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ISO 14001:2004 EMS

Introduction:

ISO 14001 process steps

ISO 14000 is a family of standards related to environmental management that exists to help organizations (a) minimize how their operations (processes, etc.) negatively affect the environment (i.e., cause adverse changes to air, water, or land) (b) comply with applicable laws, regulations, and other environmentally oriented requirements, and (c) continually improve in the above. ISO 14000 is similar to ISO 9000 quality management in that both pertain to the process of how a product is produced, rather than to the product itself. ISO 14001 sets out the criteria for an Environmental Management System (EMS). It does not state requirements for environmental performance,  but maps out a framework that a company or organization can follow to set up an effective EMS. It can be used by any organization that wants to improve resource efficiency, reduce waste, and drive down costs. Using ISO 14001 can provide assurance to company management and employees as well as external stakeholders that environmental impact is being measured and improved. ISO 14001 can also be integrated with other management functions and assists companies in meeting their environmental and economic goals.

ISO 14001 is voluntary, with its main aim to assist companies in continually improving their environmental performance, while complying with any applicable legislation. Organizations are responsible for setting their own targets and performance measures, with the standard serving to assist them in meeting objectives and goals and in the subsequent monitoring and measurement of these. The standard can be applied to a variety of levels in the business, from organizational level, right down to the product and service level. Rather than focusing on exact measures and goals of environmental performance, the standard highlights what an organization needs to do to meet these goals. ISO 14001 is known as a generic management system standard, meaning that it is relevant to any organization seeking to improve and manage resources more effectively. This includes:

  • single-site to large multi-national companies
  • high-risk companies to low-risk service organizations
  • manufacturing, process, and the service industries, including local governments
  • all industry sectors including public and private sectors
  • original equipment manufacturers and their suppliers.

Plan Do Check Act Methodology of EMS

Plan–establish objectives and processes required

Prior to implementing ISO 14001, an initial review or gap analysis of the organization’s processes and products is recommended, to assist in identifying all elements of the current operation and, if possible, future operations, that may interact with the environment, termed “environmental aspects” . Environmental aspects can include both direct, such as those used during manufacturing, and indirect, such as raw materials. This review assists the organization in establishing their environmental objectives, goals, and targets, which should ideally be measurable; helps with the development of control and management procedures and processes; and serves to highlight any relevant legal requirements, which can then be built into the policy .

Do–implement the processes

During this stage, the organization identifies the resources required and works out those members of the organization responsible for the EMS’ implementation and control . This includes establishing procedures and processes, although only one documented procedure is specified related to operational control. Other procedures are required to foster better management control over elements such as documentation control, emergency preparedness and response, and the education of employees, to ensure that they can competently implement the necessary processes and record results . Communication and participation across all levels of the organization, especially top management, is a vital part of the implementation phase, with the effectiveness of the EMS being dependent on active involvement from all employees.

Check–measure and monitor the processes and report results

During the ‘check’ stage, performance is monitored and periodically measured to ensure that the organization’s environmental targets and objectives are being met. In addition, internal audits are conducted at planned intervals to ascertain whether the EMS meets the user’s expectations and whether the processes and procedures are being adequately maintained and monitored.

Act–take action to improve performance of EMS based on results

After the checking stage, a management review is conducted to ensure that the objectives of the EMS are being met, the extent to which they are being met, and that communications are being appropriately managed; and to evaluate changing circumstances, such as legal requirements, in order to make recommendations for further improvement of the system . These recommendations are incorporated through continual improvement: plans are renewed or new plans are made, and the EMS moves forward.

Continual Improvement Process

The core requirement of a continual improvement process (CIP) is different from the one known from quality management systems. CIP in ISO 14001 has three dimensions:

  1. Expansion: More and more business areas get covered by the implemented EMS.
  2. Enrichment: More and more activities, products, processes, emissions, resources, etc. get managed by the implemented EMS.
  3. Upgrading: An improvement of the structural and organizational framework of the EMS, as well as an accumulation of know-how in dealing with business-environmental issues.

Overall, the CIP concept expects the organization to gradually move away from merely operational environmental measures towards a strategic approach on how to deal with environmental challenges.

Concepts of environmental control:

We all have an impact on the environment by the mere act of living from day-to-day. An EMS, in its simplest form, asks us to control our activities so that any environmental impacts are minimized.However unstructured approach may lead us to improve in the wrong direction or, indeed, may leave us without any clear direction at all. It is tempting to control and minimize those impacts we feel we can tackle easily. Our attitude towards environmental issues is influenced by a topical environmental event, and therefore, we can be influenced to act without thoroughly understanding some of the more complex issues. We may focus on, and minimize, environmental impacts which are trivial in nature compared with other impacts which are far more significant and require more considered thought processes. Unless a structured approach is taken the organization may focus on what it believes to be its environmental impacts, a belief based upon ‘gut feel’ and ease of implementation. In reality, this does not address real issues but promotes a ‘green’ feel-good factor or perceived enhancement of image – both internal and external to the organization – which is not justified. For example, a company engaged in the extraction of raw materials by mining may have an environmental objective to save energy. By implementing a ‘save energy by switching off lights’ campaign in its site offices it may feel it  has achieved ‘green’ status and may proudly boast of such an environment friendly approach. There will be some energy saved by administration personnel switching off lights and heating when they are not being used for long periods. However, such savings in energy are trivial compared to the massive impact that the mining industry has on the environment: the visible impact of the site and surrounding land,  the associated increased noise levels from the operation of such a site, the high use of energy both in extraction technology and transport activities, the use of chemicals in the purification process and of course, the use of non-renewable resources (the raw material that is being mined). Unless the mining company considers the relative scale and significance of environmental impacts, then by claiming to be ‘green’ it has really missed the whole point of environmental control and impact minimization.An organization must move away from this ‘gut feel’ approach to a structured system that demands as a minimum from the organization, an understanding of the concepts behind and strong linkages between:

  • Identifying all environmental aspects of the organization’s activities.
  • Using a logical, objective (rather than subjective) methodology to rank such aspects into order of significant impact upon the environment.
  • Focusing the management system to seek to improve upon and minimize such significant environmental impacts.

Benefits of ISO 14001

ISO 14001 was developed primarily to assist companies with a framework for better management control that can result in reducing their environmental impacts. In addition to improvements in performance, organizations can reap a number of economic benefits including higher conformance with legislative and regulatory requirements  by adopting the ISO standard. By minimizing the risk of regulatory and environmental liability fines and improving an organization’s efficiency, benefits can include a reduction in waste, consumption of resources, and operating costs. Secondly, as an internationally recognized standard, businesses operating in multiple locations across the globe can leverage their conformance to ISO 14001, eliminating the need for multiple registrations or certifications. Thirdly, there has been a push in the last decade by consumers for companies to adopt better internal controls, making the incorporation of ISO 14001 a smart approach for the long-term viability of businesses. This can provide them with a competitive advantage against companies that do not adopt the standard ). This in turn can have a positive impact on a company’s asset value. It can lead to improved public perceptions of the business, placing them in a better position to operate in the international marketplace . The use of ISO 14001 can demonstrate an innovative and forward-thinking approach to customers and prospective employees. It can increase a business’s access to new customers and business partners. In some markets it can potentially reduce public liability insurance costs. It can serve to reduce trade barriers between registered businesses. There is growing interest in including certification to ISO 14001 in tenders for public-private partnerships for infrastructure renewal.

Conformity Assessment

ISO 14001 can be used in whole or in part to help an organization (for-profit or not-for-profit) better manage its relationship with the environment. If all the elements of ISO 14001 are incorporated into the management process, the organization may opt to prove that it has achieved full alignment or conformity with the international standard, ISO 14001, by using one of four recognized options. These are:

  1. make a self-determination and self-declaration, or
  2. seek confirmation of its conformance by parties having an interest in the organization, such as customers, or
  3. seek confirmation of its self-declaration by a party external to the organization, or
  4. seek certification/registration of its EMS by an external organization.

ISO does not control conformity assessment; its mandate is to develop and maintain standards. ISO has a neutral policy on conformity assessment. One option is not better than the next. Each option serves different market needs. The adopting organization decides which option is best for them, in conjunction with their market needs.

Option 1 is sometimes incorrectly referred to as “self-certify” or “self-certification”. This is not an acceptable reference under ISO terms and definitions, for it can lead to confusion in the market. The user is responsible for making their own determination. Option 2 is often referred to as a customer or 2nd-party audit, which is an acceptable market term. Option 3 is an independent third-party process by an organization that is based on an engagement activity and delivered by specially trained practitioners. The fourth option, certification, is another independent third-party process, which has been widely implemented by all types of organizations. Certification is also known in some countries as registration. Service providers of certification or registration are accredited by national accreditation services such as NABCB in INDIA or UKAS in the UK.

Structure of ISO 14001:2004

ISO 14001 requires organizations to identify the environmental aspects of their activities, products or services and to evaluate the resulting impacts on the environment, so that objectives and targets can be set for controlling significant impacts and for improving environmental performance.ISO 14001 specifies the EMS requirements that an organization must meet in order to achieve certification by a third party – the certification body. (The Standard was specifically designed to be an auditable standard leading to independent certification.)

The requirements of ISO 14001 include:

  • Development of an environmental policy
  • Identification of environmental aspects and evaluation of associated environmental impact
  • Establishment of relevant legal and regulatory requirements
  • Development and maintenance of environmental objectives and targets
  • Implementation of a documented system, including elements of training, operational controls and dealing with emergencies
  • Monitoring and measurement of operational activities
  • Environmental internal auditing
  • Management reviews of the system to ensure its continuing effectiveness and suitability

The six main clauses of ISO 14001 are titled as follows:
4.1 General Requirements
4.2 Environmental Policy
4.3 Planning
4.4 Implementation and Operation
4.5 Checking and Corrective Actions
4.6 Management Review

ISO 14001 implementation cycle

ISO 14001 implementation cycle for continuous improvement

ELEMENT-BY-ELEMENT GUIDANCE

ISO 14001 Requirement: 4.1 General requirements

An organization must establish, document, implement, and continually improve their environmental management system and show how they meet all the requirements of this standard. The organization defines the scope of the EMS, i.e. the boundaries of the organization to which the EMS applies.

ISO 14001 Requirement: 4.2 Environmental Policy

The organization must have a policy, or commitment statement, developed by top management relative to the scope of the EMS that conforms to the standard. This is generally a short statement that drives the remainder of the EMS. There are specific items that must be committed to in the policy, such as compliance with legal and other requirements, prevention of pollution, and continual improvement. In addition, the policy must be communicated to all employees, and others working on behalf of the organization, and be available to the public. The policy provides a framework for reviewing objectives and targets and be appropriate to the nature and scale of the entity included in the scope. This policy must be documented, implemented, and maintained. This means that it is kept current through the EMS review and continual improvement process, and is implemented through the remainder of the EMS elements.

ISO 14001 Requirement: Planning- 4.3.1 Environmental Aspects

This element requires a procedure to identify environmental aspects and related impacts that the organization can control or have influence over, and determine those which are significant to the organization. ISO 14001 does not prescribe what aspects should be significant, or even how to determine significance. However, it is expected that a consistent and verifiable process is used to determine significance. Aspects are defined as how an organization’s activities products and/or services interact with the environment. An impact is how an aspect changes the environment. The intent of this element is to help the organization identify how it affects the environment, prioritize aspects, and use the EMS to manage, control, and improve upon the aspects.So the organization must ensure that the significant aspects are taken into account in the EMS. In order to ensure that the system is continually improving and current, this information must be kept up to date.

ISO 14001 Requirement: 4.3.2 Legal and Other Requirements

This is a requirement for a procedure that explains how the organization obtains information regarding its legal and other requirements, and makes that information known to key functions within the organization. The intent of this element is to identify the environmental legal and other requirements that pertain to its operations and activities so that the organization can ensure that they are taken into account in the EMS. In doing so, the organization must also determine how these requirements apply to the significant aspects.

ISO 14001 Requirement: 4.3.3 Objectives, Targets, and Programs

There is no requirement for a procedure in this element. However, there must be some process that ensures that the objectives and targets are consistent with the policy, which includes the commitments to compliance with legal and other requirements, continual improvement, and prevention of pollution. Also, the organization must take into consideration significant aspects, legal and other requirements, views of interested parties, and technological, financial, and business issues when deciding what it wishes to accomplish as an objective. The objectives and targets need to exist at whatever functions and levels of the organization, and be measurable, where practicable. Management programs (MPs) are the detailed plans and programs explaining how the objectives and targets will be accomplished. These MPs usually note responsible personnel, milestones and dates, and measurements of success. Noting monitoring and measurement parameters directly in the MP facilitates conforming to 4.5.1 on Monitoring and Measurement discussed below. MP’s are required for the objectives and targets in an EMS.

ISO 14001 Requirement: 4.4.1 Structure and Responsibility

ISO 14001 requires that the relevant management and accountability structure be defined in this element. Top Management is expected to ensure that resources are available so that the EMS can be implemented, maintained, and improved. These resources include human resources, organizational structure, financial and technological resources, and others as needed. Roles, responsibilities, and authorities must be defined, documented and communicated as appropriate. The organization must denote the Management Representative who is responsible to oversee the EMS and report to management on its operation. This person(s) ensures that the EMS is established, implemented and maintained consistent with ISO 14001, and also reports to top management on the performance of the system including recommendations for improvement.

ISO 14001 Requirement: 4.4.2 Competence, Training, and Awareness

The key point in this element is to ensure that persons performing tasks that have or can have significant impact on the environment and/or relate to the legal and other requirements are competent to do those tasks. Competence is ensured through appropriate education, training, and/or experience. The organization needs to identify training needs as they relate to the EMS, the significant aspects, and the legal and other requirements and make sure this training is provided (records of such are to be maintained). A procedure is needed that makes sure such persons are: aware of the need to conform with all EMS procedures and requirements and what they specifically need to do to do so; the significant aspects and the legal and other requirements associated with their respective responsibilities and why improved performance is beneficial; and the consequences of not following these procedures and requirements. In addition to job-specific knowledge, it expected that all personnel within the EMS (including contractors) have general awareness on items such as the policy and emergency response.

ISO 14001 Requirement: 4.4.3 Communications

Procedures are required for both internal and external communications. Note that ISO 14001 only requires procedures, and allows the organization to decide for itself the degree of openness and disclosure of information. Whatever the decision is in terms of disclosure, the decision process must be recorded. There is a specific requirement that the organization consider external communications about its significant environmental aspects and record its decision. For internal communications, the procedure needs to describe how it is done among the levels of the organization. For external communications, it has to describe how external communications are received, documented, and a response provided.

ISO 14001 Requirement: 4.4.4 EMS Documentation

This requirement ensures that the organization has documented the system in either electronic or paper form such that it addresses the elements of the standard, describes how the organization conforms to each element, and provides direction to related documentation. Not all ISO 14001-required procedures need to be documented, as long as the system requirements can be verified. However, documentation must be provided such that enough is available to ensure the effective planning, operation, and control of processes related to the significant aspects, and to demonstrate conformance to ISO 14001. Such documentation at a minimum includes policy, objectives and targets, a definition of the scope of the EMS, and other main elements.

ISO 14001 Requirement: 4.4.5 Control of Documents

The organization is required to control documents, such as system procedures and work instructions, to ensure that current versions are distributed and obsolete versions are removed from the system. There is a requirement for a document control procedure that ensures documents are approved prior to use, are reviewed and updated as necessary, changes to versions are identified, that the current versions are available at points of use, that they are legible, identifiable, and that obsolete ones are so noted to avoid unintended use. It is acceptable to use documents of internal origin in the EMS, but those must be identified as being essential to the EMS and their distribution controlled.

ISO 14001 Requirement: 4.4.6 Operational Control

For this element, critical functions related to the policy, significant aspects, the legal and other requirements, and objectives and targets are identified and procedures and work instructions are required to ensure proper execution of activities. Requirements for communicating applicable system requirements to contractors also need to be addressed in these procedures. The required procedures need to provide instruction such that the organization conforms to the policy, objectives and targets, the legal and other requirements, and addresses any impacts from significant aspects. Which procedures are needed can be determined by review of the significant aspects, objects and targets, the legal and other requirements, and policy and then deciding what must be proceduralized and documented to ensure that deviations from planned arrangements do not occur. In regard to the contractors, the organization will need to establish procedures related to the significant aspects the legal and other requirements, of the goods and services it uses, and communicating the relevant elements of those procedures to the suppliers and contractors.

ISO 14001 Requirement: 4.4.7 Emergency Preparedness and Response

Although typically addressed through conventional emergency response plans, this
element also requires that a process exist for actually identifying the potential emergencies, in addition to planning and mitigating them. Emergency incidents include those that may not be regulated, but may still cause significant impact as defined by the organization. As part of continual improvement, it is required that the organization not only responds to emergency situations, but also reviews the emergency procedures and make improvements as necessary. This may involve periodic testing of emergency procedures, if practicable.

ISO 14001 Requirement: 4.5.1 Monitoring and Measurement

In order to properly manage the system, measurements must be taken of its performance to provide data for action. Procedures are required describing how the organization will monitor and measure key parameters of operations. These parameters relate to the operations that can have significant impacts, to monitor performance towards the objectives and targets, and to monitor conformance to the legal and other requirements and other EMS requirements.Equipment related to environmental measurements, such as temperature and pH meters and pressure gauges, must be calibrated according to procedures, and records maintained.

ISO 14001 Requirement: 4.5.2 Evaluation of Compliance

The first part of this element (4.5.2.1) requires the organization to have a procedure(s) to periodically evaluate its compliance with applicable legal requirements as defined in 4.3.2. The organization will need to keep records of these periodic evaluations. ISO 14001 in 4.5.2.2 also requires a similar evaluation for compliance with other requirements. Again these are defined in 4.3.2 and the procedure can be the same as, and even part of, 4.5.2.1.

ISO 14001 Requirement: 4.5.3 Non-conformances, Corrective and Preventive Action

This element requires procedures for acting on non-conformances identified in the system, including corrective and preventive action. A non-conformance is a situation where the actual condition is not in accordance with planned conditions. Someone not following a procedure, a regulatory non-compliance, or an incident, is all examples of possible systemic non-conformances. Non-conformances may be identified through audits, monitoring and measurement, and communications. The intent is to correct the system flaws by addressing root causes, rather than just fixing the immediate incident only. The standard also requires that trends in corrective actions be evaluated to see if deeper-rooted preventive actions can also be implemented. The procedure needs to make sure the non-conformances are not only first addressed to mitigate environmental impact; but that further investigation occurs to determine their cause, and action taken to avoid it happening again. Preventive actions would then be those actions resulting from an evaluation as to why nonconformities are occurring and taking action to prevent their recurrence. The standard states that the corrective action is appropriate to the magnitude of the problem and the impacts encountered; to avoid either over-compensating or under-compensating for a problem. The organization must record the results of corrective actions taken, and must also review the effectiveness of actions taken

ISO 14001 Requirement: 4.5.4 Control of Records

Records are expected to exist to serve as verification of the system operating and the organization’s conformance to the standard and its own EMS requirements. Procedures in this element are required for the maintenance of records, and specifically require that records are identifiable, retrievable, safely stored, and legible, retained as appropriate, and traceable.

ISO 14001 Requirement: 4.5.5 Internal Audit

ISO 14001 requires that the system provide for internal audits. This procedure could include methodologies, schedules, checklists and forms, and processes used to conduct the audits. The purpose of this audit is to determine whether the system conforms to the requirements of ISO 14001 and the organization’s own EMS detailed requirements, and if the EMS has been properly implemented and maintained. The procedure for internal audits has to address responsibilities and requirements for planning and executing the audits, reporting results, and what records will be generated (and maintained in accordance with 4.5.4). The procedures also address determination of audit scope, how often they will be conducted, and specifically how they will be done. Auditors need to be selected such that it ensures objectivity and impartiality of the audit process.

ISO 14001 Requirement: 4.6 Management Review

This element requires that periodically, top management will review the EMS to ensure it is operating as planned, and is suitable, adequate, and effective. The organization needs to ensure that in the review: results of internal audits (EMS and compliance); external communications; environmental performance; status on objectives and targets; status of corrective and preventive actions; follow up on actions from prior management reviews; and changing conditions or situations; and recommendations for improvement are all discussed. Results and records of management review include: agendas, attendance records, minutes, and documented agreed upon action items.

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