Module -3 Environmental Management System

EMAS, ISO 14000 - EMS as per ISO 14001– benefits and barriers of EMS – Concept of
continual improvement and pollution prevention – environmental policy – initial
environmental review – environmental aspect and impact analysis – legal and other
requirements- objectives and targets – environmental management programs – structure and
responsibility – training awareness and compétence- communication – documentation and
document control – operational control – monitoring and measurement – management review

EMAS (ECO-MANAGEMENT AND AUDIT SCHEME )

 It is one of the Voluntary instruments of environmental protection, i.e., it positively
motivates organizations to responsible approach and to improving its environmental
performance beyond the legal requirements
 Established by the European Union in order to detect and monitor the impacts of the
activities of organizations on the environment and to publish information in the form
of individual environmental statements
 EMAS is a proactive approach of the company to monitoring, control and gradual
reduction of the impact of the activities of the organization on the environment.
EMAS
 It is designed for organizations functioning in the private sector (joint stock
companies, limited liability companies, etc.) as well as for organizations of state and
public administration (ministries, municipalities, etc.) or its parts (producing unit,
remote workplaces).
 EMAS system is one of two ways which an organization can use to implement the
EMS
 The second tool used to implement the environmental management system is ISO
 Both ways are similar to each other in many parts - environmental policy, continuous
improvement, objectives and target values, programs, the implementation of the
system and its operation, monitoring, and management review
 EMAS, however, extends the ISO 14001 system, especially in terms of transparency
when organizations with an established system according to EMAS are obliged to
publish environmental statements and hold open discussions with the public and other
interested parties
ISO 14001
 The ISO 14001 standard defines EMS as “that part of the overall management system
which includes the organizational structure, planning activities, responsibilities,
practices, procedures, processes and resources for developing implementing,
achieving, reviewing and maintaining the environmental policy”
Components of an EMS
 Four components
 It is like a cycle of plan, do, check, and act.
 If the cycle is adhered to constantly it leads to continuous improvement of the system.
 The design and implementation of an EMS requires a considerable time and effort
therefore requiring the commitment of management of the organization.
 Management needs to communicate their support to the system and emphasize that
“they aim to improve their environmental performance”.
The ‘Plan’ Phase
 This stage is helpful in the formulation of an environmental policy
 It serves the direction for future action and communication of the organization’s
environmental commitment and targets
The ‘Do’ Phase
 An organizational chart is defined and laid down at this stage in order to embed the
environmental management in the organization
 Individual roles and responsibilities are outlined in addition to the allocation of
resources like finance, personnel, skills and technology
 Next step is the identification of training needs to build environmental awareness and
competence
The ‘Check’ Phase
 This stage aims at checking how the firm performs in terms of environmental
management and if necessary, to analyze the causes of problems, identify possibilities
for improvement and take subsequent action to realize these changes
The ‘Act’ Phase
 Management review here aims at making sure that the EMS continues to produce the
desired effects as outlined in the policy
 Apart from the information derived from audits, other internal reports on
performance and incidents, external reports on regulatory and environmental changes,
and suggestions for improvement received from internal and external sources can play
a role for the organization to act upon
 The process is then repeated again. The drivers or motivations to use EMS are internal
and external involving different forces.
Benefits of ISO 14001 Certification
 EMS certification is of the management system itself, not the environmental
performance
  A company can develop EMS but will not be certified, however most companies that
develop EMS do indeed certify it
 Certification does not generate instant results
Certification of EMS ISO 14001 has the following benefits to companies:
 Prove that its activities have been evaluated and accepted by an accredited,
independent third party.
 It shows that an external ‘stamp’ of approval of the EMS has been given and that, the
organization’s commitment to improve environmental performance is valid
 Shows commitment to the protection of the Environment. Possibly, the greatest
positive impact to the environment will be in the reduction of hazardous waste
 This would apply to reduction, reuse or recycling, all of which maximize natural
resources. There is thus conservation of other natural resources in the process.
 Gives new organizations more chance with regulators that the written documentation
necessary to demonstrate compliance with the regulations will be abide by. Overall,
relations with regulators would improve after ISO 14001 certification. ‘The agency
will know the certified organization care for the environment and has systems in place
even before visiting the operation’. This positive relation is extremely valuable and
would help foster a better working relationship.
 Leads to long-term cost savings, especially in the area of environmental control and
cleanup of incidents. According to Kuhre (1995) certification will not eliminate all
cleanup cost, however, it should minimize the number and size of future cleanups.
There would also be increase in competitive position of the company. The costs
would be partially offset by ‘increased customer satisfaction, trust and moral’.
 Obviously, leads to prevention of suffering and possible death by workers due to
mishaps. The costs associated with injuries will also be reduced. Systems that protect
or minimize impacts on the environment would in most cases also minimize impact
on employees. This equates to reduced employee injuries and illness. A reduction in
 injury and illness will occur if the organization includes health and safety in injury of
ISO 14001 certification efforts in addition to EM.
 Increases public awareness in the environment as these is increasing days. If an
organization improves its EM program, it would surely improve its community
relations as well. ISO 14000 procedures are proactive environmental actions. Any
proactive action that an organization does is good for the environment and could be
communicated to the public since it is a positive venture. If the public is aware of
these attempts, their confidence in the organization will be increased.
 Creates customer trust and satisfaction. Once an organization has the ISO 14001
certification, the customer feel more secure that the environment is being catered for.
Organizations that obtain the certificate would be able to increase the market share of
their products since most customers are environmentally conscious these especially in
 advanced industrialized countries. Certification is a little more tangible than the lip
service given in many cases. ISO 14001 provides competitive edge to business
 It levels the playing field of international trade bringing more competitors to the
scene. These means companies certified to ISO 14001 have market access all over the
world. In addition employment would be created in the home country thereby
reducing unemployment thus poverty. Creating employment however does not mean
poverty reduction as people have been employed in industries but are lowly paid thus
poor.
 Insurance companies these days find it easier transacting business with companies
that have effective EMS like ISO 14001 as they view such a company as having
limited liability. Investors these days also try to invest in environment friendly
companies.
 􀂃 The standard also provides an effective means of technological development as
well as its transfer to other sectors of the industry or the organization.
Pollution Prevention and Continuous Improvement
 Pollution prevention is generally defined as “the use of processes, practices, materials,
products or energy that avoid or minimize the creation of pollutants or wastes at the
source
Pollution prevention techniques and practices focus on

•Substances of concern
• Materials and feedstock substitution
• Operating efficiencies
• On-site reuse and recycling
• Training
• Purchasing practices
• Product design
• Equipment modifications
• Product reformulation
• Process changes
• Clean production
• Avoidance of cross-media transfer of pollutants or waste
• Life-cycle assessment
Pollution Prevention Techniques and Practices
1) Materials and feedstock substitution is a method of source elimination.

 Polluting materials in a production process or embedded in a product are replaced

with less polluting or nonpolluting substances
 Opportunities for materials and feedstock substitution include:
 Painting applications
 Parts cleaning
 Metal finishing
 Printing operations
Building and grounds maintenance
2) Operating efficiencies and training are examples of how normal parts of good operation
can provide effective ways to prevent pollution.
Examples include
 Changing production schedules to minimize equipment and feedstock change overs
 Improving maintenance schedules
 Segregating by-products at the source
 Training staff to improve material handling and recognize opportunities
3) Product design and reformulation includes methods for preventing pollution associated
with the entire life cycle.
 Addressing environmental concerns at an early stage can avoid environmental impacts
throughout the product life cycle in a cost-effective manner.
 Results of redesigning or reformulating a product include
 Reducing toxicity of a product
 Reducing waste material
 Extending the life of a product
 Extending the life of the materials used
 Reducing energy and material intensity needed to produce, use and dispose of the
product
4) Equipment modifications and process changes involve new technologies or approaches
to existing operating systems processes and practices to improve production efficiencies and
reduce pollution and waste.
 An example is mechanical stripping instead of using solvents to remove paint and
varnish
5) The Value of Waste
 Waste can also be viewed as a loss of valuable process materials that could have
economic and environmental benefits if reused or recycled.
The following approaches reflect this perspective on the value of waste.
 On-site reuse and recycling is considered pollution prevention because it occurs at the
same place as the original activity.
 Reuse means using materials again in their original form or in new applications.
 Recycling extends the effective life of resources. Environmentally sound recycling is
usually preferable to end-of-pipe solutions.
 Raw materials, chemicals and treated and untreated wastewater are examples of
materials that could be reused or recycled.
Some examples of reuse and recycling are
 Recovering metals by ion exchange or reverse osmosis
 Recycling cooling water
 Reusing trim and cuttings from plastic moulding in on-site production rather than
taking them for off-site disposal
Environmental Policy:
What is an environmental policy?
 An environmental policy is a statement about an organisation's environmental
position and values
 The ISO 14001 standard states that an environmental policy is the organisation's
overall environmental performance intentions and direction formally expressed by top
management
Benefits of developing an environmental policy
 An organisation can publicly advertise that it has considered its environmental
performance and has adopted best practice or is working towards improving its
environmental performance
 It can advertise the environmental status and environmental objectives of the
organisation to all stakeholders
 Current and potential clients can read the statement and are able to determine whether
they would like to continue or start business with the organisation
 It also can provide clear direction to all stakeholders about the organisation's
environmental values
Who should develop an environmental policy?
 A senior manager or managing team should endorse the environmental policy but not
necessarily be directly responsible for developing the policy.
 Should appoint someone talented, familiar with the organisation and who has the
ability of writing interesting factual statements.
 Choose someone which can inspire and communicate the true environmental policy of
the organization
What is the usual procedure for maintaining an environmental policy?
 Similar to an environmental management system environmental policies should be
regularly be reviewed
 When there has been change or change is planned, or when there has been a
significant performance issue the environmental policy should be reviewed.
 Otherwise, more general reviews should occur periodically (e.g. annually).
What should be included in an environmental policy?
 The ISO 14001 standard is probably the best reference standard for the development
of an environmental policy.
In summary, an environmental policy must be
 Appropriate to the organisation;
  Include a commitment for continual improvement and prevention of pollution;
 Include a commitment to comply to relevant legal and other requirements; and,
 Provide the framework for setting and reviewing environmental objectives and
targets.
 Understand whether the organisation presents a direct environmental risk to their
operations;
 Understand whether the organisation presents a risk to public perception if they are
engaged;
 Understand whether the organisation present an environmental risk by not
understanding and not complying with legal & other requirements; and,
 Understand whether the organisation has any environmental programs to reduce
environmental impact and improve their environmental performance.

Initial environmental review

 Within the implementation of an environmental management system (EMS), the
initial environmental review (IER) is a first step in which a company begins to
consider systematically all the factors driving the complex relationships between its
production system and the external environment.
 The Initial environmental review's key purpose is to determine an organisation's
environmental performance. The review helps to identify and understand the
significance of environmental impacts, assist in identifying legal and other
requirements, and which current documentation is in compliance with ISO 14001.
 First step in creating an EMS is to perform an Initial Environmental Review.
 Tells where organization is and creates a road map for organization
There are four main areas:
1. Review previous environmental issues
2. Consider any regulations which have operational impact
3. Identify and evaluate possible environmental issues in organization.
4. Outline current operations and how it is managed; also consider indirect impacts

 The Initial Environmental Review does not considered an audit.

 The Environmental Review is an initial assessment to help to create an EMS.
 The Environmental Audit assesses the performance of the organizations’ EMS.
 Approach and methods
Process maps - outlines the process requirements (i.e. resources) and the outputs
including wastes, emissions and by-products that serve as a baseline for identifying
environmental aspects.

Inputs: raw materials; Outputs: emissions; by-

PROCESS
energy, resources products; wastes

Benefits of an Initial Environmental Review

Helps determine the organization’s environmental position, and should include
 Environmental statutory and regulatory requirements
 Recognize items/areas with environmental impact
 Environmental Performance Criteria
 Feedback of previous experiences
 Opportunities for improvement in-house as well as external (contractors, vendors,
etc.,)
Legal and other requirements
ISO 14001 Requirements
 The organization shall establish, implement and maintain a procedure(s) to identify
and have access to the applicable legal requirements and other requirements to which
the organization subscribes related to its environmental aspects, and to determine how
these requirements apply to its environmental aspects.
 The organization shall ensure that these applicable legal requirements and other
requirements to which the organization subscribes are taken into account in
establishing, implementing and maintaining its environmental management system.
The principles of environmental legislation and guidelines for compliance
The Law
 Not always agree with laws – but must obey
 Non acceptance of a law, or pleading ignorance of the law is no defence when it
comes to courtroom proceedings.
 For example, in the case of an adjoining river to a manufacturing site becoming
accidentally polluted, it is no defence to state that the Company was unaware that this
was an unlawful act.
 The legal system would maintain that the Company should have taken reasonable steps to
find out beforehand.
Penalties for breaking environmental laws
 Certainly there are instances of heavy financial penalties (fines) for breaches of
legislation
 Additionally, senior management individuals have been sent to prison – usually in
cases of proven negligence
 Supreme Court Judgment which states that the fines should be substantial enough to
have a real economic effect on the organization’, the purpose being to put pressure on
managers and shareholders to comply.
Concept of Strict Liability
 Offences under environmental law are subject to the concept of strict liability
 As an illustration, consider the river in previous note 1, being polluted by a large
drum of chemicals. If the reason for the incident is adverse weather conditions (storms
blowing drums over causing spillage) or even criminals or vandals
deliberately causing the spillage, then the Company is still guilty of pollution. All the
Company can do is to plead mitigating circumstances which should reduce the
severity of the fine. Such mitigating circumstances could be:
◦ Enclosed and locked storage areas for the drummed chemicals;
◦ Use of 24-hour security cameras and vandal proof fencing around the site.
Legislation – responsibility for compliance
 It is the implementing organization’s responsibility to ensure compliance with the
law.
 This responsibility cannot be passed on to a third party, for example, the auditor from
the certification body.
 The external auditor, however, must exercise due diligence and by asking questions
based upon his training, expertise, knowledge and experience, should discover if the
organization is compliant.
Determination of applicable legislation
 Legislation is publicized by governments and regulatory authorities and should be
readily available.
 Options can be access to internet sites, enquiries at government offices and reading of
appropriate trade and professional journals.
 In this way a register of legislation can be compiled.
 However, the register of legislation by itself is not sufficient.
  The client must demonstrate how each piece of legislation applies – or not – as the
case may be with reasons for inclusion or non-inclusion in the register.
 This register demonstrates that a review process has occurred by a responsible person

Objectives, targets and program(s)

Environmental objectives
 Overall environmental goal, consistent with the environmental policy that an
organization sets itself to achieve.

Environmental target
 Detailed performance requirement, applicable to the organization that arises
from the environmental objectives and that needs to be set and met in order to achieve
those objectives.
Environmental Management Programs
 Environmental management programs support the Environmental Policy and the
overall goal of reducing negative environmental impact
 Programs were established to assure compliance with federal, state, and local
environmental regulations
 Each program includes specific requirements that are documented in the EMS
Manual as well as a corresponding written plan, procedure, or instruction
Air Emissions
 Program includes performance standards for the boilers, emergency generators and
incinerators
 This program also encourages and supports alternative transportation including bus,
carpool, and telework options.
EnergyjManagement
 This program seeks to reduce electricity consumption associated with laboratory,
utility, office, and outdoor operations and support the agency wide efforts to reduce
campus building energy intensity and increase usage of renewable energy.
Green Purchasing
 Program encourages the purchase of recycled content materials, energy-efficient
equipment, alternative fueled vehicles, bio-based products, environmentally
preferable products, and non-ozone depleting substances.
Hazardous Materials Management
 Program provides criteria for the safe and environmentally sound storage, handling,
transportation and disposition of hazardous materials used in laboratory research,
support and maintenance operations, and construction activities
Hazardous Waste Management
 This program provides for the management of hazardous wastes to ensure that such
wastes are identified, accumulated, stored, transported, treated, and disposed or
recycled in an environmentally sound manner
Pesticides
 This program follows integrated pest management (IPM) principles when controlling
pests in the animal facilities, inside campus buildings, and on campus grounds
through limited pesticide application in a manner that is effective yet safe for the
environment, personnel, and research activities
Solid Waste Management
 Program ensures that solid wastes are identified, classified, collected, transported,
stored, recycled, treated and/or disposed safely and in a manner protective of human
health and the environment
 Maximization of the quantity of material diverted from the landfill, either by
recycling, reuse, or reduction in quantities used, is a primary objective
Storm water Management
 Program focuses on reducing the potential for outdoor petroleum and chemical spills,
and minimizing the impact of construction projects on the storm water conveyance
system.
Wastewater
 Program reduces the potential for pollutants to enter the sanitary sewer system
through effective pretreatment, source reduction, proper chemical disposal, and other
wastewater management programs
Water Consumption
 Program seeks to reduce water consumption associated with laboratory, utility,
facility, and domestic operations.
ORGANIZATIONAL STRUCTURE AND RESPONSIBILITY
Organizational structure outlines the hierarchy and reporting relationships between
various functions and levels in an organization. Duties at each level of responsibility and
functional area may be summarized in a more detailed organization chart.
Definitions Function, Functional Area – Department or area of responsibility.
Example: Finance, Environment, Marketing, Maintenance.
 Role – Position (job title) held by a person and its relationship to other positions in the
organization. Example: President, Department Head, Environmental Management
Representative, Purchasing Manager, Maintenance Foreman.
Responsibilities – Assigned duties and obligations of a person in a role. Example:
Schedule and lead environmental audits; report compliance monitoring results to
government; supervise emergency response team; ensure regular preventive maintenance
is done on equipment.
Authority – The power and influence a person has as a result of his or her particular
role. Authority also arises from a person’s character and personality traits. Example:
Authority to request a report on environmental performance; authority to direct a person
to take a sample or conduct an analysis; authority to discipline an employee for
inappropriate behaviour
ISO 14001 STRUCTURE AND RESPONSIBILITY says:
 Roles, responsibilities, and authorities shall be defined, documented, and
communicated to facilitate effective management.
 Management shall provide resources essential to the implementation and control of
the environmental management system.
 Resources include human resources, and specialized skills, technology, and financial
resources.
 The organization shall appoint specific management representatives who,
irrespective of other responsibilities, shall have defined roles, responsibilities, and
authority for:
(a) ensuring the EMS requirements are established, implemented, and maintained
in accordance with this International Standard
(b) reporting on the performance of the EMS to top management for review, and
as a basis for improvement of the EMS.
What does ISO 14001 require?

Unlike ISO 9001, which looks at the ability of the employees to maintain the
processes in order to produce good product, ISO 14001 is concerned with how the processes
interact with the environment. In essence, how does the organization ensure that employees
(or other outside workers) who are running processes with the potential for significant
environmental impacts are able to do so in such a way that those impacts do not happen?
There is a basic three-step process for this, called competence, training, and awareness.

Competence. The first step is to identify what skills and abilities are required for a person to
perform the job function so as to avoid the potential significant impacts. This competence can
be gained in the form of outside education, training, or experience. For instance, if you have a
chemical process that must maintain the concentration of a bath to a certain pH, or else there
will be unwanted air emissions, then this bath concentration must be maintained.
If you require the operator to measure the concentrations and adjust the pH level through
addition of an acid or base, then there is a level of chemical knowledge required to perform
this action. It may not require the operator to hold a degree in chemistry, but chemical
 knowledge must be there in order to avoid the unwanted environmental impact of air
emissions.

Training. After identifying what competencies are required for the processes to avoid
potential significant environmental impacts, you need to find people with these competencies
to fill these positions. Of course, in reality there will often be a choice of candidates who
have many of the required competencies, but not all of them. This is where training comes
into place, especially when you are first implementing your environmental management
system and find that the people already doing a job do not have all of the competencies that
are newly identified for the position.
Training can come in many forms, from enrollment in external programs offered by colleges,
universities, or specialized training companies, to on-the-job training where an experienced
person works with a less-experienced individual to teach them the knowledge they need to
perform the job. The employee in the example above need not attain a degree in chemical
engineering to perform the job, but they may need to gain an understanding of the chemical
processes required to safely perform their tasks.

Awareness. Even those who have the desired competencies need to be made aware of how
their tasks can lead to the identified potential environmental impacts. The requirements of
ISO 14001 separate the need for awareness into four distinct areas:
 Conforming to the environmental policy and procedures. When people understand why a
policy or procedure is in place, they are much more likely to follow that requirement. Telling
employees that they need to prevent pollution from their process is one thing, but when they
understand that not following the process can lead to environmental damage and potential
fines that can lead to company insolvency, they may be more likely to follow the rules.
 Significant environmental aspects and potential impacts. The person running a chemical
process may know that uncontrolled waste emissions from that process can be harmful to the
environment if not properly controlled, but they may not understand what those controls need
to be. Awareness of the proper procedure and the benefits of following it are important to
compliance with the rule.
 Roles and responsibilities to achieve conformity. If a person does not understand
what their role is, they are very unlikely to perform that role. This is particularly
important when you are dealing with a temporary employee or contractor who will
not know your specific processes unless you tell them. For example, if you expect that
all fluorescent light bulbs will be collected and stored for proper recycling, but do not
tell a contractor or summer student who is employed to replace the bulbs, then they
may just throw them in the regular garbage because they did not understand that this
was their role.
 Potential consequences of departure from procedures. This links directly back to
my first point: if employees are aware of the consequences of not following the
procedures, such as environmental damage or fines for the organization, they are more
likely to understand why the procedure needs to be followed rather than just following
 it because that is what is written. Many employees gain a great deal of pride and
satisfaction in their work if they better understand why it is important.

Communication:

ISO 14001:2015 Clause7.4 Communication refers to all types of communications,

both internal and external to, the organization. It requires organizations to establish and
maintain a process for internal communications between the various levels and functions of
the organization. It also requires organizations to document and respond to relevant
communications from external interested parties.

Examples of internal communications include:

 Communicating environmental objectives and targets to employees.

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

Examples of external communications include:

 Dealing with environmental complaints or proactively inviting such stakeholders, or

‘green’ pressure groups to the site.
 Responding to media inquiries, especially in the event of an incident.

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

 motivate the workforce;

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

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

 communicating internally between levels and functions, and

 soliciting, receiving, documenting and responding to external communications.

As people often see environmental issues in global terms, it can take time for employees to
appreciate the impacts of their working practices. So it's a good idea to explain the
implications for the business if procedures aren't followed.

It is essential:

 to communicate clearly how the EMS affects departments and individuals

 that senior management continues to show commitment
 to ensure that employees are given the necessary training whenever their role changes

7 C's of communication:
COMMUNICATION FOUNDATION
The 7 C's stand for
 Clear
 Concise
 Concrete
 Correct
 Coherent
 Complete
 Courteous

Clear
 No matter what the task at hand
 Writing a memo, composing an email, alerting the emergency department speaking to
a small group of personnel, or presenting to the city council
 Need to ensure key points are as clear as possible
  Best to minimize the key points per sentence, so there is no need to read between the
lines and misinterpret the message

Concise
• Brief as possible
• No one likes to read long monotonous memos
• Document is then reviewed once written
• Once the review is complete, it is given back to the writer to write with fewer words
• Ensures the workforce receives the clearest and concise message possible
• It also teaches the leadership team to write as brief as possible to get the point across

Concrete
 There are so many definitions, uses and interpretations for the same words that it can
become a bit overwhelming
 It's important to choose the most distinct words with the most precise meanings to get
the message across
 Leads to the goal that want to achieve

Correct
 When writing, this deals not only with the facts of the message, but also the use of
proper spelling and grammar
 When speaking, using proper words, appropriate pauses and pronunciation

Coherent
 Whether communicate through writing or speaking, ensure that the message is logical,
that it flows and is relevant to the key points
 Coherent is especially important when giving a report to activate an acute care team

Complete
 When the message is complete, the receiver has all the information necessary to be
informed by the meaning and will be able to respond appropriately

Courteous
 Communicate politely, respectfully, openly, honestly, and professionally as possible
 How do you want to be treated when someone is communicating with you?
 Keep that point of view in mind when you communicate with them.
Documentation:
Implementation The environmental management system documentation comprises:
• Description of the environmental management system and the interaction of its
elements; • Conventions on policy, objectives and targets; • Information on significant
environmental aspects; • Information on processes; • Organization chart; • ..
Documents are an important element of an environmental management system (EMS) as
they provide written evidence of procedures, records and instructions. They can also
provide a history of the EMS, enabling you to check whether improvements are continuing to
being made.

EMS document control and record keeping

Guide
Documents are an important element of an environmental management system (EMS) as they
provide written evidence of procedures, records and instructions. They can also provide a
history of the EMS, enabling you to check whether improvements are continuing to being
made.

Documents you are likely to need as part of your EMS include:

 an environmental policy
 objectives and targets
 structure and responsibilities for those involved in environmental work in your
business
 information on how the EMS operates
 how documents and operational procedures are controlled
 monitoring and measurement records
 corrective and preventive action
 records, eg training and auditing information
 management review decisions
Your documents can be in either electronic or paper format. But whichever format you
choose, you should ensure that they:

 are available for easy reference at all times

 are clear and unambiguous
 are updated and that people use the latest versions
 show who has responsibility for investigating and fixing problems
You should consider how documents are updated, who updates them, how you ensure people
look at the most up-to-date version and what happens to old versions. If you have a quality
management system - such as ISO 9000 - you should already have document control
procedures in place and can follow quality management standards.
Definitions ! Under ISO 14001, documentation refers to all written material concerning the
EMS ! Documents include policies, procedures, manuals, plans, diagrams, flowcharts,
correspondence, memoranda related to the EMS ! Records are documents, but under ISO
14001 are distinguished from documentation: » Documentation concerns what should happen
» Records contain information on what has happened
ISO 14001 Standard specifications do not require extensive documentation ! A management
system needs consistent procedures ! Documentation (i.e., written information) aids
consistent application of procedures ! To ensure systematic use of documented procedures,
they must be controlled Here is how ISO 14001 deals with the issue
ISO 14001 Document Control says: The organization shall establish and maintain procedures
for controlling all documents required by this International Standard to ensure that:
(a) they can be located
(b) they are periodically reviewed, revised as necessary, and approved for adequacy by
authorized personnel
(c) the current versions of relevant documents are available at all locations where operations
essential to the effective functioning of the EMS are performed
(d) obsolete documents are promptly removed from all points of issue and points of use, or
othewise assured against unintended use
(e) any obsolete documents retained for legal and/or knowledge preservation purposes are
suitably identified.
Documentation shall be legible, dated (i.e., with dates of revision), and readily identifiable,
maintained in an orderly manner and retained for a specified period. Procedures and
responsibilities shall be established and maintained concerning the creation and modification
of the various types of document.

In Other Words Documents must be: ! Available where and when needed ! Clear, up to date,
identifiable, dated (including revisions), stored neatly and logically, kept for a specified
period of time ! Developed, reviewed, revised, approved, and modified only by authorized
persons ! Removed from use when out of date ! Identified as obsolete if archived

Operational Control:
ISO 14001 Operational. Control (Cont'd) (a) establishing and maintaining
documented. procedures where their absence could lead to. deviations from the
environmental policy
Definition and implementation of operational controls
The standard states that 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 may include:
 constructing processes to ensure consistent results

 considering the life cycle of a product when establishing controls

 using technology to ensure results

 ensuring personnel are competent

 performing processes in a certain way

 monitoring and measuring of results

 deciding on the amount of documented information required to support the above

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.
Operational controls and procedures are the measures that enable a business to function.
They are also the means by which you can manage environmental impacts through your
environmental management system (EMS). Existing controls may be based on common sense
and they may have been developed over a number of years.
Operational controls: Things to bear in mind
 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.

Monitoring and Management:

The Environmental Management and Monitoring Plan (EMMP) represents the key
mitigation and enhancement measures for major impacts, which are translated into
concrete action programs/projects and defines the institutional framework and mechanisms
for ensuring their appropriate implementation.

Environmental monitoring is essential to gather information about and assess the

effectiveness of the environment in which collections are kept. ... The records produced by
monitoring the environment will provide a baseline of the existing conditions where
collections are located.
Environmental measurement is any data collection activity or investigation involving the
assessment of chemical, physical, or biological factors in the environment which affect
human health or the quality of life. Learn more about environmental measurement programs
and tools that aid in environmental decisions.
There are a number of key reasons why your business should measure its environmental
performance: Cost savings and improved productivity - areas of your business such as raw
material use, waste production and energy use can all be looked at closely to identify savings.

What needs to be monitored & measured?

To start with, what do you need to monitor and measure per the ISO 14001 requirements for
your environmental management system (EMS)? Everything is linked back to
the identification and classification of environmental aspects in clause 4.3.1 of ISO 14001,
which are the ways that the processes of your organization interact with the environment.
After going through all of your processes and seeing what interactions exist with the
environment, you need to identify which have significant impacts. In short, this is up to your
judgment.

For instance, if you have a fume hood for chemical usage that vents outside of your building,
you will have identified that you have an environmental aspect of air emissions, but this does
not mean it is significant. If you use your fume hood very rarely, and only for cleaning with a
small amount of isopropyl alcohol, then the amount of this very benign chemical that is being
released is small. This would not be significant. If, on the other hand, you use your fume
hood daily to vent the exhaust from a process that creates cyanide gas, then this air emission
is something you would deem significant and need to control.

How do you need to control your monitoring & measurement equipment?

When you think about the need for controls in processes with significant aspects, it is easy
to see why you would want to make sure that your measurements are correct. If you have a
significant chemical process, as described above, your control may be to have a filter to
capture the cyanide, and measure the level of cyanide in the resultant air after filtration, to
ensure the filter is working. If this is what you are doing to prevent the significant aspect
from becoming an environmentally toxic leak, then you will want to make sure your
measurement device is working properly. In other words, that it is calibrated and verified.

What is calibration? Calibration is a process where you compare measurements between

those taken by a device under review and a known good measurement. The known good
measurement is the standard. When you calibrate a unit you make the comparison with the
known good measurement, and if the device matches the correct measurement, then the
device is considered in calibration. This device can then be used and safeguarded for damage,
adjustment, or tampering so that it remains correct, and you can then use the device until the
next required calibration due date. If you have a calibration system for other equipment in
your organization, the equipment for ISO 14001 monitoring and measurement can be
controlled in the same way; a new system is not required.
 Some devices will change so often that calibration is not possible. These devices need to be
verified before use. In the case of the chemical measurement, you might have a meter that is
tested with a gas that contains a known concentration of cyanide before use. If the meter
reads the correct measurement, then you can use it, but if not it needs to be adjusted or
corrected prior to use. In this case, the container of known concentration should be calibrated
at regular intervals to ensure that it remains correct.

Monitoring, Measurement, Analysis and Evaluation

7 steps for ISO 14001 Monitoring, Measurement, Analysis and Evaluation
To ensure that your organization is meeting its EMS policies, objectives and targets:

1. Identify the activities that can have significant impacts and risks
2. Determine key characteristics of the activity to be monitored
3. Select the best way to measure the key characteristics
4. Record data on performance, controls and conformance with objectives and targets
5. Determine the frequency with which to measure the key characteristics
6. Analysis & reporting
7. Establish management review and Evaluation

Plan what Needs to be Monitored and Measured

Identify criteria against which your business can measure and monitor its performance.
Particular attention should be given to any criteria that needs to be communicated and where
it relates to compliance obligations.

For example, a criterion could be compliance with an effluent discharge permit or compliance
with chemical substance legislation.

Examples of What to Measure

 Environmental policycommitments
 Environmental objectives
 The characteristics of operational activities, products and services related to significant
environmental aspects
 The status of compliance obligations.
Methods may include, as appropriate, statistical techniques to be applied to the analysis of
those results.

Measuring performance against criteria can be undertaken using performance indicators.

Developing a Process
You should expect to see that your organization has developed a process (method,
techniques, format, etc.) to identify, collect and analyze various data and information from
both internal and external sources, including:

 EMS records
 Monitoring and measuring results
 Process performance results
 Meeting objectives
 Internal audit findings
 Customer surveys and feedback
 2nd or 3rd party audit results
 Competitor and benchmarking information
 Product test results;
 Supplier performance information.
This ‘input’ (information and data) should reflect upon the adequacy, suitability and
effectiveness of the environmental management system and its processes.

The ‘output’ (result of the analysis) must provide information (understanding, insight,
awareness, confidence, knowledge of, etc.).

Identify Appropriate Indicators

Indicators help to convert relevant quantitative or qualitative information into a concise, more
understandable and useful form for evaluating performance.

Indicators can comprise operational performance indicators (for example energy consumed,
waste generated) and environmental condition indicators (for example concentration of
specific pollutant in surrounding air).

An example of an indicator relevant to the permit could be pH or parts per million (ppm) of
heavy metal. For the chemical substance legislation criterion, the indicator could be the
number of suppliers responding to a questionnaire, electricity consumption, scrappage rates,
production units, emissions, product fuel use and number of complaints or incidents.

Monitoring and Measuring

Monitoring and measuring should take into account the need for reliability of
data/information reliability. This depends on factors such as availability, adequacy, scientific
and statistical validity and verifiability.

Monitoring and measurement should be supported by processes that ensure the data obtained
are of the type, amount and quality needed for effectively evaluating performance.

For monitoring and measuring an effluent permit consent, it would be expected that a
process, appropriate competency and internal audits would be in place. For chemical
substance legislation, it would be expected that appropriate quality control is in place to
manage records.

Analysing Data
Analysis of information should consider the data quality, validity, adequacy and
completeness and assist the organisation in its communication of reliable information.

Data analyses should include consideration of the quality, validity, adequacy and
completeness of information to deem it reliable.
As such, the data and information collected through monitoring and measurement should
constitute objective verifiable evidence. Such evidence allows an independent body or person
to determine if a claim made by the organisation can be substantiated.

For example, an organisation claiming that it has reduced its emissions may have to provide
monitoring data to back-up the claim to an interested party, if requested. Environmental
auditing is a method that can be used to check the reliability of data.

Organizations are required by ISO 14001:2015 to retain appropriate documented information

in the of records, spreadsheets, and reports, etc. as evidence of the monitoring, measurement,
analysis and evaluation of results.

What is environmental management review?

A management review is the final element of the environmental management
system (EMS) process. It involves a formal evaluation of the adequacy of your business'
EMS - taking into account any new environmental issues, legislation, changing circumstances
and continual improvement.
The management review should cover:

 environmental performance and progress in achieving objectives and targets

 compliance with legislation
 results of internal audits and reports
 actions required as a result of non-conformances
 new processes and any changes to known environmental issues
 any changes in circumstances - for example changes in legislation or new technology
 the effectiveness of training
 the need for any revisions to your environmental policy, objectives and targets
 follow-up actions from previous management reviews
 recommendations for improvement
The management review meetings are a vital part of your business' EMS as they show
commitment at the highest level - allowing those with authority and specialist knowledge to
put forward ideas and solutions to problems. They should be minuted and you must ensure
that any agreed actions are carried out.

What is the Purpose of Management Review of EMS?

1. Determine and evaluate environmental management system (EMS) performance
2. Determine the need for change and improvement, recommendations for improvement
3. Determine the suitability of the policies and the objectives
How Often Should We Schedule A Management Review of the EMS?
ISO standards state the frequency or intervals of reviews must be defined in the EMS by the
Management Team.

The frequency of management reviews might be quarterly, six monthly or annually. You may
decide to have stand-alone management reviews or combine it with other business activities,
e.g. strategic planning, business planning, operations meetings or functional reviews.
 How's Best to Document your ISO 14001 Management Reviews?
It is not a mandatory requirement to document your ISO 14001 management review
process for achieving certification, however, we find it useful for the business and
recommend you develop and implement a Management Review Procedure that defines:

 Management review responsibilities - at what level of management, senior manager,

facility manager etc.
 Management review scheduling
 Management review inputs (agenda)
 Management review outputs (minutes, actions)
What Should Be Reviewed?
Customer feedback, audit findings & audit results (using a gap analysis tool or ISO 14001
audit checklist), as well as Internal and external issues should be discussed by the
management team; processes performance, EMS objectives, preventive actions,
recommendations for improvement - and their potential effect on the strategic direction of the
organization.

The management review meetings must address the possible need for changes to policy,
objectives, targets, and other elements of the EMS.

The management review process must ensure that the necessary information is collected
ahead of time to allow management to effectively carry out this evaluation.

Internal

1. Minutes from previous management reviews

2. The policies, objectives and targets
3. Results of EMS and process audits
4. The extent to which objectives and the numeric targets were met
Suitability and effectiveness of the EMS based possible changing circumstances that may
include:

External

1. New or proposed legislation or regulations

2. External providers and suppliers performance
3. Changing expectations/requirements of relevant interested parties (customer feedback,
customer requirements)
4. New or modified activities, products, or services
5. Advances in technology and science
6. Changing market preferences of buyers
All management reviews must be documented. Observations, conclusions, and
recommendations for further necessary action from the review must be recorded. If any
corrective action must be taken, Top management should follow up to ensure that the action
was effectively implemented.
 The Management Review Process Should Focus on the Following INPUTS:

1. The status of actions from previous management reviews considered during management
review
2. Changes in:
1. External and internal issues that are relevant to the EMS
2. Compliance obligations and other expectations of interested parties
3. Significant environmental aspects
4. Risks and opportunities
3. The extent to which objectives have been met
4. Information on our organization’s environmental performance, including trends in:
1. Non-conformities and corrective actions
2. Monitoring and measurement results
3. Compliance obligations fulfilment
4. Audit results
5. The adequacy of resources
6. Communications from interested parties, including complaints
7. Opportunities for continual improvement
Auditors now expect to see evidence of a more strategically focused management review.
Context, risks and opportunities need to be considered, as well as the alignment of the EMS
to the organization’s overall strategic objectives.

9.3.3 Outputs
You should seek and record evidence of outputs from the management review process, there
should be evidence of decisions regarding output from the management review process
includes decisions and actions related to:

1. Conclusions on the continuing suitability, adequacy and effectiveness of the EMS

2. Decisions related to continual improvement opportunities
3. Decisions on any need for changes to the EMS, including resource needs
4. Actions if needed, when objectives have not been met
5. 5. Opportunities to improve integration of the environmental management system with
other business processes, if needed
6. Any implications for the strategic direction of the organization
Management review output is documented in the minutes of the review meeting:

 Action items are highlighted to ensure that they are easily identifiable
 Action items include the assignment of responsibility
 Action items include timeframe and allocation of resources for implementation
Auditors will expect to see evidence of the same types output from the management reviews
as per the previous version of the standard. However, note that the results of management
reviews may now be held in any format that your organization chooses.

Organizations are now required to retain documented information as evidence of the results
of the management reviews