ISO 14001 is an internationally recognised standard that outlines the requirements for an environmental management system (EMS). It provides a framework for organisations to identify and control their environmental impact, improve their environmental performance, and demonstrate their commitment to sustainability. Below you can learn more about ISO 14001 clauses and what can be done to achieve compliance with this standard.

4 Context of the organization

4.1 Understanding the organization and its context

Clause 4.1 is the first auditable requirement of ISO 14001:2015.

This requirement is about understanding the organisation (the company that wants to implement EMS) and understanding relevant external and internal issues that may potentially affect you / your business / your product or services.

List of things that can be done to achieve compliance with this clause is long, examples are:

• policy statement regarding organisations purpose and strategic direction
• tactical plans, policies or road map to achieve future goals
• records of meetings where context is routinely discussed and monitored, e.g. as part of the structured management review process or within each of the function
• structured risk assessment of external and internal issues
• use of PEST (Political, Economic, Social, Technological)
• use of PESTLE (Political, Economic, Social, Technological, Legal, Environmental)
• use of SWOT (Strengths, Weaknesses, Opportunities, Threats)

Good results are typically achieved by using PEST or PESTEL in conjunction with SWOT.

SWOT seems to be perfectly tailored for 4.1. clause as it is focused on both – internal issues (Strengths, Weaknesses) and external issues (Opportunities, Threats). Using SWOT is usually quite simple and intuitive, but here you have some tips on what can be considered when it comes to environmental management.

Strengths: what does your business do well in terms of environment/sustainability, do you have any environmental experience, do you have a low incident rate, do you have a strong leadership focused on sustainability issues, do you already have environmental training for employees, do you have emergency procedures…

Weaknesses: what does your business NOT do well in terms of environment/sustainability, maybe lack of internal environmental knowledge, training, induction, maybe regular environmental incidents, maybe adverse environmental impact, or complaints from customers/employees/local community on environmental related issues…

Opportunities: these are external factors businesses can leverage, you may look at your weaknesses for an idea of opportunities, examples may be: improving knowledge, reducing the occurrence of incidents, involving employees in environmental matters

Threats: potential threats may be related to changes or updates in environmental legislation and failure to achieve compliance, environmental breach and fines, or environmental incidents

It is important that this activity is not done just once, it’s an ongoing and regular process. Also, it’s good to involve staff members in this analysis as you can get more accurate input from the whole company.

4.2 Understanding the needs and expectations of interested parties

An interested party, or in other world stakeholder, is any person or organisation that can affect, can be affected by, or perceive itself to be affected by your decision or activity.

To achieve compliance with clause 4.2, firstly you need to determine interested parties relevant to your EMS. You may divide them into internal (e.g. employees, owners, board of directors), and external (e.g. customers, suppliers, investors, regulators, local communities, government bodies).

Secondly, you need to determine the requirements of these interested parties (what they need from you and your EMS). For example:

Employees: expect appropriate environmental training and safe workspace free from environmental hazards.

Regulators: expect compliance to relevant legislation.

Customers: expect sustainable packaging.

It is worth mentioning, that expectations go both ways. E.g. employees expect appropriate environmental training – you expect from employees compliance with environmental procedures.

In practice it can be achieved by the use of brainstorming, use of surveys, networking, face-to-face meetings, association membership, attending conferences, lobbying, participation in benchmarking, etc., in order to gain stakeholder information and their requirements.

Good results may be achieved also by using stakeholder mapping to determine importance by using the four-quadrant method (power/influence versus interest/importance grid).

To determine the level of stakeholder engagement RACI method (Responsible, Accountable, Consulted, Informed) can be used.

Once you define stakeholders, you need to determine which of these needs and expectations become compliance obligations. Compliance obligations may be either legal requirements (e.g. local laws, regulations etc.) or so-called other requirements (e.g. contractual arrangements with customers, requirements of industry associations, requirements of a parent company).

4.3 Determining the scope of the environmental management system

While determining the scope of your environmental management system you need to consider several points. Think about this clause as determining BOUNDARIES AND APPLICABILITY of your ems – it’s almost like putting a fence around your system so that everyone knows what activities, products, services and locations are included in it.

You shall consider the external and internal context as described in 4.2 and also compliance obligations referred in 4.2 (interested parties). If you need a refresher about these clauses check out my previous posts. Finally, you shall consider organisation units, functions and physical boundaries – consider if your ems is applicable just to selected locations or if it is business-wide.

Consideration of boundaries and applicability of the ems can include:

• range of products and services covered by the system
• different sites and activities, site-specific requirements
• common support provided by centralised functions
• external provision of processes, products and services

While determining the scope you need to consider your authority and ability to control and influence. Generally speaking, you can “control” activities that you conduct and activities under your direct responsibility (e.g. types of vehicles you use, types of chemical substances you use, types of or material you use). Then normally the “influence” is associated with the supply chain (downstream) – you can influence your suppliers to do something e.g. manage their wastes or to implement ems, by putting it into your Supplier Manual.

You can also influence upstream – e.g. you can influence your customers by educating them for example how to dispose of the product after the end of life. Sometimes the line between “control” and “influence” can be blurred, but typically control is related to direct environmental aspects and influence to indirect environmental aspects.

The scope of the EMS shall be documented and available for interested parties. Also, it is important to ensure alignment between your documented scope and your agreed scope of certification. The scope can include the whole of the organisation, specific and identified functions of the organisation, specific and identified sections of the organisation, or one or more functions across a group of organisations. 

4.4 Environmental management system

Clause 4.4. states that you shall establish, implement, maintain and continually improve an Environmental Management System, including the processes needed and their interactions.

It is up to you to determine what those processes are and how they are applied within your business, but the world “interactions” is key here as it brings a process approach to the plate. Even if sometimes we tend to think that the process approach is a pure QMS requirement – when it comes to standardised management systems it is universal.

Integration of the EMS into your standard business management processes is a must. EMS cannot be something that sits outside, somewhere in the corner and is separated from the rest of the business. EMS must be embedded into processes and be an integral part of the business management system as a whole.

You shall consider the knowledge gained in 4.1 and 4.2, when establishing and maintaining the EMS. A quick reminder 4.1. is about understanding the organisation and its context and clause 4.2 is about understanding the needs and expectations of interested parties.

Things to consider:

• sequence, interactions, expected inputs and outputs, e.g. process flow diagram, process mapping, value stream mapping, Turtle diagrams, SIPOC charts, process cards
• defined process requirements, good practices, roles, required competencies, associated training
• assignment of responsibilities and authorities e.g. process owner, process user
• process performance indicators, targets, trends
• arrangements for governing the processes e.g. process owner reviews, dashboards, risks and opportunities, user training, continual improvement initiatives
• approach towards continual improvement and action taken when process performance is not meeting intended results

5 Leadership

5.1 Leadership and commitment

A lot has been already written about leadership, not only in the context of the environmental management system, but in general.

Hashtag #leadership has almost 3.3M followers.

Like it or not – you are always leading by example (Harward Business Review) 

The quality of leaders is reflected in the standard they set for themselves (Ray Kroc)

Leadership is the art of getting someone else to do something you want to be done because he wants to do it (Eisenhower)

When it comes to the EMS requirements, Leaders at all levels establish the direction of the EMS and create conditions in which people are engaged in achieving environmental objectives.

Top management (the person or group of people who directs and controls an organisation at the highest level) shall demonstrate leadership and commitment with respect to the EMS, and provide direction by:

• taking accountability for the effectiveness of the ems – even top management can delegate to others, they are still accountable
• establish environmental policy and objectives aligned with the strategic direction
• integrate ems into the business system and day-to-day processes
• provide resources for ems e.g. people, tools, hardware, software
• communicate the importance of the ems
• ensure ems achieve intended results e.g. by monitoring
• support and direct other employees in terms of ems
• promote continual improvement, and build an improvement culture
• support others to demonstrate their leadership – give other management roles leadership responsibilities to flow down to all functions

Clause 5.1. is often audited in the background. These are areas that auditors observe, rather than asking directly about each point one by one.

Possible actions that you can do to demonstrate leadership:

• communicate mission vision, policies and processes
• create and sustain shared values
• encourage an organisation-wide commitment to ems

Behaviour triggers the behaviour. Declarations trigger declarations.

If your commitment to the ems as top management is only at the declaration level, you cannot expect good results, you will hear what you want to hear, but not necessarily see it in action

Leadership by example are not the best leadership. It is the only leadership.

5.2 Environmental policy

Environmental policy shall be established, implemented and maintained by top management.

First things first, what is “policy”…

The policy details the company’s strategic direction and rules, but it does not give any detailed direction on how this strategy is going to be executed.

It usually contains statements such as ‘we shall’ and ‘we shall not’.

As policies reflect general rules – they are not changed or updated very often. To find out the relationship between policy and other documents, check the link below.

https://eqmconsult.com/the-ultimate-guide-about-the-types-of-documents-in-qms/

Environmental policy must be:

• appropriate and aligned with the purpose and context of the organization e.g. strategic direction, mission, vision, environmental impact of activities, products and services, ethical principles, core values, codes of conduct
• establish framework for setting environmental objectives, e.g. core environmental themes such water, energy, emissions, consumables, chemical products, resources depending on the impact
• include commitment to protect the environment, including pollution prevention* and other relevant specific commitments (e.g. sustainable use of materials, climate change mitigation and adaptation, protecting biodiversity and ecosystems)
• include commitment to meet compliance obligations (regulatory, industry, statutory, customers, and other e.g. internal)
• include commitment to continual improvement of the ems and it’s performance

* pollution prevention means that you need to think how to avoid or limit your business impact on the environment at first place and secondly how to offset remaining impact that cannot be avoided.

Environmental policy should be documented, communicated within and outside the organisation, and available to interested parties.

Arrangements for communicating the policy may include: availability across the organisation and methods used to deploy e.g. hard copies displayed in prominent places, electronic copies via intranet/internet sites, identification and distribution to relevant interested parties, awareness, understanding and application across the organisation e.g. communication methods (meetings, briefs, e-mail, websites), responding to feedback, providing interpretation, translation into other languages (as required).

Additionally you shall maintain documented information to demonstrate that the policy is controlled, reviewed periodically for continuing suitability, and updated as required in response to business changes.

5.3 Organizational roles, responsibilities and authorities

As mentioned while reviewing clause 5.1 as a Leader you are accountable for the effectiveness of the EMS.

You set the strategic direction of the ems, however to execute this, you may need to delegate some responsibilities.

Clause 5.3 says that top management should allocate responsibility and authority to:

• ensure that the ems complies with the requirements of ISO 14001 standard
• report performance of the ems

There is no requirement to nominate so called “Environmental Representative”, but the responsibility and authority of employees performing important roles across the organisation must be allocated and communicated. This can include roles and responsibilities of functional leaders, heads of departments, process owners, lead process users, end users…

You should be able demonstrate that relevant roles, responsibilities and authorities are communicated and understood.

This may be achieved by using e.g. organisation chart, resource allocation, role profiles, accountability statements, job descriptions, terms of reference, training, competence, qualification, performance review.

RACI Matrixes may be a good model to cover this requirement:

R – Responsible – a person or group of people that get the job done

A – Accountable – approves the work and ensure resources

C – Consulted – typically subject matter experts that are consulted

I – Informed – no active participation, but must be made aware of updates or decisions

6 Planning

6.1 Actions to address risks and opportunities

6.1.1 General

The overall objective of this clause is to ensure that your ems is capable of achieving intended results (e.g. conformity to requirements, meeting environmental performance targets) to prevent or reduce unwanted effects, and environmental impacts, and achieve continual improvement.

You can ensure this by identifying risks and opportunities and by planning actions related to them.

There might be many sources of risks and opportunities:

Environmental aspects:

• as a source of risk: e.g. water scarcity during periodic droughts
• as a source of opportunity: e.g. opportunity to reduce wastes due to the introduction of returnable packaging

Compliance obligations:

• as a source of risk: not meeting legal requirements may result in legal penalties
• as a source of opportunity: going above and beyond compliance obligations can improve your company reputation

Interested parties:

• as a source of risk: not meeting environmental requirements by the supply chain
• as a source of opportunity: government funding for the introduction of new technologies that would improve air quality

Organisational context:

• as a source of risk: release of pollutants into environment as a result of the language barriers between employees who may not understand work procedures
• as a source of opportunity: achieving competitive advantage as a result of the ems implementation

You need to identify risks and opportunities and also potential emergency situations (unplanned or unexpected events requiring rapid actions to prevent or mitigate their consequences) such as:

• floods
• fire
• chemical leakage

While identifying emergency situations you should consider:

• type of hazards on the site (e.g. flammable liquids, storage tanks or compressed gases)
• most likely type and severity of the emergency
• possibility of emergency situations in nearby facilities

Although risks and opportunities must be identified and addressed, no formal application is required.

This can be simple method with the evaluation of likelihood and potential consequences or more complex methodology e.g. based on ISO 31000 standard. You choose 🙂 

6.1.2 Environmental aspects

Identification and evaluation of Environmental Aspects lie at the heart of the environmental management system.

Environmental aspects are all around us, and in simple words and by definition it is “every element of an organisation’s activities, products or services that has or can have an impact on the environment.”

There are three important components of environmental aspect management

• Identification
• Assessment
• and Action

Identifying environmental aspects and selecting those that have a significant impact on the environment will affect our entire EMS, including planning environmental objectives and actions to minimise environmental impact.

When determining environmental aspects, you may consider:

• emissions to air
• release to water
• releases to soil
• consumption of raw materials and natural resources
• energy consumption
• energy emitted (e.g. heat, radiation, vibration (noise) and light)
• generation of waste by organisation and by-products
• used space
• biodiversity

There are many types and examples of environmental aspects, but instead of listing them here (probably I’d run out of space anyway) – I’ll redirect you to the article I wrote earlier titled: The ultimate guide to the identification and evaluation of environmental aspects within the organisation

You can read it here:

https://eqmconsult.com/the-ultimate-guide-to-the-identification-and-evaluation-of-environmental-aspects-within-the-organisation/

6.1.3 Compliance obligations

There are two types of so-called Compliance Obligations:

Requirements resulting from the applicable environmental law (regulatory requirements) requirements of governmental or other competent authorities, laws and regulations adopted at international, national and local levels, requirements set out in permits, licenses, orders, rules or guidelines issued by administrative bodies, judgments of courts, examples are:

• emissions limits
• concentration of pollutants
• noise limits
• handling of hazardous materials
• chemical compliance
• control of waste
• planning/building licences
• environmental permits

Requirements from other sources, such as requirements of interested parties (as defined in clause 4.2) examples are:

• Voluntary rules or codes of conduct
• Agreements with social groups or NGOs
• Customer requirements
• Corporate Policies
• Industry standards
• Sector guidance for the best available technology (BAT)
• Sectoral Reference Documents (SRD)
• Best Environmental Management Practices (BEMP)

When planning ems you need to define compliance obligations related to identified environmental aspects, determine how they apply to your organisation, ensure that your organisation have access to these requirements and understand how to comply with them. Make sure that you keep this analysis in a documented form, you’ll need to take them into account when implementing and improving your EMS.

6.1.4 Planning action

Failing to plan is planning to fail (Alan Lakein)

Clause 6.1.4. is all about planning. You already identified your organisation’s significant environmental aspects (6.1.2), you already defined and analysed compliance obligations (6.1.3), you already identified risks and opportunities (6.1.1) – that’s great – a lot is already done!

Now you need to plan, at a high level, actions related to the above and think  how to integrate those actions into the business processes. You may take life-cycle approach and think how to integrate and embed environmental aspects into each part:

• Design
• Sourcing
• Manufacturing
• Distribution
• Product Use
• End of Life

Planning may include the establishment of environmental objectives.

6.2 Environmental objectives and planning to achieve them

Setting objectives is like setting GPS when you start a journey, without knowing your destination you’d just drift aimlessly.

Establishing environmental objectives shall take into account:

• significant environmental aspects (6.1.2)
• associated compliance obligations (6.1.3)
• risks and opportunities (6.1.1)

Objectives can be strategic, tactical or operational. You have to decide WHAT will be done, WHAT resources will be required, WHO will be responsible, WHEN it will be achieved, and HOW the results will be measured.

DOs

• Set up objectives that are consistent with your environmental policy and related to your significant environmental aspects, setting goals in areas with little impact on the environment would be meaningless.
• Make sure that objectives are specific and measurable. It can be achieved by following SMART method.
• Ensure that objectives are monitored e.g. Business Plan Deployment (BPD) charts, dashboards, matrices, reports, progress charts, or traffic light charts.
• Communicate them at the relevant levels.
• Update them accordingly to take into account changing circumstances that could result in new, expanded, amended, or cancelled objectives.

DON’Ts

• Don’t confuse objectives with the means to achieve them. “Replacement of light bulbs into energy-saving ones”, or “Purchase of containers for selective waste collection”, are NOT environmental objectives. They can help to achieve objectives (e.g. reduced energy used or increased level of waste segregation), but are not objectives themselves.
• Don’t be too general. Objective such as “Reducing the negative impact on the environment” or “Reducing the risk of emergency” are not specific, they raise questions – what exactly does it mean, in which areas you want to reduce negative impact, to what extent, to what level, when you consider objective as achieved.
• Don’t treat the implementation of monitoring and measurement as an objective itself. Just standing on a scale every single morning will not make my weight drop down (unfortunately).

Don’t confuse indicators to measure their effectiveness, for example, if your goal is to “Increase the environmental awareness of employees” measuring the effectiveness by the number of people participating in training would not be the best idea. Participation in the training does not indicate an improvement in awareness.

7 Support

7.1 Resources

My children’s energy when it’s time to sleep, students’ creativity, and cold drinks in all-inclusive hotels – these are examples of nondepletable resources… Clause 7.1. is not about the natural resources and their exhaustibility, it is about the need to define and provide the resources necessary to establish, implement, maintain and improve the environmental management system. This may include various types of resources:

• Human Resources, including people knowledge and skills
• Material Resources, including facilities, and infrastructure
• Intellectual Resources, including technology and know-how
• Financial Resources, including you know what

While determining resources you may consider the following:

• resource planning, including make versus buy
• utilization of existing internal resources e.g. people, facilities, materials, equipment, finance, information
• utilization of resources provided by external providers

7.2 Competence

The competence requirement in this clause applies to persons who may have an impact on your ems, e.g.:

• those whose work has the potential to cause significant environmental effects
• those who identify and evaluate environmental impacts or compliance obligations
• those who contribute to achieving environmental goals
• those who react to emergency situations
• those who conduct internal audits
• those who assess compliance

To be compliant with this clause you will need to:

• define competency needs, e.g. qualification, role profiles, job descriptions, accountability statements, skills matrices, performance criteria, development frameworks…
• ensure competency, e.g. by specified induction, training, assessment, evaluation…
• understand training needs related to ems (e.g. gap analysis)
• take action to acquire the necessary competencies and evaluate the effectiveness of actions, e.g. periodic assessment and evaluation of competency to ensure continued adequacy and effectiveness

Evidence of competency includes for example education, training certificates, records of achievement, qualification statements, Individual Development Plans (IDP), Continued Professional Development (CPD), Body of Knowledge (BoK), On the job training (OtJ), workplace assessments…

7.3 Awareness

Awareness is the first step towards change.

As a person who is responsible for the implementation of an EMS in your organisation you will need to ensure that employees and others working under your company’s control (such as contractors) are aware of:

• environmental policy
• significant environmental aspects and impacts associated with their work
• their contribution to the effectiveness of the ems
• consequences of non-compliance with the ems requirements

As a person working for a company with implemented ems, you’ll need to be aware of the above and follow these rules and system assumptions. There is good news here – you don’t need to learn it by heart. You should know about its existence, its purpose, and its role in meeting the commitments. You will also need to know your role in the ems and how your work affect the ems and the environment.

Awareness may be demonstrated different ways, you can consider:

• awareness training programmes
• inductions
• on-job training 
• awareness campaigns
• notice boards
• alerts
• posters
• leaflets
• code of conduct
• employees contribution and participation programmes
• demonstrating compliance to process
• notification of changes

7.4 Communication

Communication regarding the values, activities and environmental results has become an essential activity of the organisation in recent years. This is due to the growing public interest in issues related to environmental responsibility.

Environmental communication aims to build trust, credibility and partnership, as well as raise environmental awareness of the stakeholders. You shall remember that communication is not like a radio broadcast where you only shout how great your company is, but it is a two-way process, in and out of the organisation. In many cases allowing stakeholders, e.g. our neighbours to raise a complaint or opinion about your company’s environmental impact (e.g. noise or odour). In such case, you’d need to review it and respond.

When establishing your communication approach you shall consider the following:

• what is to be communicated e.g. environmental policy, objectives, performance, aspects, impacts
• when to communicate e.g. frequency, scheduled, ad-hoc, shift coverage for internal communication
• who to communicate with e.g. externally to customers, regulators, stakeholders, local community, investors, external providers, and media; internally to employees, employee representatives, contractors
• how communication occurs (methods of communication) e.g. meetings, briefings, notices, e-mails, telephone, text, intranet, internet, visual management, campaigns, social media, alerts, bulletins, webinars, press releases, newsletters, exhibitions, environmental reports
• who undertakes the communication e.g. managers, supervisors, team leaders, team members, employee representatives, corporate communication, public relations, marketing

The needs of many different stakeholders may be satisfied by using a single method of communication, but it may be necessary to use multiple methods to meet the specific needs of each individual stakeholder.

The environmental communication shall be transparent, appropriate, true, not misleading, factual, accurate, reliable, and understandable. This is related to responsible marketing (no to greenwashing). All information about products and services shall be provided in a manner that can be understood by consumers to make informed decisions and to compare the characteristics of different products and services. Any sustainability and green claims shall be evidenced by supporting factual information.

7.5 Documented information

Paperless business at first glance seems to be a perfect option for environmental protection. No paper = lower resource consumption, and no documents have to be packaged or transported. Win.

Many of us tend to assume that using email requires just the electricity used to power our computers. It’s easy to overlook the invisible energy usage involved in running the network and maintaining the physical infrastructure behind it. Data centres consume a lot of energy, particularly when it comes to sending and storing data.

How does this relate to Clause 7.5 of the EMS?

When implementing ems you need to ensure that your system contains required (by ISO 14001) documented information and also other necessary documented information to ensure the effectiveness. The scope of it may vary and depends on the organisation. More is not always better.

Additionally, you’d need to determine how long the information will be stored and when it can be destroyed. When it comes to electronic media, sometimes you may just assume that it will be stored indefinitely, just in case… But to protect the environment and prevent humongous storage of data, maybe you shall think to have a regular (careful) clean-up and let go of data you do not need anymore. A kind of 5S on hard drives and servers.

And let’s be clear, I’m not advocating coming back to paper, just to give some consideration to the environmental impact while going digital.

Also, to ensure compliance with Clause 7.5 you can consider:

• ensuring that the ems includes documented information appropriate to the organisation (size, products, services, processes, complexity, competency etc.)
• identification and description (e.g., a title, date, author, or ref. number); format (e.g., language, software version, graphics) and media (e.g., paper, electronic); review and approval for suitability and adequacy
• ensuring that authorised persons and approval methods are identified
• ensuring that documented information is available and suitable for use, adequately protected (e.g., from loss of confidentiality, improper use, or loss of integrity)
• ensuring distribution, access, retrieval, and use; storage and preservation, including preservation of legibility; control of changes (e.g., version control); retention and disposition; prevention of the unintended use of obsolete documents by removal or suitable identification – data protection processes for electronically managed documentation

8 Operation

8.1 Operational planning and control

The operational planning and control clause is about embedding environmental issues into day-to-day business processes (considering life-cycle perspective, e.g. design, supply chain, storage,  transportation, logistic, production, and end-of-life) in order to minimise the negative impact of environmental aspects.

Operational control can be achieved with the use of various tools implemented according to hierarchy:

• eliminate negative impact at the source whenever possible (e.g. by the adoption of environmentally conscious design),
• replace or substitute (implement process or project changes),
• isolate the operation from the environment,
• introduce engineering / technical controls,
• introduce administrative controls (e.g. procedures, working instructions).

The scope of operational control will depend on:

• the type of operational activities,
• risks and opportunities,
• significant environmental aspects and
• compliance obligations.

Things to consider:

• organisation approach, including relevant function engagement to plan, implement and control operational activity,
• establishment of operational criteria for the processes e.g. temperature for consumable storage
• supervision over processes e.g. engaging competent personnel, conducting processes in a strictly established manner, implementing monitoring or measurement
• organisation approach to control changes and its impact on the environment
• control of the processes, products and services obtained from external providers, e.g. outsourced processes (e.g. Supplier Manuals, contracts, communication of environmental requirements)
• information on potential environmental impacts related to transport or delivery, use, end-of-life and end-of-use, or disposal

8.2 Emergency preparedness and response

Emergency preparedness is a bit like introducing new drugs to the market – they are tested on people.

When implementing ISO 14001, you will need to:

• Identify potential emergency scenarios
• Plan actions to prevent or mitigate the negative impact
• Periodically test your procedure
• Communicate to personnel and other stakeholders (e.g. by training)
• Review and revise emergency procedures

Typical emergency preparedness procedures:

• Fire or explosion
• Accidental emissions to the atmosphere
• Leakage of hazardous chemicals, oils, or consumables (accidental discharges to water or soil)
• Gas or toxic substances leakage
• Natural disasters, severe weather, flooding

Consider the following while preparing emergency response procedures:

• list of key emergency personnel with adequate backup in case of absence
• emergency services with contact details (e.g. fire brigade, leakage recovery services, ambulance services)
• site plan, escape routes and exits (clear), assembly points, emergency signage
• first aid and medical assistance
• emergency equipment checked for suitability and accessibility
• internal and external communication plans
• information on hazardous materials (COSHH & MSDS)
• training and testing
• business recovery

9 Performance evaluation

9.1 Monitoring, measurement, analysis and evaluation

If we didn’t measure things we wouldn’t know how good we were at measuring the things that we are measuring!

To ensure compliance with this requirement you will have to: decide what to monitor;  how to monitor; when the measurement is ok, when it’s not ok; when to monitor; and when to analyse.

Sounds easy, but in practice may be more difficult than exiting the escape room. While QMS indicators are commonly used and well-known, ems indicators sometimes might be problematic. 

What we can measure then? Below few types of environmental indicators.

Environmental Condition Indicators (ECIs): Provide information on the local, regional, national or global state of the environment. Examples are: the concentration of pollutants in the air, air quality in the region, the temperature of the oceans or the depletion of the ozone layer. You may, influence them to some extent, directly or indirectly, but in many cases these metrics are beyond your direct control.

Environmental Performance Indicators (EPIs): Provide information on the environmental performance of an organisation, unlike ECI, they are not calculated at the regional level, but at the level of the organisation. They further divide into 2 types: MPIs and OPIs.

Management Performance Indicators (MPIs): Provide information on management efforts. Examples are: the effectiveness of environmental training, the degree of compliance with legal requirements, or the share of pro-environmental investments in the overall investment pool.

Operational Performance Indicators (OPIs): Provide information on the environmental effects related to your operational activities. Examples are: electricity consumption per produced product, water consumption per employee, percentage of water reused in a production process, or the percentage of packaging intended for multiple uses.

9.2 Internal audit

In terms of the requirements, the EMS audit does not differ significantly from the QMS audit.

In QMS, when planning the frequency of audits, you need to consider the importance of processes.

In EMS, you need to consider the ENVIRONMENTAL importance of processes, i.e. the impact on the environment. Therefore, processes that are more harmful to the environment will be audited more often, and less harmful processes less often.

The audit process itself and its stages do not differ either:

• Initiate
• Prepare
• Conduct
• Audit report
• Follow up
• Complete

What slightly differ ems audits from other audits, in my opinion, it is the level of use of all senses.

The senses are important in all kinds of audits, however, I have the impression that they play an important role as tools for environmental auditors:

• Sight (visual impacts, wastes, chemical products…)
• Hearing (noise)
• Smell (odour)

9.3 Management review

The commitment to environmental responsibility must be on a Business Value Level.

Imagine a tree. Suppose the tree is your environmental management system. The fruits are results (e.g. reduced costs, achieved savings, minimized resources consumption).

But what really makes a fruit? They grow from the roots. If you want to change the fruit, you have to change the roots first. And in our case roots are values.

Regular management reviews of your EMS is extremely important. It enables you to look at values, implications for the strategic direction and integration of the ems with business processes.

The aim is to ensure:

• suitability (fit for purpose, supporting culture and values)
• adequacy (meets the requirements and your company’s needs)
• effectiveness (achieves intended results)

10 Improvement

“Continuous improvement is better than delayed perfection” (Mark Twain)

General Improvement (10.1) and Continuous Improvement (10.3) are such clauses in the standard that contain minimum words but in fact, a lot can be put within it.

When it comes to the environmental management system – organisations shall improve both – the effectiveness of the ems itself, and most importantly the environmental performance.

It is recommended to take into account:

• results of analysis and evaluation of environmental performance
• compliance assessment
• internal audits
• management review outputs

Examples of improvement include correcting, preventing and reducing undesired effects, breakthrough changes, technological innovations, reducing waste, process re-engineering, structural re-organization, benchmarking.

To identify opportunities for improvement you can consider:

• external drivers e.g. regulatory changes, legislation, market expectations, competitor activity, interested party perceptions, customers, environmental impact, benchmarking of best industry practice…
• internal drivers e.g. business strategy, achievement of objectives, problem resolution, cost reduction, improved environmental efficiency, lessons learned, risk reduction, prioritization, employee suggestions…

The EMS can be improved as a whole or by elements. You can use various methodologies and tools to undertake continual improvement including for example: PDCA, 5S, visual factory, value stream mapping, Kaizen, Kaikaku, SIPOC, Cause and effect (fishbone)…

If you already have a Quality Management System in place such as ISO 9001, AS 9100 or ISO/TS 16949 and want to integrate it with environmental practices by the implementation of the Environemntal Management System according to ISO 14001 – visit www.iso14001in14weeks.co.uk – I will be happy to help!

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