Restaurant, and a separate testing laboratory for checking inks and adhesives. (Issue: Energy use resource/material use and hazardous substances)
• The site employs a total of 62 people, with 5 working mostly off-site as Sales Representatives. Nineteen people work in the administrative section which comprises sales, orders, purchasing, and accounts. Operational staff work on a 3 shift, 24-hour day, 6 days a week system.Shift hours are: 6 am — 2 pm, 2 pm — 10 pm, and 10 pm – 6 am. (Issue: Energy use, resource, and material use)
• Occasionally work is carried out over the weekends, mainly for maintenance or for direct mail campaigns but sometimes to accommodate extra work for urgent, complex or large orders. (Issue: Energy use, interested party complaints about noise and vibration)

Management System

• The company already operates Quality and Health and Safety Management Systems and where appropriate, environmental controls have been integrated into these existing systems. The company started developing its Environmental Management System last year.The Facilities Manager was charged with the responsibility of implementing the system by the Board; he has delegated the responsibility on a day to day basis to the new post of Head of Safety, Health Environment, and Quality (SHEQ), created six months ago. (Issue: resources to support system)
• The project has involved other managers including both the Operations Manager and the Accounts and Purchasing manager. The Facilities Manager’s previous environmental experience relates only to health and safety, and he has only recently had responsibility for environment added to his job specification. (Issue: resource and training required  to maintain competence)
• The Head of SHEQ has overall responsibility for maintaining the environmental manual as part of the integrated environment, health and safety and quality system. He wrote the environmental manual and general procedures on environmental management, whilst the Facilities Manager, aided by the Operations Manager was responsible for the more technically based documentation. (Issue: loss of staff and associated competence)
• The site conducted an initial review (12 months prior to audit), and has since developed an environmental policy and environmental manual containing programs and procedures for managing the site’s operations.

Process Issues

• Operations at the site include preparation for the presses where customer’s artwork is received via electronic transfer of files, though special artwork can sometimes require hard copy delivery. (Issue: Energy use, GHG release, resource and material use, hazardous substances, the potential for spillage and associated contamination of land or process water and stormwater discharges.)
• This information is converted into images on cellulose film in the prepress area. The images are stabilized using fixer and developer before the image is transferred to aluminium plates by high-energy UV rays. Typically this equipment uses 2,500 watts for operation (Issues: Energy use, resource and material use, hazardous substances and associated waste and water discharges)
• Plates are then cleaned in a sink with chemicals and taken to the mu|ti—unit print presses, where printing ink is applied to the paper substrate via the aluminium plates to produce the printed image (signatures). (Issue: Energy use, resource and material use, hazardous substances and associated waste and water discharges)
• The inks can be premixed or are applied as standard colours to different plates to produce the right co|our. This is checked against standard specifications. (Issue: hazardous substances and associated waste and water discharges)
• The transfer process is carried out using a fountain solution, which is produced by dosing mains water with fountain solution chemical to get the desired dilution. Surface coating of publication covers is sometimes requested, and this is applied during the printing process. (Issue: resource use (water) hazardous substances and associated waste and water discharges)
• Bindery operations are where the finished elements are collated together and bound either by inserting metal wire staples or glued (perfect bound) together. The finished publications are bound and shrink-wrapped onto wooden pallets prior to shipping to the customer (Issue: Packaging hazardous substances and associated waste and water discharges)
• Feedstocks mainly comprise cellulose films, aluminium plates, and paper. Liquid raw materials include printing inks, binding adhesives; heat-seal coatings, cold-seal coatings, and solvents. (Issue: Resource use)
• Drummed solvents are dispensed into 25-litre containers for internal transport to process areas. Inks are delivered in half tonne mini-bulk tanks and are off-loaded in the ink storage area, at the rear of the building. The inks are transferred manually to the sheet-fed printing presses, but the latest line can be fed from an integral reservoir. Other coating materials are delivered in either 25 or 200-liter drums, directly to the primary Print Shop room. (Issue: Packaging, hazardous substances, and associated waste and water discharges)
• Inks from bulk storage tanks and smaller containers are blended on-site to produce “finished” printing ink and adhesives, originally premixed in a separate Mixing Room, are now mixed in a small area next to the main presses to make efficient use of the main air, emission abatement equipment ducting that was installed (five years prior to audit). Consumption of inks is estimated at 35 tonnes per month. Emissions from pre-mixing operations are vented directly to the atmosphere. (Issue: Packaging air emissions, hazardous substances, and associated waste and water discharges)
• Printing and coating are carried out in the Print Shop, which is split into four distinct work areas; sheet-fed lithographic presses take up the entire space. Two high-speed photocopying machines sit together on the second floor as a self-contained ‘print on demand’ unit. (Issue: Energy use, hazardous substances, resource use, and associated waste and water discharges)
• Printing operations involve the application of materials with relatively high solvent content to the surface of a moving plate or film. Rapid solvent evaporation is achieved by the movement of heated air across the plate and sheet surface, which results in solvent laden air being emitted from the system. (Issue: Energy use, hazardous substances, air emissions)
• All application of printing inks and other wet materials is carried out in the Print Shop area and associated cleaning rooms. Volatiles are either captured by the abatement equipment in the Print Shop area or vented directly to the atmosphere by the building’s forced ventilation system. (Issue: water discharges, air emissions)
• Total solvent losses to the atmosphere from pre-mixing and printing processes were estimated to be about 0.5 tonnes per month prior to a change of ink supplier and product. (Issue: water discharges, air emissions)
• Cleaning of printing equipment is carried out in a self-contained, solvent emissions ducted washroom adjacent to the Print Shop. The plant is solvent based and uses 1 tonne per year of ethyl acetate and ethanol. An underground sump collects waste residues from the cleaning process and is emptied bi-annually. (Issue: water discharges, air emissions, contaminated land from the underground tank).
• In addition, there is an ultrasonic cleaning plant, which uses an aqueous caustic solution for roller cleaning and ancillary cleaning. Twenty-five litres of ethyl acetate is used per application, which is thought to be captured by the abatement filtering system but may also ultimately be lost to the atmosphere. Both sets of the plant are themselves cleaned periodically with cleaning liquids (solvent and caustic), being fully replaced with fresh chemicals. (Issue: Energy use, hazardous substances, water discharges, and air emissions)
• Finished goods are packaged manually in the Finishing Department. Due to the restricted size of the storage area, the site operates its own distribution service and owns ten 7.5 tonne trucks. In addition, some delivery is subcontracted to a Local carrier which may move finished goods to a leased warehouse in Indore for further distribution. (Issue: Energy use, vehicle emissions)The Testing Laboratory employs a full-time chemist who carries out sample testing of incoming inks.  Small quantities of numerous different solvents, inks and other chemicals are used to test different ink formulations and are stored in a dedicated storage room within the laboratory. (Issue: Hazardous substances, spillage, waste disposal, and water discharge).

Environmental Controls

• Hazardous wastes are generated from primary production, laboratory operations, and cleaning processes. Waste inks and solvents are stored in a bulk container for off-site recycling.So|vent-based inks are filtered on-site to produce a solvent waste stream which is recycled and a solid waste stream which is disposed of as hazardous waste. (Issue: Liquid and solid, hazardous and general waste)
• Waste cooling waters from the printing lines are discharged to a foul sewer. The area’s drains are to be included in the second phase of the Navi Mumbai Area Treatment Scheme (NMATS) under the management of the MPCB EPD. They currently discharge directly to the harbour via a 1-kilometre undersea outfall pipe. (Issue: water discharges, the current level of marine pollution)
• Stormwater surface drains are currently blocked in the solvent storage area and the site has constructed an underground sump to collect local rainwater flooding this area. The sump discharges to the stormwater system, which in turn discharges directly to the harbour via the area outfall pipe already mentioned. (Issue; flooding)
• Volatile organic compound (VOC) emissions from the pre-mixing operations, printing, and (occasionally) binding activities are mostly vented to atmosphere through abatement ducting, fans and filters which have been retrofitted in the print shop area. Fugitive emissions include those from manual transfer of solvents and inks, ink mixing, adhesives, from the bindery emissions from the test laboratory and those from the ultrasonic cleaning plant. (Issue: Air emissions)

Environmental history

• The site has received complaints from the public and other local businesses concerning both noise and odours. In the past six months, over eight complaints have been received from four different sources regarding noise, and approximately seven complaints have been made about strong odours from four different sources, two of which also complained about noise problems. (Issue: Interested Party complaints)
• The site’s planning/land use permission contains limits on environmental noise emissions between the hours of 17.00 and 08.00, of 45 dB(A). The local Environmental Inspector has conducted noise monitoring and has recorded an exceedance of this limit on two out of 14 occasions during the regulated time period. The local government administration has, therefore, requested that the site implements environmental noise reduction measures where practical. Response to this request in ongoing. (Issue: Legal Compliance)
• The site is developing a program to implement the license requirements to manage and reduce emissions of VOCs to the atmosphere. This is being monitored carefully by the MPCB, who are keen to ensure regulatory requirements are met, and that public complaints are reduced. (Issue: Legal Compliance)
  The site had a small spill of toluene to the stormwater drain approximately one month ago, when a drum was knocked over which was not sealed. This was immediately reported to the authorities.

4. Interested Parties and needs and expectations of Interested Parties.

Needs and expectations of External interested parties

Needs and expectations of Internal interested parties

5. Compliance obligations

All the above will become compliance obligations with the exceptions of:

• Media (All) This will be re-visited once the EMS is operational
• Customers( 4. Environmentally sustainable product), we are striving for this but this will not become a compliance obligation yet
• Distributors ( 2. Continuity of product supply), we cannot guarantee
• Neighbours (1.Absence of noise/odour/vibration incidents), we cannot guarantee: the absence of noise/odour/vibration incidents but a compliance obligation will be reductions wherever ‘reasonably practicable’
• Staff (3.  Training and support for all and 5.Continuity of employment) we cannot guarantee, depends on budget, etc. 
• Contractors/Suppliers (4.Level playing field for all environmental requirement), we cannot guarantee at the present

6. Organizational unit(s), function(s), physical boundaries

‘Honey Printers Pvt. Ltd operates from its sites in Panvel, Navi Mumbai, and soon in Pune and New Delhi. No sites are/will be shared with other organizations and each site has a clearly defined boundary/demarcation to their neighbors. At each site, the organizational unit(s)/ function(s) comprises of Office administration (finance, sales, order processing, Support functions, HR, Quality, IT, Environmental, OH&S, general management), Design of customer’s artwork. At the Panvel, Navi Mumbai HK Isite only, Development (preparation), Production (Printing signatures), Production (pressrooms), Production (bindery), and final Dispatch of printed materials (Delivery).

7. Activities, products, and services of the organization

The design, development, production, and delivery of a range of high-quality and environmentally sensitive printing solutions. Print work providers for sheetfed and heat set lithographic services and can be prepared on a bespoke basis, or chosen from a range of standardized offerings. Delivery is provided through outsourced transportation services.

8. Authority and the ability to exercise control and influence

Full authority and ability to control is possible over our main printing sites in Navi Mumbai, Pune, and New Delhi, and a strong authority and ability to influence over our outsourced transportation services. We have a strong authority, and great ability to influence our paper sourcing suppliers’ environmental performance and that of our inks procurement suppliers’ environmental performance. However, we have little authority and limited ability to influenceunused stock policies from our customers. Our current levels of influence over our customer’s choice of environmentally benign raw materials are not high, though we are seeking to increase this through a change in policy in sales contract negotiations. Finally, we have no authority and marginal ability to influence the final disposal of our product.

9. Determined scope

The scope of ‘Honey Printers Pvt. Ltd’ Environmental Management System applies to the design, development, production, and delivery of a range of high quality and environmentally sensitive printing solutions from its site in Hong Kong, with a planned rollout program to include our proposed Germany and Beijing offices. Print work providers for sheetfed and heat set lithographic services and can be prepared on a bespoke basis, or chosen from a range of standardized offerings. It covers the management of business activities that support these products and services (including transportation outsourcing) and the influences (where possible) of any significant aspects that occur in its life cycle e.g procurement, unused stock, and final disposal.

—————————End of example————————————— 

Clause 4.4 Environmental management system

The organization must establish, implement, maintain and continually improve its environmental management system, which includes its process and its interactions in accordance with the requirements of these international standards so as to achieve its intended outcome which includes enhancing its environmental performance. While establishing and maintaining its environmental management system the organization should consider the knowledge gained while determining its external and internal issues and needs and expectations of interested parties. 

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

The organization retains authority and accountability to decide how it fulfills the requirements of this International Standard. including the level of detail and extent to which it:
a) establishes one or more processes to have confidence that it  is controlled, carried out as planned, and achieve the desired results;
b) integrates environmental management system requirements into its various business processes such as design and development, procurement, human resources, sales, and marketing;
c) incorporates issues associated with the context of the organization and interested party requirements within its environmental management system.
if this international Standard is implemented for a specific part of an organization, policies, processes and documented information developed by other parts of the organization can be used to meet the requirements of this. International Standard, provided they are applicable to that specific part

ISO 14001:2015-Clause 4.4 states that the organization shall establish, document, implement, maintain and continually improve an EMS, the requirements which encompass all the requirements of the Standard. The words used in the Standard are ‘establish’ and ‘maintain’. There is no guidance as to the level or depth of establishment or what evidence is required to show maintenance. However, it can be taken to mean that there must be some objective evidence of the system being in place and reviewed and revised.  Such review processes can take the form of monthly progress meetings, corrective actions from audits, and of course audit themselves.  Audits are evidence of reviewing; that is, asking the question: ‘Are the planned activities of the organization occurring in practice?’  It would be very prudent for an implementing organization to offer evidence of one or two audits of a significant impact over a period of 2 to 3 months. An improvement in the environmental management system is intended to show an improvement in environmental performance. The organization is expected to periodically review and evaluate its environmental management system to identify opportunities for improvement and its implementation. The rate, extent, and timescale of this continual improvement process are to be determined by the organization in the light of economic and other circumstances. An organization  is required to

1. establish an appropriate environmental policy,
2. identify the environmental aspects arising from the organization’s past, existing or planned activities,  products, and services, in order to determine the environmental impacts of significance,
3. identify applicable legal requirements and other requirements to which the organization subscribes,
4. identify priorities and set appropriate environmental objectives and targets,
5. establish a structure and programmed to implement the policy and achieve objectives and meet targets,
6. facilitate planning, control, monitoring, preventive and corrective actions, auditing and review activities to ensure both that the policy is complied with and that the environmental management system remains appropriate, and
7. be capable of adapting to changing circumstances.

This sub-clause, like its predecessor, makes provision for the entire life cycle of an EMS, ranging from its establishment to its continual improvement. The third revision adds the processes and interactions between the elements of the EMS. The EMS shall be established and managed to ensure that the intended outcomes of the EMS are achieved and environmental performance is enhanced. The focus of the third revision of the EMS on the enhancement of environmental performance should be noted, as the first two revision of the standard required the improvement of the management system, which means that the enhancement of environmental performance is an outcome of the improvement of the management system. This sub-clause also suggests that the output of clause 4 is knowledge. This generated knowledge is to inform other processes of the EMS. The high-level analysis of the organizational context generates conceptual information or knowledge about the relationships between the organization, the environment, and the environmental management system. The standard does not require that this information or knowledge be documented (with the exception of the scope of the management system). The standard does, however, require that this knowledge be considered when other requirements of the ISO 14001: 2015 standard are addressed. The requirements demanding consideration of the outputs from clause 4.1 include:

• Clause 4.3, determining the scope of the EMS;
• Clause 5.2, environmental policy;
• Clause 6.1, actions to address risk and opportunities.

The issues need to be unpacked and documented as risks and opportunities that require management in terms of the following clauses:

• Clause 9.2.2 Internal audit program; and
• Clause 6.1.4, planning to take action;
• Clause 6.2.1, environmental objectives;
• Clause 9.3, management review.

Compliance Obligations – Definition

ISO 14001:2015 defines Compliance obligations as “legal requirements that an organization has to comply with any other requirements that an organization has to or chooses to comply with”. In the note, it further states “Compliance obligations can arise from mandatory requirements, such as applicable laws and regulations, or voluntary commitments, such as organizational and industry standards, contractual relationships, codes of practice and agreements with community groups or non-governmental organizations.”

6.1.3 Compliance obligations

The organization should determine and have access to the compliance obligations related to its environmental aspects. The organization must also determine how these compliance obligations apply to the organization. The organization must take these compliance obligations into account when establishing, implementing, maintaining, and continually improving its environmental management system. The organization must maintain documented information about its compliance obligations. Compliance obligations can result in risks and opportunities for the organization.

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

The organization determines, at a sufficiently detailed level, the compliance obligations it identified in 4.2 that are applicable to its environmental aspects, and how they apply to the organization. Compliance obligations include legal requirements that an organization has to comply with any other requirements that the organization has to or chooses to comply with. Mandatory legal requirements related to an organization’s environmental aspects can include, if applicable:
a) requirements from governmental entities or other relevant authorities;
b) international, national and local laws and regulations; 
c) requirements specified in permits, licenses, or other forms of authorization;
d) orders, rules, or guidance from regulatory agencies;
e) judgments of courts or administrative tribunals.
Compliance obligations also include other interested party requirements related to its environmental management system which the organization has to or chooses to adopt. These can include, if applicable:

• agreements with community groups or non-governmental organizations;
• agreements with public authorities or customers;
• organizational requirements;
• voluntary principles or codes of practice;
• voluntary labelling or environmental commitments;
• obligations arising under contractual arrangements with the organization;
• relevant organizational or industry standards.

Explanation:

Compliance obligations may be mandatory (eg. Acts and Regulations), or voluntary (eg. contractual relationships, codes of practice and agreements, and even expectations of third parties). Voluntary undertakings become compliance obligations once an organization decides to adopt them. The revised standard requires the organization to take a high-level look at their “compliance obligations”, which include both regulatory requirements and voluntary commitments (for example to industry standards, contracts, and agreements with communities or NGOs). The organization must determine the risks and opportunities associated with compliance obligations. This could be the scale of penalties resulting from non-conformance, the benefits accruing from meeting commitments, or the risks of the EMS failing to maintain compliance. They must plan actions to address compliance obligations and to integrate these actions into the EMS or other business processes. they must determine the competence requirements needed to meet compliance obligations and ensure these are satisfied. They must ensure that awareness-raising and communications programs take account of compliance obligations. They must maintain processes for evaluating fulfillment of compliance obligations, determine to evaluate and take action after evaluation, and maintain knowledge and understanding of its compliance status and the management review should consider trends in the fulfillment of compliance obligations.

ISO 14001:2015 requires organizations to developing an understanding of their compliance obligations, both regulatory and voluntary. There is more emphasis on understanding the expectations of stakeholders and determining those that should be addressed. These could range from commitments to investors or customers about carbon emissions, applicable industry performance standards, local community agreements, and any other commitments made by the organization. ISO 14001:2015 requires more rigor in identifying risks associated with non-compliance, at strategic and operational levels, and in establishing means of control. A fundamental change is being to demonstrate compliance status. This is not a one-off exercise, but a process that provides almost real-time knowledge and understanding of how the organization is performing with regard to regulatory compliance and voluntary commitments. Many organizations, especially those subject to detailed regulatory scrutiny, may already have reliable and ongoing mechanisms for checking compliance, ranging from continuous emissions monitoring to daily housekeeping checks and weekly or monthly reviews of performance against improvement targets aimed at delivering conformance to compliance obligations. Organizations meeting the new compliance requirements of ISO 14001:2015 are probably in a far better position to understand their compliance risks and reap the benefits from being able to demonstrate to stakeholders that they are fulfilling their commitments to environmental sustainability.

Elements of meeting requirements of Compliance obligation:

1. Commitment to compliance
2. Determining compliance obligations
3. Translating requirements of compliance obligations into impact on the organizations
4. Ensuring that organizational and technical measures are taken in order to comply with the requirements
5. Self-assessing Compliance
6. Internal Audit
7. Management review of Compliance

1. Commitment to compliance

The organization’s top management must lay down its commitment to fulfilling its compliance obligations. In practice, this is done by including a text in a ‘policy declaration’ signed by top management, in which other policy principles (such as the commitment to improving performance) are laid down. More important than the written statement is the way that this commitment is communicated within the organization by its top management. It is essential that compliance with Compliance obligations are part of the organization’s internal culture. Simply putting a statement down on paper is not enough to bring this about, however; regular communication about the importance of compliance is part of this commitment. It is important that the culture allows for open communication about compliance, and that employees are encouraged to come forth promptly to discuss any problems with compliance. Clause 7.3  Awareness is also relevant in this regard since it sets requirements for creating awareness about compliance with the environmental policy as well as implications of not meeting compliance organization, by the organization’s employees as well as third parties such as temporary workers.

Employee awareness and involvement can be encouraged by:

• Oral and written communication from top management reiterating the importance of compliance, and the progress made in this area.
• Making this a regular agenda item in meetings.

2. Determining Compliance Obligations

The organization must determine and have access to the compliance obligations related to its environmental aspects. It must determine how these compliance obligations apply to the organization. It must take these compliance obligations into account when establishing, implementing, maintaining, and continually improving its environmental management system. Compliance obligation can be a voluntary commitment based on a determination of relevant interested parties and their relevant requirements. Voluntary commitments become obligatory once adopted. The organization must evaluate compliance at predetermined frequencies and take necessary action to address actual or potential non-compliance. It must maintain knowledge and understanding of compliance status. In addition to periodic audits such as Site inspections/observations and Review of records, the organization must also compare results of monitoring to regulatory requirements.

The organization must identify legislation and regulations that apply to it, meaning that they relate to the organization’s environmental aspects. On the basis of the organization’s process steps/ operations/present facilities, an evaluation is made of which legislation and regulations may apply. Sometimes legislation and regulations only apply if a particular limit or threshold is exceeded, for example, the presence of certain quantities of certain substances. It is then important:

• to document why the legislation and regulations in question are applicable (or not);
• in the case of ‘critical limits’, to ensure that limits are not exceeded, or if they are exceeded, that timely action is taken.

It must be realized that some legislation and regulations will be more clearly applicable and some less. An organization must also have an intention to be familiar with, and to comply with, less obvious legislation and regulations. The organization can fairly be expected to be familiar with all the applicable legislation and regulations. The overview of legal requirements must be kept up to date, even when there are changes to legislation. Organizations must, therefore, keep track of these changes and evaluate how they may affect areas such as operational control, as well as measuring and monitoring and any objectives enshrined in a process,  are:

• who keeps track of changes in requirements of compliance obligations;
• what sources of information are used;
• how often this is done;
• who translates this information into requirements for the organization, and how;
• how this is recorded;
• how changes are communicated internally;
• who determines how, and how often, compliance with the requirements is checked.

It is important that the person responsible for keeping track of and evaluating Compliance obligations including legislation and regulations requirements and other related requirements is also competent to do so. Competence includes knowledge of:

• the processes in the organization related to legislation and regulations requirements and other requirements;
• the main thrust of the various kinds of legislation and regulations that can apply.

Often there are several officials/departments in an organization who play a part in this process, such as HRM for health-related legislation, Technical Services for inspection requirements and relevant technical standards, a QES department for general legal changes, and possibly a legal/accounting department for insurance conditions, etc. Good working relationships and laying down who does what can make these things clearer. With regard to keeping track of changes in requirements of Compliance obligations, there must also be a regular check to see if the applicable requirements still fit the environment and the company’s operations. New or different requirements may apply due to changes in, or of, operations. There may also be requirements that no longer apply. If desired, evaluating the implications of legislation and regulations on new operations or changes can be a part of a Management of Change Process.

3.Translating requirements of compliance obligations into impact on the organizations

Once an organization is aware of its compliance obligations, it will be necessary to ‘unravel’ them to find the specific requirements that affect it. An organization can only make a pronouncement about its own compliance if these requirements are made explicit. This is a time-consuming (albeit one-time) operation, especially for organizations subject to many laws and regulations. Ultimately, however, it has great added value. It must be clear how these Compliance obligations impact the organization, for example:

• impact of  legislation and regulations on the organization
• Technical provisions that must be made;
• Organizational measures required;
• Emissions that must be kept below certain levels;
• Studies that must be done;
• Notifications that must be made;
• Obligatory monitoring, and monitoring reports.

Besides determining its compliance obligations, an organization must identify and evaluate its environmental aspects. The organization’s operations/processes will dictate the line of approach. Making this identification usually shows a connection between the applicable compliance obligation requirement and the personnel responsible. The organization can opt to combine the translating of all the legal requirements into their impacts on the organization with the identifying of its environmental aspects. If it does so, it is important to ensure that all legislation and regulations have been adequately incorporated. Ultimately, the responsibilities and tasks with regard to such things as legal and other requirements come together in the job descriptions, procedures, and/or operational instructions. When identifying both environmental aspects and legislation and regulations, items in a specific job or task descriptions or procedures/ operational instructions can be numbered and referred to

4. Ensuring that organizational and technical measures are taken in order to comply with the requirements

Once the organization knows which requirements apply, it determines how each requirement will impact it and what measures and actions are necessary to comply with the requirements. If a requirement has not yet been met, an action must be defined in the organization’s environmental program to achieve compliance with it (this program may be annually updated). It may be necessary to notify and confer with the competent authority to define this action. The next step is to ensure that these measures and actions are actually taken. Doing so properly guarantees that the requirement is met even in between compliance checks. The method of ensuring compliance depends on the type of requirement for the organization. There are roughly four types of requirements:

• ‘Static’ requirements: requirements for parts of the organization that do not change often, such as requirements for a building (fire-proof doors, presence of a sprinkler system, etc.).
• Technical requirements: requirements for technical measures and maintenance.
• Performance and monitoring requirements: requirements that entail taking measurements (of concentrations, annual obligations or amounts), keeping records or drawing up reports (including reports, measurements and studies by third parties).
• Organizational requirements: for matters such as training and instructing personnel.

Other methods for guaranteeing compliance include:

• a checklist which is gone through at defined intervals;
• frequent measuring, recording and reporting (these can be kept up to date in a register or overview of measurements, records, and reports);
• laying down the method in procedures or instructions which are ensured by means of internal audits;
• translating requirements into action linked to officers and recording these actions once carried out.

The severity of these measures is proportional to the risk of nonconformities. The degree of guarantee must be heavier as the risks increase. The risk has often already been determined in the identification and evaluation phase. The management system can include an overview by the element of how compliance was ensured. If there are changes to legislation and regulations it will be easy to find what parts of the management system must be adapted.

5. Self-assessing Compliance

The essence of this element is that an organization must be able to say with conviction that it has met its compliance obligation including legislation and regulations under control. It is difficult to guarantee that all legislation and regulations are being complied with at every moment. Round-the-clock monitoring of all the requirements is impossible. A focused approach should enable the organization’s management to have confidence that there is a high level of compliance and that any nonconformities are resolved (where necessary, in consultation with the competent authorities). Assuming that the organization knows which requirement of compliance obligation including legislation and regulations apply, and has translated requirements they contain into their impacts on it, it can get a structural idea of its own compliance by taking the following steps. This means that there is an established process for this self-evaluation.

1. The approach depends on the number of requirements

If the number of requirements of Compliance obligations is limited, a checklist can be used for a periodic check that the requirements are being met. The management system can designate who fills out the checklist and at what intervals, how the results are reported to management, and how the rectification of nonconformities is ensured. If the number of requirements is greater, it is a good idea to establish principles for the frequency with which compliance with the individual requirements is evaluated. This frequency will depend on factors like the chance of nonconformity with the requirements and any consequences of nonconformity. Using these general principles as a basis, an organization can determine the appropriate frequency and method of evaluation for each requirement.

2. Basis of the approach
To determine how and how often compliance with particular requirements should be evaluated, there must be an idea of:

• The chances of nonconformity with these requirements arising.
• The potential consequences of such a nonconformity for the environment or working conditions.

There is a relationship here with the requirement from the standard to identify and evaluate the environmental aspect. The organization can apply the risk assessment when identifying its environmental aspects. The outcome of the risk assessment can be used to determine how strictly to specify the evaluation of compliance with legislation and regulation for a particular environmental aspect. An organization can establish a few basic principles for specifying how it evaluates its own compliance. This can be done using the matrix also used for the risk assessment. Each organization can use its own categories for chances and effect.

Example of principles for specifying self-evaluation of compliance

The higher the risk becomes, the more often the self-evaluation must be performed. It must be clear how compliance is evaluated for each requirement. This means that it is known:

• Who is responsible for carrying out the evaluation;
• What is evaluated (for example which rules or checklist, etc.);
• How to record that the evaluation has been done, and how any nonconformities are dealt with.

Evaluating compliance can take various forms, including:

• as part(s) of a checklist used for routine checks;
• periodic agenda point(s) during meetings;
• continuous or periodic measuring program and reporting results;
• incidental measurement;
• specific evaluation by management/production manager etc.;
• internal audits with an additional audit focused specifically on the process of identifying and complying with legal requirements;
• workplace inspections.

3.Checking compliance with legal and other requirements
According to the standard, the organization must periodically evaluate whether it is meeting these requirements and must keep records of this evaluation. The frequency of this evaluation can differ for each requirement. The organization must determine how often to evaluate the various requirements and how to perform the evaluation.

6. Internal Audit

During internal audits, the organization itself determines how the parts of its management system are working. The question is also whether the management system is good enough to achieve its objectives. One important objective is to comply with compliance obligations. The internal audit yields essential information for the management review. Sometimes people think that internal audits can be used to perform the ‘self-evaluation. This is only possible to a limited degree. Since the internal audits are intended to evaluate the organization’s own system, they also test the effectiveness of the procedures for self-evaluating compliance. Compliance can only be evaluated using internal audits if requirements from legislation and regulations are embedded in procedures or instructions.

7. Management review of Compliance

The results of the evaluation of compliance must be available during the management review. If management is to make a judgment of compliance, they must be given an overview of performance. For top management, it is in any case important to know for which Compliance including legislation and regulations requirements is critical and/or insufficient and what measures need to be taken (if necessary) to improve compliance. The cause of any nonconformity is also investigated so as to formulate corrective action.

Compliance Obligation in relationship to the other parts of the management system

We shall now discuss the part of ISO 14001:2015 standards having a direct reference to compliance Obligations. Other parts of the management system are also important for proper compliance. A brief indication of their relationship to compliance follows, in order of the elements of the standard.

Relationship of elements of ISO 14001:2015 standard relevant for compliance management.

1.0 Scope:

Consistent with the environmental policy, the intended output of the environmental management system includes fulfillment of compliance obligations.

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

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 changes in compliance obligations.

4.2 Understanding the needs and expectations of interested parties

The organization shall determine which of the relevant needs and expectation of the interested parties relevant to EMS become its compliance obligations. 

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

An organization is expected to gain a general (Le. high-level, not detailed) understanding of the expressed needs and expectations of those internal and external interested parties that have been determined by the organization to be relevant. The organization considers the knowledge gained when determining which of these needs and expectations it has to or it chooses to comply with, i.e. its compliance obligations.
Interested party requirements are not necessarily requirements of the organization. Some interested party requirements reflect needs and expectations that are mandatory because they have been incorporated into laws, regulations, permits, and licenses by governmental or even court decisions. The organization may decide to voluntarily agree to or adopt other requirements of interested parties (e.g. entering into a contractual relationship. subscribing to a voluntary initiative). Once the organization adopts them, they become organizational requirements (i.e. compliance obligations) and are taken into account when planning the environmental management system.

4.3. Determining the scope of the environmental management system

The organization shall determine the boundaries and applicability of the environmental management system to establish its scope. When determining this scope, the organization shall consider the compliance obligations referred to in Clause 4.2

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

In setting the scope. the credibility of the environmental management system depends upon the choice of organizational boundaries. The organization considers the extent of control or influence that it can exert over activities, products, and services considering a life cycle perspective. Scoping should not be used to exclude activities, products, services, or facilities that have or can have significant environmental aspects, or to evade its compliance obligations. The scope is a factual and representative statement of the organization’s operations included within its environmental management system boundaries that should not mislead interested parties.

5.2  Environmental  policy

Top management shall establish, implement and maintain an environmental policy that, within the defined scope of its environmental management system includes a commitment to fulfill its compliance obligations.

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

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 the fulfilment of the compliance obligations;
• correct nonconformities

6.1 Actions to address risks and opportunities – 6.1.1 General 

When planning for the environmental management system, the organization should consider compliance obligations  to be addressed to:

• give assurance that the environmental management system can achieve its intended outcomes;
• prevent or reduce undesired effects, including the potential for external environmental conditions to affect the organization;
• achieve continual improvement. 

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

The overall intent of the process established in clause 6.1.1 is to ensure that the organization is able to achieve the intended outcomes of its environmental management system, to prevent or reduce undesired effects. and to achieve continual improvement. The organization can ensure this by determining its risks and opportunities that need to be addressed and planning action to address them. These risks and opportunities can be related to environmental aspects, compliance obligations, other issues, or other needs and expectations of interested parties.
Compliance obligations can create risks and opportunities. such as failing to comply (which can damage the organization’s reputation or result  in legal action) or performing beyond its compliance obligations (which can enhance the organization’s reputation)

6.1.4 Planning action

The organization should plan to take actions to address its compliance obligations;

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

The organization plans, at a high level, the actions that have to be taken within the environmental management system to address its significant environmental aspects, its compliance obligations, and the risks and opportunities identified in 6.1.1 that are a priority for the organization to achieve the intended outcomes of its environmental management system.

6.2.1 Environmental objectives

The organization should establish environmental objectives at relevant functions and levels, taking into account the organization’s significant environmental aspects and associated compliance obligations, and considering its risks and opportunities.

7.2 Competence

The organization should  ensure that f personnel doing work that affects its environmental performance under its control have the necessary competence  to fulfil its compliance obligations;

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

The competency requirements of this International Standard apply to persons working under the organization’s control who affect its environmental performance, including persons:
a) whose work has the potential to cause a significant environmental impact;
b) who are assigned responsibilities for the environmental management system, including those who:
1] determine and evaluate environmental impacts or compliance obligations;

7.3 Awareness

The organization should ensure that persons doing work under the organization’s control are aware of the implications of not conforming with the environmental management system requirements, including not fulfilling the organization’s compliance obligations.

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

Awareness of the environmental policy should not be taken to mean that the commitments need to be memorized or that persons doing work under the organization’s control have a copy of the documented environmental policy. Rather, these persons should be aware of its existence, its purpose, and its role in achieving the commitments, including how their work can affect the organization’s ability to fulfill its compliance obligations.

7.4 Communication

The organization shall establish, implement and maintain the processes needed for internal and external communications relevant to the environmental management system, when establishing its communication processes, the organization shall take into account its 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.

9.1 Monitoring, measurement, analysis and evaluation

The organization shall communicate relevant environmental performance information both internally and externally, as identified in its communication processes and as required by its compliance obligations

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

When determining what should be monitored and measured, in addition to progress on environmental objectives, the organization should take into account its significant environmental aspects, compliance obligations, and operational controls.

9.1.2 Evaluation of compliance

Once the Compliance obligation has been determined, the organization should establish, implement and maintain the processes needed to evaluate fulfillment of its compliance obligations. The organization should determine the frequency from evaluation of compliance, action taken from evaluation of compliance, and maintain knowledge and understanding of its compliance status. The organization should retain documented information as evidence of the compliance evaluation results.

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

The frequency and timing of compliance evaluations can vary‘ depending on the importance of the requirement, variations in operating conditions, changes in compliance obligations, and the organization’s past performance. An organization can use a variety of methods to maintain its knowledge and understanding of its compliance status, however, all compliance obligations need to be evaluated periodically. If compliance evaluation results indicate a failure to fulfill a legal requirement, the organization needs to determine and implement the actions necessary to achieve compliance. This might require communication with a regulatory agency and an agreement on a course of action to fulfil its legal requirements. Where such an agreement is in place, it becomes a compliance obligation.  A non-compliance is not necessarily elevated; to a nonconformity if, for example, it is identified and corrected by the environmental management system processes. Compliance-related nonconformities need to be corrected, even if those nonconformities have not resulted in actual non-compliance with legal requirements. 

Explanation:

9.3 Management Review

The management review should include the changes in the needs and expectations of interested parties, including compliance obligations. the management review should also include information on the organization’s environmental performance including fulfillment of its compliance obligations.

Definition of Life Cycle

The definition of the life cycle as per ISO 14001:2015 is Consecutive and interlinked stages of a product (or service) system, from the raw material acquisition or generation from natural resources to final disposal. Life cycle stages include the acquisition of raw materials, design, production, transportation/delivery, use, end-of-life treatment, and final disposal.
According to ISO 14001:2015 ,(0.2 Aim of an environmental management system) Life cycle perspective is “A systematic approach to environmental management can provide top management with information to build success over the long term and create options for contributing to sustainable development by controlling or influencing the way the organization’s products and services are designed, manufactured, distributed, consumed and disposed by using a life-cycle perspective that can prevent environmental impacts from being unintentionally shifted elsewhere within the life cycle“.

A system or life cycle can begin with extracting raw materials from the ground and generating energy. Materials and energy are then part of manufacturing, transportation, use, and eventually recycling, reuse, or disposal. In the context of this standard, the term life cycle refers to the consecutive and interlinked stages of a product system from the acquisition of raw materials to end-of-life disposal. A life cycle perspective means we recognize how our choices influence what happens at each of these points so we can balance trade-offs and positively impact the economy, the environment, and society. A life cycle approach is a way of thinking which helps us recognize how our selections – such as buying a new machine or a raw material – are one part of a whole system of events. A life cycle perspective identifies both opportunities and risks of a product or technology, all the way from raw materials to disposal. To do this there is a continuum of life cycle approaches from qualitative (life cycle thinking) to comprehensive quantitative approaches (life cycle assessment studies). People, companies, and governments use these various life cycle perspective in anything from day to day shopping, selecting office supplies for the workplace, engineering new product design, or developing new government policy. The life cycle a product system includes all associated activities, products, and services and may include procured goods and services as well as end-of-life treatment, decommissioning, and disposal. A life cycle perspective includes consideration of the environmental aspects of an organization’s activities, products, and services that it can control or influence. Stages in a life cycle include acquisition of raw materials, design, production, transportation/delivery, use, end of life treatment, and final disposal. When applying a life cycle perspective to its products and services, the organization should consider the following:

• the stage in the life cycle of the product or service,
• the degree of control it has over the life cycle stages, e.g. a product designer may be responsible for raw material selection, whereas a manufacturer may only be responsible for reducing raw material use and minimizing process waste and the user may only be responsible for use and disposal of the product,
• the degree of influence it has over the life cycle, e.g. the designer may only influence the manufacturer’s production methods, whereas the manufacturer may also influence the design and the way the product is used or its method of disposal,
• the life of the product,
• the organization’s influence on the supply chain,
• the length of the supply chain, and
• the technological complexity of the product.

The organization can consider those stages in the life cycle over which it has the greatest control or influence as these may offer the greatest opportunity to reduce resource use and minimize pollution or waste.

A Life-Cycle perspective Promotes

• Awareness that our selections are not isolated, but influence a larger system. Buying office paper is a good example. If you knew that it takes 24 trees to create 50,000 sheets of office paper and 2.3 cubic meters of landfill space to dispose of it, you might choose paper made from recycled material and elect to support paper producers that source from sustainably managed forests.
• Making choices for the longer term and considering all environmental and social issues associated with those. Life cycle thinking helps us avoid short term decisions that lead to environmental degradation – such as over-fishing or polluting our air with mercury.
• Improving entire systems, not single parts of systems, by avoiding decisions that fix one environmental problem but cause another unexpected or costly environmental problem. Life cycle thinking helps avoid shifting problems from one life cycle stage to another, from one geographic region to another and from one environmental medium (air, water or soil) to another.
• Informed selections, but not necessarily ‘right’ or ‘wrong’ ones. Life cycle thinking simply helps us put our decisions in context with facts from all parts of the system or life cycle. It means we look for unintentional impacts of our actions (such as damaging a natural eco-system or inadvertently supporting unfair labour conditions and wages) and take some action to prevent those impacts (such as purchasing office paper from sustainably managed forests or coffee certified “fair trade”). For instance, if the shop around the block from your office sells coffee grown by workers who receive a fair wage on the world market, cultivated without pesticides that harm people planting or harvesting the beans and from a plantation that did not cause an endangered forest to be chopped down, you might choose to purchase your daily cup from that shop.

Why consider life cycle perspective?

The reason according to ISO 14001 (A.8.1 Operational planning and control) is that ‘Some of the organization’s significant environmental impacts can occur during the transport, 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.‘ The organization considers the extent of control or influence that it can exert over activities, products, and services considering a life cycle perspective.

Today organization and its employees in design, sales, and finance make many choices to balance customer satisfaction, quality, innovation, safety, costs, and more. Thinking in terms of the life cycle, businesses recognize that each choice sets the stage for not only how the product will look and function, but also for how it will impact the environment and the community as it is manufactured, used, disposed, or re-used and recycled. For example, washing machines, refrigerators, and other appliances can be made from recycled materials, be free of harmful substances, use minimal water and energy, and be designed to have a long life. Each product characteristic is determined when the product is designed and will impact the environment differently.

Products can be designed so they will have a less environmental impact when they are manufactured, used, and discarded. Today, refrigerators are made without CFC refrigerants that harm the ozone layer, and some models are also designed to use half as much energy as they did 10 years ago.

To make decisions during product design, organization research where the raw materials might come from, which manufacturing processes may be needed, who will use the product, what type of maintenance and cleaning might be required, what types of waste will be created, and where the product will go when it is discarded. To find this out, designers conduct life cycle studies and measure the potential impacts of various options. (Example: The German carpet producer Donau-Tufting GmbH conducted a life-cycle study of their carpet production. Based on what the study found, Donau-Tufting decided to remove heavy-metal colourings and vulcanization chemicals from the carpets they make. The company gained an advantage in the market over its competitors, as the new carpet achieved an additional 25% turnover.).
The organization can also request such information from suppliers. With life cycle information, companies are able to calculate the full life-cycle cost of the goods they purchase. This includes the point-of-purchase price as well as the costs of transporting, storing, installing, cleaning, operating, repairing, and eventually discarding those goods – also known as the ‘total cost’ of owning that product (Example: A business which makes industrial cleaners worked with its chemical supplier to identify the life cycle costs of manufacturing, purchasing, using, and disposing of the chemicals supplied. Together, they used the results to identify changes in the formulation of the cleaner to reduce these costs. Next, the business approached its customer who purchases the cleaner to wash buses, subway cars, and train cars. The business calculated that this customer was paying not only for the cleaner, but also for water use, cleaner spilt during use, and unused cleaner discarded as residue in each packaging container. This customer also paid fees for special handling, storage, worker training, and reporting on the use of the cleaner to comply with laws and regulations. But so far this customer had never measured these costs or connected them with its choice of cleaner. Seeing an opportunity to work with its customer, the business designed a cleaning “system” to deliver cleaner to customers in one large container, connect it to a hose, mix it with the exact amount of water, and apply it directly to the buses, subways, and train cars. The system would use less water and less clean, eliminate handling and storage, and ensure cleaner wasn’t lost as residue in packaging or as “waste” to the environment from spills. By managing all life cycle issues, the system reduces the customer’s costs, manages risks to worker health and safety, mitigates environmental impacts, and provides a longer-term contract for the business.)
A product designed with better environmental, social and economic performance across its life cycle may have benefits the company can communicate to its customers. Some businesses elect to use product declarations or other labels to market environmental and social attributes to their customers. There are international standards for these business-to-business communications or “environmental product declarations”. Each declaration must be based on a life cycle study and tell the business customer about the life cycle environmental impacts of the component or product being purchased. Declarations exist for building and construction products, refrigerators and other appliances, chemicals, train cars, dairy products, and circuit breakers, to name a few. Life cycle thinking that influences product design, strategic planning, procurement, and sales help businesses:

•  Enhance their image and the value of their brands. The organization can avoid criticism and participate in issues abroad or beyond their direct sphere of influence. Financial indices such as the Dow Jones Sustainability Indexes (DJSI) track and report the financial performance of leading sustainability-driven businesses, worldwide.
• Find new ways for marketing and sales departments to communicate and interact with customers – some fifty percent of the organization say they are interested in learning about sustainability. This means a company can promote its products and services by talking about its social and environmental attributes.
• Share lifecycle information with suppliers, customers, and waste handlers to identify risks and opportunities for improvement – the risks might relate to the environment, human health, safety, and finance, while opportunities could include growing market share, brand image, effective use of materials, and innovation. Together, businesses can find new ways to improve output while optimizing their use of time, money, labour, and material input

Providing Life Cycle Information to Customers

Market interest in environmental information on products that is credible, unbiased, verifiable, and covers the entire life cycle is growing. To be complete, the information should cover the product life cycle from acquiring raw materials to recycling those materials when the product is no longer in use. Environmental product declarations (EPDs) are meant to provide this type of information in business-to-business communication, promoting “green procurement” in the business and public sectors. Companies use EPDs to communicate their product’s environmental performance. ABB, a global manufacturer of power and automation technologies for utility and industry customers, has more than 40 EPDs for a range of its products. EPDs include information about any hazardous substances, disassembly, recovery, and recycling of used products and waste. Quantified life cycle information from an EPD is also a necessary input for many ABB customers working to modify and improve the environmental performance of their products and services through eco-design and innovation

Is Life cycle assessment a requirement in ISO 14001:2015?

No, it is not a requirement as clearly stated in Annex to ISO 14001 (A.6.1.2 Environmental aspects): ‘When determining environmental aspects, the organization considers a life cycle perspective. This does not require a detailed life cycle assessment; thinking carefully about the life cycle stages that can be controlled or influenced by the organization is sufficient. Typical stages of a product life cycle include raw material acquisition, design, production, transportation/delivery, use, end-of-life treatment, and final disposal. The life cycle stages that are applicable will vary depending on the activity, product or service.‘

The inclusion of life cycles in ISO 14001:2015 doesn’t mean an intricate and heavily detailed analysis. The standard even goes so far as stating in Annex A that a detailed life cycle assessment is not required “…. thinking carefully about the life cycle stages that can be controlled or influenced by the organization is sufficient “.
It calls this lower level approach taking a life cycle ‘perspective’ rather than an ‘assessment’ and the difference is an important one. One of the differences in the extent of an organization’s ‘control’ or ‘influence’ over the various life cycle stages and how that extent will be a crucial factor in the breadth of the perspective considering the whole cycle. Thinking about the practical limits of where an organization can directly control matters, where it can influence them and where that influence begins to have little or no effect will certainly force clarity on the scope of the exercise and on the environmental management system (EMS). Even though the standard is clearly steering organizations away from a detailed life cycle assessment in the initial stages, the top-level exercise like the one being promoted can still reap benefits (for example, new design possibilities, energy savings, synergies in the supply chain). Any more detailed follow-up analysis, however, is in the hands of the organization itself and can’t be ‘demanded’ by an auditor or driven by an external certification body. To have a perspective implies viewing something from a singular point. Therefore taking a perspective on a life cycle means viewing the entire life cycle from the position that you or your organization has within that cycle and capturing the unique properties of such a view.
Finally, the whole point of a cycle is that it repeats itself, otherwise it is not cyclical. No two cycles repeat themselves in exactly the same way or result in the same outcome. Life cycles of similar products might look the same on the surface, but underneath, the environmental impacts could vary widely. The real key to unlocking the benefits of taking a life cycle perspective lies in how it enhances the various parts of your existing EMS. These benefits are less reliant on the level of detail but hinge more on the sensible use of the information generated. More data may not mean more information. To understand how this might work in practice, we need to look in more detail at how life cycle thinking can affect individual elements of your existing EMS and the most obvious initial point of impact on an EMS is in the steps required to establish an organization’s operating and commercial context. Even though a formal life cycle assessment is not a requirement for your EMS, understanding the life cycle of your product or service is necessary to get the job done. This needs to include all aspects of your product life cycle such as product packaging, packaging for shipment, and even the final disposal of your product.

ISO 14001 key requirements that refer to the life cycle perspective are:

I Scope

“This International Standard is applicable to any organization, regardless of size, type and nature, and applies to the environmental aspects of its activities, products, and services that the organization determines it can either control or influence considering a life cycle perspective.”
There’s more to understanding an organization’s effective reach than direct managerial control of activities. As per ISO 14001:2015 (A.4.3 Determining the scope of Environmental management system ) “In setting the scope, the credibility of the environmental management system depends upon the choice of organizational boundaries. The organization considers the extent of control or influence that it can exert over activities, products, and services considering a life cycle perspective.”
No organization exists in a vacuum but is part of a complex web of buying, selling and exchanging. At each transactional point, there’s an opportunity to make a decision that favours minimization of negative or promotion of positive environmental impacts. Until now, most organizations have looked at the minimum starting point of what is in their direct control; an approach that tends to focus on the physical boundaries of an operational site and everything inside that perimeter. Many have not progressed much beyond that view. Some might have revisited the scope due to managerial or operational changes, some may even have embraced the idea that sourcing raw material can benefit from the attention of an environmental manager, revealing the power of a procurement policy that brings financial as well as reputational benefits. All these management system scopes have their advantages, but they are all dogged by a conscious decision to take a limited view of the whole. The obvious next step is to relate the scope of your existing EMS to the number of stages in the life cycle of your product or service. Usually, this will be no more than one or two if you are thinking about direct control in relation to the responsibility; looking at the stages immediately adjacent and either side of your operations and the potential for influence can be an eye-opening experience for many. In such cases, life cycle thinking, whether prompted by internal initiatives, external product or material related legislation, has given new ideas, flushed out new opportunities, new challenges and revealed hitherto unforeseen exposures to risk. Ultimately this is more than a choice about credibility, reputation or corporate social responsibility. Taking this approach increases an organization’s resilience, continuity, risk management and the promotion of innovation through opportunity identification and realization. If an organization needs to demonstrate that they are taking the ‘life cycle perspective’ requirement into account, they may also need to account for any obvious disparity between an EMS scope and the specific characteristics of the life cycle involved. So, for example, if areas out of the scope for EMS purposes such as suppliers, transport or end-user disposal remain out of scope, the conscious decision taken to exclude such factors may need supporting with further evidence

6.1.2 Environmental aspects

“Within the defined scope of the environmental management system, the organization shall determine the environmental aspects of its activities, products, and services that it can control and those that it can influence, and their associated environmental impacts, considering a life cycle perspective.”
Looking at the requirement in Clause 6.1.2 one can see that the three elements that have to work together are control, influence and life cycle. They should come from a consistent position and inform one another on an ongoing, dynamic basis. New information or a change in one should lead to the changes being reflected in the others. In turn, the system overall should reflect the decisions taken with regard to the amount of control and influence that can be exercised, and how far upstream and downstream of operations it can be usefully applied. Even more importantly, the process of identification and evaluation of significant aspects should also be based on that same life cycle perspective. If it has not been previously applied to that process, it may change the overall significance rating, with new aspects added to reflect the increased sphere of influence being considered. It can’t be overemphasized that this evaluation of aspects is a core element of the system. If the process does not accurately reflect the management system scope or has an evaluation structure that is not consistently applied across all the potential aspects and impacts, the rest of the system is unlikely to rectify such problems. An extension of scope and a willingness to start exercising influence through buying habits, information giving or rethinking design elements of a product are all good decisions in themselves but any such changes will need to be consistent with the identified and relevant environmental aspects as well. The outputs from the evaluation of aspects and impacts will need a further examination for risks and opportunities in order to meet the requirements of Clause 6.1.1. At the same time, these are added to a consideration of the risks and opportunities related to contextual issues identified in Clause 4.1. All of which means that any change prompted by the life cycle perspective already discussed in relation to these earlier clauses should show up throughout the planning process.
So, in summary, when identifying the environmental aspects of your product or service, you need to consider the entire life cycle of the product or service, and during your design and development of the product and service, you need to identify what operational controls you will put in place to address any significant environmental aspects. Here are some examples of environmental aspects and operational controls that might not have been captured with the current requirements of ISO 14001:

• At the end of life, is there a way to recycle your product? Even if there is, could you recycle the product better and re-use some materials? Many companies are starting to have products returned at the end of life to be properly recycled, such as paint at hardware stores or electronics at special electronic recycling depots. This allows for better and more environmentally friendly recycling with the possibility of reclaiming materials for reuse.
• For a product made of plastic, have you considered the type of plastic it is made of? Could the product be made of a material that is more easily recycled at the end of life? Could it be made of a material that can be reused rather than recycled?
• When packaging your product, what are you using? If you are packaging in a large plastic container, could the container size be reduced, or the material changed to something that does not use a non-renewable natural resource?
• For delivery service, have you considered your packing materials and how they impact the environment?  Instead of plastic packaging material, have you considered biodegradable material made from corn starch or another material? Some companies are even using popcorn as a packaging material, which is easily biodegraded.
• Have you considered the impact of your recycling partners? Remember that you need to consider environmental aspects that you can influence, as well as those you can control. This means that choosing a metal recycling company that is closer to your facility could be more environmentally friendly that one that is far away, due to the distance the trucks would have to travel.
• Have you considered the impact of your delivery partners? How often does your delivery company maintain its vehicles? Is there an alternate company that has cleaner-burning delivery vehicles? Identifying how your delivery company impacts the environment and making your choices accordingly is one way that you can influence the impacts of these environmental aspects.

8.1 Operational Planning and Control

”Consistent with a life cycle perspective, the organization shall:
establish controls as appropriate to ensure that its environmental requirement(s) are addressed in the design and development process for the product or service, considering each stage of its life cycle;
determine its environmental requirement(s) for the procurement of products and services as appropriate;
communicate its relevant environmental requirement(s) to external providers, including contractors;
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 outputs from all the planning turn into the reality of day-to-day operations. Thus the life cycle perspective gets a specific mention in the major ‘doing’ clause where the interface between the plan and the complexity of operations is manifested in a series of controls. Planning and designing those controls is an art in itself, especially where there is no direct employee of the organization involved, where the process might be outsourced, or where the control is shared between the organization and a supplier or contractor. Deciding at what point control becomes influence can also be another important consideration in ensuring that the management of individual processes is consistent, thorough but not constrictive. Here, consistency with the outputs of the earlier life cycle thinking can shed light on areas that may formerly have been considered indistinct or that have traditionally benefitted from a simple functional approach. In many cases, it highlights areas where the levers of influence lie. Life cycle work can point out where

• purchasing policies need support with enough details so that it’s possible to go beyond lip service,
• service level agreements can be drawn up informed by the chance to access and manage both risks and opportunities,
• potential contract variations with contractors and suppliers can be revisited for mutual benefit, and
• outsourcing processes have or can deliver benefits other than reduced costs by releasing new and improved levels of environmental or resource-related performance, still measurable in financial terms

Practical help – Life cycle perspective

A life cycle perspective includes consideration of the environmental aspects of an organization’s activities, products, and services that it can control or influence. Stages in a life cycle include acquisition of raw materials, design, production, transportation/delivery, use, end of life treatment, and final disposal. When applying a life cycle perspective to its products and services, the organization should consider the following:

• the stage in the life cycle of the product or service,
• the degree of control it has over the life cycle stages, e.g. a product designer may be responsible for raw material selection, whereas a manufacturer may only be responsible for reducing raw material use and minimizing process waste and the user may only be responsible for use and disposal of the product,
• the degree of influence it has over the life cycle, e.g. the designer may only influence the manufacturer’s production methods, whereas the manufacturer may also influence the design and the way the product is used or its method of disposal,
• the life of the product,
• the organization’s influence on the supply chain,
• the length of the supply chain,
• the technological complexity of the product.

The organization can consider those stages in the life cycle over which it has the greatest control or influence as these may offer the greatest opportunity to reduce resource use and minimize pollution or waste.

Life Cycle Tools

Life cycle thinking can be put into practice in many ways… involving a number of different “tools”. Referring to eco-labels, sustainability indices, and company reports on environmental and social issues help individual citizens bring life cycle thinking into purchasing decisions. Governments take a life cycle approach to policy-making by involving a wide range of stakeholders (such as via Product Panels), life cycle modelling, or new policy approaches (such as Integrated Product Policy). In private sector companies, engineers and designers apply life cycle thinking when designing products and services, via studies based on Life Cycle Assessment), Total Cost of Ownership calculations, Design-for-Environment programs and management systems oriented toward products or facilities. Quantitative and qualitative tools for mapping life cycles and measuring impacts continue to evolve as more professionals apply life cycle thinking and ask for life cycle information.
Life Cycle Assessment (LCA), Design for Environment (DfE), Product-Service Systems (PSS) & Integrated Product Policy (IPP) are all responses to the identified need for a paradigm shift in our approach to achieving sustainable development – each builds on the concept of life cycle thinking.