ISO 14001-Clause 4.4.2: Competence, training and awareness
ISO 14001 Requirements
The organization shall ensure that any person(s) performing tasks for it or on its behalf that have the potential to cause a significant environmental impact(s) identified by the organization is (are) competent on the basis of appropriate education, training or experience, and shall retain associated records.
The organization shall identify training needs associated with its environmental aspects and its environmental management system. It shall provide training or take other action to meet these needs, and shall retain associated records.
The organization shall establish, implement and maintain a procedure(s) to make persons working for it or on its behalf aware of
- the importance of conformity with the environmental policy and procedures and with the requirements of the environmental management system,
- the significant environmental aspects and related actual or potential impacts associated with their work, and the environmental benefits of improved personal performance,
- their roles and responsibilities in achieving conformity with the requirements of the environmental management system, and
- the potential consequences of departure from specified procedures.
The Standard requires that the organization shall identify training needs and this clause requires that all personnel whose work may create a significant impact upon the environment have received appropriate training.There are two excellent reasons for training employees about environmental management and your EMS:
- Every employee can have an impact on the environment.
- Any employee can have good ideas about how to improve environmental management efforts.
Each person and function within your organization can play a role in environmental management. For this reason, your training program should cast a wide net. Everyone in the organization should be trained on the environmental policy, significant environmental impacts of their work activities, key EMS roles and responsibilities, procedures that apply to their activities, and the importance of conformance with EMS requirements. All personnel should receive appropriate training. However, training is just one element of establishing competence, which is typically based on a combination of education, training, and experience. For certain key roles which includes tasks which can cause significant environmental impacts, you should establish criteria for measuring the competence of individuals performing those tasks.
Thus the organization must satisfy the following four criteria:
Ensure that training needs are identified:
This can be performed via appraisals. In most companies this is an annual event – at the very least for salary review purposes. From this training needs will be identified and a plan of either internal or external training planned. All individuals will need some level of training in the requirements of the environmental policy and a background to the requirements of ISO 14001. Some individuals will need specific training in emergency response. Others may need their roles to be changed and defined. An internal quality assurance auditor may well need to be
‘converted’ to an environmental systems auditor via an external training course.
Ensure that these planned needs are met:
There must be a system to ensure that such individual training plans are carried out as intended. Procedures will be needed to describe such mechanisms, as well as including a broader description of how the organization’s training strategy is structured. In addition to specific external courses or seminars, internal workshops and briefings are an acceptable vehicle for training. Internal environmental newsletters are also part of the range of tools available.
Verify that the training has achieved its purpose i.e. increased awareness:
This verification can be performed via feedback from training sessions: either a written report from the individual or a simple questionnaire to complete. Some organizations will ask personnel to undertake simple ‘tests’ to measure the effectiveness of the training. Other ways of verifying ‘awareness’ could be through the internal audit system. Asking questions of personnel during such audits will give an indication of their knowledge. One of the challenges can be the measurement of ‘continuous improvement’ within training. Clearly, measurable targets can be set for delivering the training, i.e. records of attendance would show who has attended such sessions. However, how can an organization ‘measure’ whether the knowledge (awareness) of personnel has ‘improved’ compared with their knowledge of say, 12 months ago?
Verify that following training, the individual is competent at applying the awareness gained to their particular job:
This can be achieved by monitoring an individual’s work, noting any improvements in work or, conversely, monitoring any persistent failure to absorb such training for example, by not being aware of the consequences of departure from a specific work instruction. Contractors, working on behalf of the organization, must also be subject to training requirements and this must be addressed in the training procedures. The employees of the contractor should have a certain level of training , that level to be determined by the organization. For both contractors and the organization itself, it must be kept in mind that the concept of significance must be applied to any training plans or programmes. The individual who is in an environmental front-line position – whose actions have the potential to cause a major impact on the environment – should have priority in environmental training followed by a more intensive scrutiny of awareness and competence than the individual whose actions have little potential to impact on the environment.Further, if for example an individual is trained to operate a pH meter to check effluent pH, clearly both awareness and competence can be verified by giving the individual a sample of liquid of known pH and asking him to test it. If the results are correct it would tend to demonstrate that the training was successful.
A critical first step in developing your training program is assessing your training and skill needs. In assessing these needs, you should consider both general and specific aspects. For e.g., What EMS procedures affect Operator’s daily work and what happens if they aren’t followed? What environmental impacts might Operator’s work cause? What broader understanding of environmental issues and our EMS does Operator need? Look at the training you conduct already, for compliance with environmental and health and safety regulations and other purposes. You may find that your existing training efforts go a long way towards satisfying the requirements for the EMS. Because of the level of effort involved in a training program, this is one EMS area where you don’t want to start from scratch. Many employees may already be qualified on the basis of their experience and previous training. All training should be documented. Since some employees may require training on how to run a process safely, on the job training certainly plays a role. Plan and schedule training opportunities carefully. While finding enough time for training can be a challenge, there may be creative ways to make “more time” . Use venues like safety meetings, staff meetings, and tool box meetings to provide “training” and reinforce key messages. New employees can pose a significant training challenge. Consider developing an EMS training package for new employee orientation. Even better, videotape one of your current EMS training courses to show new employees. In reviewing training needs, don’t forget to consider the qualifications and training needs of your environmental manager and your trainers. Professional certification programs may be appropriate for certain functions. Factor your EMS skills requirements into your recruiting, selection, and new employee orientation efforts. Establishing competency for various tasks can be a challenge. Competency criteria for jobs that can cause significant environmental impacts should be as objective as possible. Consider “job aids” to supplement training or help establish competence. Examples of job aids include written or pictorial job procedures, decision tables or flow charts.
Key Steps in Developing a Training Program
Step 1: Assess training needs requirements
Step 2: Define training objectives
Step 3: Select suitable programs and methods
Step 4: Prepare training plan (who, what, when, where, how)
Step 5: Implement training program
Step 6: Track training (and maintain records)
Step 7: Evaluate training effectiveness
Step 8: Improve training program (as needed)
- How does your organisation ensure that all persons working for them, or on their behalf such as staff, contractors, shift workers, casual staff, labour hire et, are competent to undertake the tasks that can cause significant environmental impacts? (Note: Assessment of competence can be on the basis of appropriate education, training and/or experience.)
- Has the organisation retained competency records such as appropriate education, training and/or experience?
- How does the organisation identify training needs associated with the significant environmental aspects and the environmental management system?
- Has training, or other actions required to meet these needs been delivered, and associated records retained?
- Has a procedure(s) been established, implemented and maintained to ensure that the people working for, or on behalf of your organisation are aware of the importance of conformity with the environmental policy and procedures and with the requirements of the environmental management system?
- Has a procedure(s) been established, implemented and maintained to ensure that the people working for, or on behalf of your organisation are aware of the significant environmental aspects and related actual or potential impacts associated with their work activities and the environmental benefits of improved personal performance?
- Has a procedure(s) been established, implemented and maintained to ensure that the people working for, or on behalf of your organisation are aware of their roles and responsibilities in achieving conformity with the requirements of the environmental management?
- Has a procedure(s) been established, implemented and maintained to ensure that the people working for, or on behalf of your organisation are aware of the potential consequences of departure from specified operating procedures?
|Example of Procedure for Competence, Training and Awareness|
|Example of format for List of Employees|
Implementation document ( Not mandatory but helps in fulfillment of requirement):
|Example of format for Employee Training Plan &Record|
|Example of format for EMS Training log and training need analysis|
|Example of format for Competency Matrix|
|Example of format for Skill Matrix|
|Example of format for Training Need Identification|
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