SECTION 10

4.3.3 Objectives and targets

The organization shall establish and maintain documented environmental objectives and targets, at each relevant function and level within the organization.

When establishing and reviewing its objectives, an organization shall consider the legal and other requirements, its significant environmental aspects, its technological options and its financial, operational and business requirements, and the views of interested parties.

The objectives and targets shall be consistent with the environmental policy, including the commitment to prevention of pollution.
 

The objectives should be specific and targets should be measurable wherever practicable, and where appropriate take preventative measures into account.

When considering their technological options, an organization may consider the use of the best available technology where economically viable, cost-effective and judged appropriate.

The reference to the financial requirements of the organization is not intended to imply that organizations are obliged to use environmental cost-accounting methodologies.
 

Internal performance criteria

Internal priorities and criteria should be developed and implemented where external standards do not meet the needs of the organization or are non-existent. Internal performance criteria, together with external standards, assist the organization in developing its own objectives and targets.

Practical help - Internal performance criteria

Examples of areas where an organization can have internal performance criteria might include

- management systems;

- employee responsibilities;

- acquisition, property management and divestiture;

- suppliers;

- contractors;

- product stewardship;

- environmental communications;

- regulatory relationships;

- environmental incident response and preparedness;

- environmental awareness and training;

- environmental measurement and improvement;

- process risk reduction;

- prevention of pollution and resource conservation

- capital projects;

- process change;

- hazardous material management;

- waste management;

- water management

- air quality management;

- energy management;

- transportation.

Environmental objectives and targets

Objectives should be established to meet the organization's environmental policy. These objectives are the overall goals for environmental performance identified in the environmental policy, When establishing its objectives, an organization should also take into account the relevant findings from environmental reviews, and the identified environmental aspects and associated environmental impacts.

Environmental targets can then be set to achieve these objectives within a specified time-frame. The targets should be specific and measurable.

When the objectives and targets are set, the organization should consider establishing measurable environmental-performance indicators. These indicators can be used as the basis for an environmental-performance evaluation system and can provide information on both the environmental management and the operational system.

Objectives and targets can apply broadly across an organization or more narrowly to site-specific or individual activities.  Appropriate levels of management should define the objectives and targets. Objectives and targets should be periodically reviewed and revised, and should take into consideration the views of interested parties.

Some issues to be considered in environmental objectives and targets

1. How do environmental objectives and targets reflect both the environmental policy and significant environmental impacts associated with the organization's activities, products or services?

2. How have the employees responsible for achieving the objectives and targets had input into their development?

3. How have the views of interested parties been considered?

4. What specific measurable indicators have been established for objectives and targets?

5. How are objectives and targets regularly reviewed and revised to reflect desired improvements in environmental performance?
 
 

Objectives can include commitments to

- reduce waste and the depletion of resources;

- reduce or eliminate the release of pollutants into the environment;

- design products to minimize their environmental impact in production, use and disposal;

- control the environmental impact of sources of raw material;

- minimize any significant adverse environmental impact of new developments;

- promote environmental awareness among employees and the community.

Progress towards an objective can generally be measured using environmental performance indicators such as:

- quantity of raw material or energy used;

- quantity of emissions such as CO2;

- waste produced per quantity of finished product;

- efficiency of material and energy use;

- number of environmental incidents

- number of environmental accidents

- percentage waste recycled;

- percentage recycled material used in packaging;

- number of vehicle kilometers per unit of production;

- specific pollutant quantities, e.g. NOx, SO2, HC, Pb, CFCs;

- investment in environmental protection;

- number of prosecutions;

- land area set aside for wildlife habitat.
 

Objective: reduce energy required in manufacturing operations.

Target: achieve ten percent reduction of energy consumption compared to the previous year.

Indicator: quantity of fuels and electricity per unit of production.
 

4.3.4 Environmental management program(s))

The organization shall establish and maintain (a) program(s)) for achieving its objectives and targets.  It shall include:

a) designation of responsibility for achieving objectives and targets at each relevant function and level of the organization;

b) the means and time-frame by which they are to be achieved.

If a project relates to new developments and new or modified activities, products or services, program(s)) shall be amended where relevant to ensure that environmental management applies to such projects.
 

The creation and use of one or more programs is a key element to the successful implementation of an environmental management system.  The program should described how the organizationís objectives and targets will be achieved, including time-scales and personnel responsible for implementing the organizationís environmental policy.  This program may be subdivided to address specific elements of the organizationís operations.  The program should include an environmental review for new activities.

The program may include, where appropriate and practical, consideration of planning, design, production, marketing and disposal stages.  This may be undertaken for both current and new activities, products or services.  For products this may address design, materials, production processes, use and ultimate disposal.  For installations or significant modifications of processes this may address planning, design, construction, commissioning, operation and, at the appropriate time determined by the organization, decommissioning.
 

Within the general planning of activities, an organization should establish an environmental management program that addresses all of its environmental objectives. To be most effective, environmental management planning should be integrated into the organization's strategic plan. Environmental management programs should address schedules, resources and responsibilities for achieving the organization's environmental objectives and targets.

Within the framework provided by the environmental management planning, an environmental management program identifies specific actions in order of their priority to the organization. These actions may deal with individual processes, projects, products, services, sites or facilities within a site.

Environmental management programs help the organization to improve its environmental performance. They should be dynamic and revised regularly to reflect changes in organizational objectives and targets.

Some issues to be considered in environmental management program(s))

1. What is the organization's process for developing environmental management programs?

2. Does the environmental management planning process involve all responsible parties?

3. Is there a process for periodic reviews of the program?

4. How do these programs address the issues of resources, responsibility, timing and priority?

5. How are the environmental management programs responsive to the environmental policy and general planning activities?

6. How are the environmental management programs monitored and revised?
 

The following is an example of a process for developing an environmental management program.

 
Environmental policy commitment#1: Conserve natural resources

Objective #1: Minimize water use wherever technically and commercially practical

Target #1: Reduce water consumption at selected sites by fifteen percent of present levels within one year

Environmental program #1: Water reuse

Action #1: Install equipment to recycle water used for rinsing in process A for reuse in process B
 

Implementation

Principle 3 - Implementation

For effective implementation, an organization should develop the capabilities and support mechanisms necessary to achieve its environmental policy, objectives and targets.
 

General

The capabilities and support required by the organization constantly evolve in response to the changing requirements of interested parties, a dynamic business environment, and the process of continual improvement. To achieve its environmental objectives an organization should focus and align its people, systems, strategy, resources and structure.

For many organizations, implementing environmental management can be approached in stages and should be based on the level of awareness of environmental requirements, aspects, expectations and benefits, and the availability of resources.
 

Ensuring capability

Resources - Human, physical and financial

The appropriate human, physical (e.g. facilities, equipment), and financial resources essential to the implementation of an organization's environmental policies and the achievement of its objectives should be defined and made available. In allocating resources, organizations can develop procedures to track the benefits as well as the costs of their environmental or related activities. Issues such as the cost of pollution control, wastes and disposal can be included.

Some issues to be considered in human, physical, and financial resources

1. How does the organization identify and allocate the human, technical and financial resources necessary to meet its environmental objectives and targets, including those for new projects?

2. How does the organization track the costs and benefits of environmental activities?

Practical help - Human, physical and financial resources

The resource base and the organization structure of the small or medium enterprise (SME) can impose certain limitations on implementation, In order to manage these constraints the SME should, wherever possible, consider cooperative strategies with

- larger client organizations to share technology and know-how;

- other SMEs on a supply chain or local basis to define and address common issues, to share know-how, to facilitate technical development, to use facilities jointly, to establish a way to study the EMS, to collectively engage consultants;

- standardization organizations, SME associations, Chambers or Commerce, for training and awareness programs;

- universities and other research centers to support production and innovation.

EMS alignment and integration

To effectively manage environmental concerns, the EMS elements should be designed or revised so that they are effectively aligned and integrated with existing management system elements.

Management system elements that can benefit from integration include

- organization policies;

- resource allocation;

- operational controls and documentation;

- information and support systems;

- training and development;

- organization and accountability structure;

- reward and appraisal systems;

- measuring and monitoring systems;

- communication and reporting.

1. How has the environmental management system been integrated into the overall business management process?

2. What is the process for balancing and resolving conflicts between environmental and other business objectives and priorities?
 
 

4.4 Implementation and operation

4.4.1 Structure and responsibility

Roles, responsibility and authorities shall be defined, documented and communicated in order to facilitate effective environmental 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 organizationís top management shall appoint (a) specific management representative(s) who, irrespective of other responsibilities, shall have defined roles, responsibilities and authority for:

a) ensuring that environmental management system requirements are established, implemented and maintained in accordance with this International Standard;

b) reporting on the performance of the environmental management system to top management for review and as a basis for improvement of the environmental management system.

The successful implementation of an environmental management system calls for the commitment of all employees of the organization.  Environmental responsibilities therefore should not be seen as confined to the environmental function, but may also include other areas of an organization, such as operational management or staff functions other than environmental.

This commitment should begin at the highest levels of management.  Accordingly, top management should establish the organizationís environmental policy and ensure that the environmental management system is implemented.  As part of this commitment, the top management should designate (a) specific management representative(s) with defined responsibility and authority for implementing the environmental management system.  In large or complex organizations there may be more than one designated representative.  In small or medium sized enterprises, these responsibilities may be undertaken by one individual.  Top management should also ensure that appropriate resources are provided to ensure that the environmental management system is implemented and maintained.  It is also important that the key environmental management system responsibilities are well defined and communicated to the relevant personnel.
 

Accountability and responsibility

Responsibility for the overall effectiveness of the EMS should be assigned to (a) senior person(s) or function(s) with sufficient authority, competence and resources.

Operational managers should clearly define the responsibilities of relevant personnel and be responsible and accountable for effective implementation of EMS and environmental performance. Employees at all levels should be accountable, within the scope of their responsibilities, for environmental performance in support of the overall environmental management system.
 

Some issues to be considered in accountability and responsibility

1. What are the responsibilities and accountability of personnel who manage, perform and verify work affecting the environment, and are these defined and documented?

2. What is the relationship between environmental responsibility and individual performance and is this periodically reviewed?

3. How do the responsible and accountable personnel

-  obtain sufficient training, resources and personnel for implementation?

- initiate action to ensure compliance with environmental policy?

-  anticipate, identify and record any environmental problems?

- initiate, recommend, or provide solutions to those problems?

- verify the implementation of such solutions?

- control further activities until any environmental deficiency or unsatisfactory condition has been corrected?

- obtain appropriate training to act in emergency situations?

- gain an understanding of the consequences of non-compliance?

- gain an understanding of the accountability that applies to them?

- encourage voluntary action and initiatives?

Practical help - Accountability and responsibility

To ensure effective development and implementation of an EMS, it is necessary to assign appropriate responsibilities. One possible approach for developing environmental responsibilities is indicated below.  It should be recognized that companies and institutions have different organizational structures, and need to understand and define environmental responsibilities based upon their own work processes.

The following is a sample model of environmental responsibilities.
 

Sample environmental responsibilities	Typical person(s) responsible
Establish overall direction	President, chief executive officer (CEO), board of directors
Develop environmental policy	President, CEO, chief environmental manager
Develop environmental objectives, targets and programs	Relevant managers
Monitor overall EMS performance	Chief environmental manager
Assure regulatory compliance	Senior operating manager
Ensure continual improvement	All managers
Identify customers' expectations	Sales and marketing staff
Identify suppliers' expectations	Purchasers, buyers
Develop and maintain accounting procedures	Finance/accounting managers
Comply with defined procedures	All staff

NOTE - In the case of SMEs the person responsible can be the owner.
 
 

4.4.2 Training, awareness and competence

The organization shall identify training needs.  It shall require that all personnel who work may create a significant impact upon the environment, have received appropriate training.

It shall establish and maintain procedures to make its employees or members at each relevant function and level aware of:

a) the importance of conformance with the environmental policy and procedures and with the requirements of the environmental management system;

b) the significant environmental impacts, actual or potential, of their work activities and the environmental benefits of improved personal performance;

c) their roles and responsibilities in achieving conformance with the environmental policy and procedures and with the requirements of the environmental management system, including emergency preparedness and response requirements;

d) the potential consequences of departure from specified operating procedures.

Personnel performing the tasks which can cause significant environmental impacts shall be competent on the basis of appropriate education, training and/or experience.
 

The organization should establish and maintain procedures for identifying training needs.  The organization should also require that contractors working on its behalf are able to demonstrate that their employees have the requisite training.

Management should determine the level of experience, competence and training necessary to ensure the capability of personnel, especially those carrying out specialized environmental management functions.
 

Environmental awareness and motivation

Top management has a key role to play in building awareness and motivating employees by explaining the organization's environmental values and communicating its commitment to the environmental policy.  It is the commitment of the individual people, in the context of shared environmental values, that transforms an environmental management system from paperwork into an effective process.

All members of the organization should understand and be encouraged to accept the importance of achieving the environmental objectives and targets for which they are responsible and/or accountable. They in turn should encourage, where necessary, the other members of their organization to respond in a similar manner.

Motivation to continually improve can be enhanced when employees are recognized for achieving environmental objectives and targets and encouraged to make suggestions that can lead to improved environmental performance.

Some issues to be considered in environmental awareness and motivation

1. How has top management established, reinforced and communicated organizational commitment to the environmental policy?

2. To what extent do employees understand, accept and share the environmental values of the organization?

3. To what extent do shared environmental values serve to motivate environmentally responsible action?

4. How does the organization recognize employees' environmental achievements?
 

The knowledge and skills necessary to achieve environmental objectives should be identified. These should be considered in personnel selection, recruitment, training, development of skills and ongoing education.

Appropriate training relevant to the achievement of environmental policies, objectives and targets should be provided to all personnel within an organization. Employees should have an appropriate knowledge base, which includes training in the methods and skills required to perform their tasks in an efficient and competent fashion and knowledge of the impact their activities can have on the environment if performed incorrectly.

The organization should also ensure that contractors working at the site provide evidence that they have the requisite knowledge and skills to perform the work in an "environmentally responsible manner".

Education and training is needed to ensure that employees have appropriate and current knowledge of regulatory requirements, internal standards and the organization's policies and objectives. The level and detail of training may vary according to the task.

Training programs typically have the following elements:

- identification of employee training needs;

- development of a training plan to address defined needs;

- verification of conformance of training program to regulatory or organizational requirements;

- training of target employee groups;

- documentation of training received;

- evaluation of training received.
 

1. How does the organization identify environmental training needs?

2. How are the training needs of specific job functions analyzed?

3. Is training developed and reviewed and modified as needed?

4. How is the training documented and tracked?

Practical help - Knowledge, skills and training

Examples of the types of environmental training which can be provided by the organization are as follows.
 
 

Type of training	Audience	Purpose
Raising awareness of the strategic importance of environmental management	Senior management	To gain commitment and alignment to organization's environmental policy
Raising general environmental awareness	All employees	To gain commitment to the environmental policy, objectives and targets of the organization; and instill a sense of individual responsibility
Skills enhancement	Employees with environmental responsibilities	To improve performance in specific areas of the organization, e.g. operations, research and development, and engineering
Compliance	Employees whose actions can affect compliance	To ensure regulatory and internal requirements for training are met

 

4.4.3 Communication

With regard to its environmental aspects and environmental management system, the organization shall establish and maintain procedures for:
 

a) internal communication between the various levels and functions of the organization;

b) receiving, documenting and responding to relevant communication from external interested parties.

The organization shall consider processes for external communication on its significant environmental aspects and records its decision.
 

Organizations should implement a procedure for receiving, documenting and responding to relevant information and requests from interested parties.  This procedure may include a dialogue with interested parties and consideration of their relevant concerns.  In some circumstances, responses to interested partiesí concerns may include relevant information about the environmental impacts associated with the organizationís operations.  These procedures should also address necessary communications with public authorities regarding emergency planning and other relevant issues.
 

Communication and reporting

Communication includes establishing processes to report internally and, where desired, externally on the environmental activities of the organization in order to

- demonstrate management commitment to the environment;

- deal with concerns and questions about the environmental aspects of the organization's activities, products or services;

- raise awareness of the organization's environmental policies, objectives, targets and programs;

- inform internal or external interested parties about the organization's environmental management system and performance as appropriate.
 

The provision of appropriate information to the organization's employees and other interested parties serves to motivate employees and encourage public understanding and acceptance of the organization's efforts to improve its environmental performance.

Some issues to be considered in communication and reporting

1. What is the process of receiving and responding to employee concerns?

2. What is the process for receiving and considering the concerns of other interested parties?

3. What is the process for communicating the organization's environmental policy and performance?

4. How are the results from EMS audits and reviews communicated to all appropriate people in the organization?

5. What is the process for making the environmental policy available to the public?

6. Is internal communication adequate to support continual improvement around environmental issues?

Practical help - Communication and reporting

a) Item that can be included in reports :

- organization's profile;

- environmental policy, objectives and targets;

- environmental policy process (including interested party involvement and employee recognition);

- environmental performance evaluation (including releases, resource conservation, compliance, product stewardship and risk);

- opportunities for improvement;

- supplementary information, such as glossaries;

- independent verification of the contents.

b) It is important to remember for both internal and external environmental communication and reporting:

- two-way communication should be encouraged;

- information should be understandable and adequately explained;

- information should be verifiable;

- the organization should present an accurate picture of its performance;

- information should be presented in a consistent form (e.g. similar units of measurement to allow for comparison between one period and another).

c) An organization can communicate environmental information in a variety of ways:

- externally, through an annual report, regulatory submissions, public government records, industry association publications, the media, and paid advertising;

- organization of open days, the publication of telephone numbers where complaints and questions can be directed;

- internally, through bulletin board postings, internal newspapers, meetings and electronic mail messages.

4.4.4 Environmental management system documentation

The organization shall establish and maintain information, in paper or electronic form, to:

a) described the core elements of the management system and their interaction;

b) provide direction to related documentation.

The organization shall establish and maintain procedures for controlling all documents required by ISO 14001 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 environmental management system are performed;

d) obsolete documents are promptly removed from all points of issue and points of use, or otherwise assured against unintended use;

e) any obsolete documents retained for legal and/or knowledge preservation purposes are suitably identified.
 

The level of detail of the documentation should be sufficient to describe the core elements of the environmental management system and their interaction and provide direction on where to obtain more detailed information on the operation of specific parts of the environmental management system.  This documentation may be integrated with documentation of other systems implemented by the organization.  It does not have to be in the form of a single manual.

Related documentation may include:

a) process information;

b) organizational charts;

c) internal standards and operational procedures;

d) site emergency plans.

A.4.5 Document control

The intent of 4.4.5 is to ensure that organizations create and maintain documents in a manner sufficient to implement the environmental management system.  However, the primary focus of organizations should be on the effective implementation of the environmental management system and on environmental performance and not on a complex documentation control system.
 

Operational processes and procedures should be defined and appropriately documented and updated as necessary. The organization should clearly define the various types of documents which establish and specify effective operational procedures and control.

The existence of EMS documentation supports employee awareness of what is required to achieve the organization's environmental objectives and enables the evaluation of the system and environmental performance.

The nature of the documentation can vary depending on the size and complexity of the organization. Where elements of the EMS are integrated with an organization's overall management system, the environmental documentation should be integrated into existing documentation. For ease of use, the organization can consider organizing and maintaining a summary of the documentation to

- collate the environmental policy, objectives and targets;

- describe the means of achieving environmental objectives and targets;

- document the key roles, responsibilities and procedures;

- provide direction to related documentation and describe other elements of the organization's management system, where appropriate;

- demonstrate that the environmental management system elements which are appropriate for the organization are implemented.
 

Some issues to be considered in EMS documentation:

1. How are environmental management procedures identified, documented, communicated and revised?

2. Does the organization have a process for developing and maintaining EMS documentation?

3. How is EMS documentation integrated with existing documentation where appropriate?

4. How do employees access EMS documentation needed to conduct their job activities?

Practical help - EMS documentation

Documents can be in any medium and should be useful and easily understood.  All documentation should be dated (with dates of revision), readily identifiable, organized, and retained for a specified period. The organization should ensure that

- documents can be identified with the appropriate organization, division, function, activity, and/or contact person;

- documents are periodically reviewed, revised as necessary and approved by authorized personnel prior to issue;

- the current versions of relevant documents are available at all locations where operations essential to the effective functioning of the system are performed;

-obsolete documents are promptly removed from all points of issue and points of use.
 
 

SECTION 17

The organization shall identify those operations and activities that are associated with the identified significant environmental aspects in line with its policy, objectives and targets.  The organization shall plan these activities, including maintenance, in order to ensure that they are carried out under specified conditions by:

a) establishing and maintaining documented procedures to cover situations where their absence could lead to deviations from the environmental policy and the objectives and targets;

b) stipulating operating criteria in the procedures;

c) establishing and maintaining procedures related to the identifiable significant environmental aspects of goods and services used by the organization and communicating relevant procedures and requirements to suppliers and contractors.

Implementation is accomplished through the establishment and maintenance of operational procedures and controls to ensure that the organization's environmental policy, objectives and targets can be met.
 

Practical help - Operational control

The organization should consider the different operations and activities contributing to its significant environmental impacts when developing or modifying operational controls and procedures. Such operations and activities may include

- research and development design and engineering;

- contracting;

- handling and storage of raw materials;

- production and maintenance processes;

- laboratories;

- storage of products;

- transportation;

- marketing, advertising;

- customer service;

- acquisition, construction or modification of property and facilities.

Activities can be divided into three categories:

- activities to prevent pollution and conserve resources in new capital projects, process changes and resources management, property (acquisitions, divestitures and property management), and new products and packaging;

- daily management activities to assure conformance to internal and external organizational requirements, and to ensure their efficiency and effectiveness;

- strategic management activities to anticipate and respond to changing environmental requirements.
 
 

SECTION 18

The organization shall establish and maintain procedures to identify potential for and respond to accidents and emergency situations, and for preventing and mitigating the environmental impacts that may be associated with them.

The organization shall review and revise, where necessary, its emergency preparedness and response procedures, in particular, after the occurrence of accidents or emergency situations.

The organization shall also periodically test such procedures where practicable.
 

Emergency plans and procedures should be established to ensure that there will be an appropriate response to unexpected or accidental incidents.

The organization should define and maintain procedures for dealing with environmental incidents and potential emergency situations. The operating procedures and controls should include, where appropriate, consideration of

- accidental emissions to the atmosphere;

- accidental discharges to water and land;

- specific environment and ecosystem effects from accidental releases.

- abnormal operating conditions;

- accidents and potential emergency situations.
 

Emergency plans can include

- emergency organization and responsibilities;

- a list of key personnel;

- details of emergency services (e.g. fire department, spill clean-up services);

- internal and external communication plans;

- actions taken in the event of different types of emergencies;

- information on hazardous materials, including each material's potential impact on the environment, and measures to be taken in the event of accidental release;

- training plans and testing for effectiveness.
 

SECTION 19

4.5 Checking and corrective action

4.5.1 Monitoring and measurement

The organization shall establish and maintain documented procedures to monitor and measure, on a regular basis, the key characteristics of its operations and activities that can have a significant impact on the environment.  This shall include the recording of information to track performance, relevant operational controls and conformance with the organizationís environmental objectives and targets.

Monitoring equipment shall be calibrated and maintained and records of this process shall be retained according to the organizationís procedures.

The organization shall establish and maintain a documented procedure for periodically evaluating compliance with relevant environmental legislation and regulations.
 

Principle 4 - Measurement and evaluation: An organization should measure, monitor and evaluate its environmental performance.
 

General

Measuring, monitoring and evaluating are key activities of an environmental management system which ensure that the organization is performing in accordance with the stated environmental management program.
 

Measuring and monitoring (ongoing performance)

There should be a system in place for measuring and monitoring actual performance against the organization's environmental objectives and targets in the areas of management systems and operational processes. This includes evaluation of compliance with relevant environmental legislation and regulations. The results should be analyzed and used to determine areas of success and to identify activities requiring corrective action and improvement.

Appropriate processes should be in place to ensure the reliability of data, such as calibration of instruments, test equipment, and software and hardware sampling.

Identifying appropriate environmental performance indicators for the organization should be an ongoing process. Such indicators should be objective, verifiable and reproducible. They should be relevant to the organization's activities, consistent with its environmental policy, practical, cost-effective, and technologically feasible.
 

Some issues to be considered in measuring and monitoring

1. How is environmental performance regularly monitored?

2. How have specific environmental performance indicators been established which relate to the organization's objectives and targets and what are they?

3. What control processes are in place to regularly calibrate and sample measuring and monitoring equipment and system?

4. What is the process to periodically evaluate compliance with relevant legal and other compliance?

4.5.2 Nonconformance and corrective and preventive action

The organization shall establish and maintain procedures for defining responsibility and authority for handling and investigating nonconformance, taking action to mitigate any impacts caused and for initiating and completing corrective and preventive action.

Any corrective or preventive action taken to eliminate the causes of actual and potential nonconformances shall be appropriate to the magnitude of problems and commensurate with the environmental impact encountered.

The organization shall implement and record any changes in the documented procedures resulting from corrective and preventive action.
 

In establishing and maintaining procedures for investigating and correcting nonconformance, the organization should include these basic elements:

a) identifying the cause of the nonconformance;

b) identifying and implementing the necessary corrective action;

c) implementing or modifying controls necessary to avoid repetition of the nonconformance;

d) recording any changes in written procedures resulting from the corrective action.

Depending on the situation, this may be accomplished rapidly and with a minimum of formal planning or it may be a more complex and long-term activity.  The associated documentation should be appropriate to the level of corrective action.
 

Corrective and preventive action

The findings, conclusions, and recommendations reached as a result of measuring, monitoring, audits and other reviews of the environmental management system should be documented, and the necessary corrective and preventive actions identified. Management should ensure that these corrective and preventive actions have been implemented and that there is systematic follow-up to ensure their effectiveness.
 
 

4.5.3 Records

The organization shall establish and maintain procedures for the identification, maintenance and disposition of environmental records.  These records shall include training records and the results of audits and reviews.

Environmental records shall be legible, identifiable and traceable to the activity, product or service involved.  Environmental records shall be stored and maintained in such a way that they are readily retrievable and protected against damage, deterioration or loss.  Their retention times shall be established and recorded.

Records shall be maintained, as appropriate to the system and to the organization, to demonstrate conformance to the requirements of this International Standard.
 

Procedures for identification, maintenance and disposition of records should focus on those records needed for the implementation and operation of the environmental management system and for recording the extent to which planned objectives and targets have been met.

Environmental records may include:

a) information on applicable environmental laws or other requirements;

b) complaint records;

c) training records;

d) process information;

e) product information;

f) inspection, maintenance and calibration records;

g) pertinent contractor and supplier information;

h) incident reports;

i) information on emergency preparedness and response;

j) information on significant environmental aspects;

k) audit results;

l) management reviews.

Proper account should be taken of confidential business information.
 

Records are evidence of the ongoing operation of the EMS and should cover

- legislative and regulatory requirements;

- permits;

- environmental aspects and their associated impacts;

- environmental training activity;

- inspection, calibration and maintenance activity;

- monitoring data;

- details of non-conformance: incidents, complaints and follow-up action;

- product identification: composition and property data;

- supplier and contractor information;

- environmental audits and management reviews.

A complex range of information can result. The effective management of these records is essential to the successful implementation of the EMS. The key features of good environmental information management include means of identification, collection, indexing, filing, storage, maintenance, retrieval, retention and disposition of pertinent EMS documentation and records.

Some issues to be considered in EMS records and information management

1. What environmental information does the organization need to manage effectively?

2. What capability does the organization have to identify and track key indicators of performance and other data necessary to achieve its objectives?

3. How does the organization's record/information management system make information available to the employees who need it when they need it?

4.5.4 Environmental management system audit

The organization shall establish and maintain (a) program(s)) and procedures for periodic environmental management system audits to be carried out, in order to:

a) determine whether or not the environmental management system

1) conforms to planned arrangements for environmental management including the requirements of ISO 14001; and

2) has been properly implemented and maintained; and

b) provide information on the results of audits to management.

The organizationís audit program, including any schedule, shall be based on the environmental importance of the activity concerned and the results of previous audits. In order to be comprehensive, the audit procedures shall cover the audit scope, frequency and methodologies, as well as the responsibilities and requirements for conducting audits and reporting results.
 

The audit program and procedures should cover:

a) the activities and areas to be considered in audits;

b) the frequency of audits;

c) the responsibilities associated with managing and conducting audits;

d) the communication of audit results;

e) auditor competence;

f) how audits will be conducted.
 

Audits of the environmental management system

Audits of the EMS should be conducted on a periodic basis to determine whether the system conforms to planned arrangements and has been properly implemented and maintained.

Audits of the EMS can be carried out by organization personnel, and/or by external parties selected by the organization. In any case, the person(s) conducting the audit should be in a position to do so objectively and impartially and should be properly trained.

The frequency of audits should be guided by the nature of the operation in terms of its environmental aspects and potential impacts. Also, the results of previous audits should be considered in determining frequency.

The EMS audit report should be submitted in accordance with the audit plan.
 
 

4.6 Management review

The organizationís top management shall, at intervals that it determines, review the environmental management system, to ensure its continuing suitability, adequacy and effectiveness.  The management review process shall ensure that the necessary information is collected to allow management to carry out this evaluation.  This review shall be documented.

The management review shall address the possible need for changes to policy, objectives and other elements of the environmental management system, in the light of environmental management system audit results, changing circumstances and the commitment to continual improvement.
 

In order to maintain continual improvement, suitability and effectiveness of the environmental management system, and thereby its performance, the organizationís management should review and evaluate the environmental management system at defined intervals.  The scope of the review should be comprehensive, though not all elements of an environmental management system need to be reviewed at once and the review process may take place over a period of time.

The review of the policy, objectives and procedures should be carried out by the level of management that defined them.

Reviews should include:

a) results from audits;
b) the extent to which objectives and targets have been met;
c) the continuing suitability of the environmental management system in relation to changing conditions and information;
d) concerns amongst relevant interested parties.

Review and improvement

Principle 5 - Review and improvement: An organization should review and continually improve its environmental management system, with the objective of improving its overall environmental performance.
 

General

A continual improvement process should be applied to an environmental management system to achieve overall improvement in environmental performance.
 

Review of the environmental management system

The organization's management should, at appropriate intervals, conduct a review of the EMS to ensure its continuing suitability and effectiveness.

The review of the EMS should be broad enough in scope to address the environmental dimensions of all activities, products or services of the organization, including their impact on financial performance and possibly competitive position.

The review of the EMS should include

• a review of environmental objectives, targets
• and environmental performance;
• findings of the EMS audits;
• an evaluation of its effectiveness;
• an evaluation of the suitability of the environmental policy and the need for changes in the light of

- changing legislation,
- changing expectations and requirements of interested parties,
- changes in the products or activities of the organization,
- advances in science and technology,
- lessons learned from environmental incidents,
- market preferences,
- reporting and communication.

1. How is the EMS periodically reviewed?

2. How are the appropriate employees involved in the review of the EMS and follow-up?

3. How are the views of interested parties taken into account in the EMS review?
 
 

SECTION 24

Continual improvement

The concept of continual improvement is embodied in the EMS. It is achieved by continually evaluating the environmental performance of the EMS against its environmental policies, objectives and targets for the purpose of identifying opportunities for improvement (see figure 1 shown below).

The continual improvement process should

- identify areas of opportunity for improvement of the environmental management system which lead to improved environmental performance;

- determine the root cause or causes of nonconformance or deficiencies;

- develop and implement (a) plan(s) of corrective and preventive action to address root cause(s);

- verify the effectiveness of the corrective and preventive actions;

- document any changes in procedures resulting from process improvement;

- make comparisons with objectives and targets.

Some issues to be considered in corrective and preventive action and continual improvement

1. What process does the organization have to identify corrective and preventive action and improvement?

2. How does the organization verify that corrective and preventive actions and improvements are effective and timely?
 

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