ISO 14001-Clause 4.4.4 Documentation
ISO 14001 Requirements
The environmental management system documentation shall include
- the environmental policy, objectives and targets,
- description of the scope of the environmental management system,
- description of the main elements of the environmental management system and their interaction, and reference to related documents,
- documents, including records, required by this International Standard, and
- documents, including records, determined by the organization to be necessary to .ensure the effective planning, operation and control of processes that relate to its significant environmental aspects.
To ensure that your EMS is well understood and operating as designed, you need to get information to the people doing the work. In addition, there are external parties that might need to understand how your EMS operates, such as customers, registrars, regulators, lending institutions, and the public. EMS documentation can be viewed as a series of explanations or statements of how EMS criteria (such as ISO 14001) apply to your organization. While you don’t need to maintain a single “manual”, you should maintain EMS information in a form that:
- describes the core elements of your EMS and how these elements relate to each other, and
- provides direction to related documentation.
You can maintain this documentation either on paper or electronically. There may be some advantages to maintaining documents electronically, such as easier updating, access control, and ensuring that the most upto-date version of a document is used by all readers. EMS documentation is related to but is not the same as EMS records. EMS documentation describes what your system consists of i.e., what you do, while EMS records demonstrate that you are doing what you said you would do. There is no laid down format and each organization should develop its own style that it can work with. However, there are, within industry and commerce, certain styles based upon years of experience which are better than others. Meeting the needs of the organization and complying with the Standard is the first consideration, being open to audit is a close second. The organization shall establish and maintain information, in paper or electronic form, to:
- describe the main elements of the environmental management system and their interaction
- include documentation required by ISO 14001
- documentation determined by the organization itself
- records required by ISO 14001
- provide direction (or reference) to related documentation.
Keep your EMS documentation simple and choose a format that works best for your organization. The documentation does not need to describe every detail of your EMS or how your organization conforms to the ISO 14001 Standard or other EMS criteria. Instead, consider providing references to other documents or procedures. Use the results of your preliminary assessment to prepare your EMS documentation. In the course of conducting the preliminary assessment, you should have collected or prepared useful material on how your organization satisfies the EMS criteria. The usefulness of your EMS documentation can be improved by including the organization’s mission statement, vision, guiding principles, and annual objectives. These will help readers understand the organizational context and how the EMS supports overall business goals. An EMS manual can be a useful tool for explaining your EMS to new employees, customers, or others. EMS documentation should be updated as needed, based on any system improvements you put in place. However, if you put too much detail in an EMS manual, you may have to update the manual frequently. The following briefly outlines a practical documented system structure but leaves the detailed style of the environmental manual, procedures, work instructions, etc. to the implementing organization.
Level 1 – The policy
Level 2 – The environmental manual and Environmental Management System Procedures
The environmental manual
This can be a rather brief document, which need only include the environmental policy and a broad description of how the organization has addressed the requirements of the Standard. As a document, with no commercially sensitive information, it can be sent to customers or other interested parties (at little cost) and is, in fact, a good marketing aid. The opportunity should be taken to show how, for each clause of the Standard, the organization has procedures in place and decision-making processes. These should be referenced. This has the double benefit of showing interested parties (including external auditors) exactly how the Standard is addressed and, more importantly, making this clear for the organization itself. Obviously, when compiling the environmental manual, if the organization cannot assign a procedure or a methodology of working to one of the clauses of the Standard then this must demonstrate a gap in the environmental management system.Certainly, the concept of a ‘signpost document’ is a good analogy and this concept is encouraged by certification bodies.
Environmental management system procedures
The procedures will tend to dominate the bulk of the whole documented system. However, efforts should be made again to signpost, if possible, other existing systems. This is preferable to writing a new procedure or instruction when the existing one is adequate. An outline process for the establishment of a procedure could be:
The identification of a procedure will probably evolve from the management system identifying environmental impacts (ranking for significance, setting objectives and targets to reduce such impacts) and the operational controls necessary to measure, monitor, control and minimize such impacts. All these activities will need documenting in the form of procedures.
An individual, following procedure identification, actually has to write the procedure. This is not a daunting task provided there are inputs from personnel who are involved (or will be involved) in operating the procedure. In practical terms, a procedure has to be workable and only those at the ‘hands-on’ level will be able to write such a workable document. This will also give ownership of the procedure at the ‘hands-on’ level. Ownership in this sense means that because the personnel using the procedure actually wrote it, they are far more likely to follow it correctly. This is not always the case if a procedure is written by an external author perhaps a consultant. Personnel may feel the procedure has been ‘thrust’ upon them and may be less willing to obey it. Procedures can be in note form – hand-written at this stage – as it is likely that changes will be required during the pilot phase.
Experience shows that it is extremely difficult for an individual to write down their daily tasks; they are of such a second nature that it is easy to make omissions, or to put the steps of a process in the wrong order. Therefore, the procedure should be piloted by other personnel. There may be subtle interfaces or interactions with other personnel or other procedures that the original authors had not considered because they are too close to their own area of responsibility.
It is inevitable that revisions will be required. For example, simple errors may need correcting; gaps in lines of communication may have been discovered; a new perspective may have been added.It is important that all those personnel using the procedure understand its purpose. Some time should be invested in training personnel, introducing the reason for the procedure should be the focus of such training.
Last but by no means least, the procedure once written, piloted, revised and implemented needs to be verified as to its effectiveness. This can only be checked by an independent internal audit and the rule of the ‘6 Ws’ is good guidance to follow. When writing a procedure, if it addresses the following questions, then it is likely to be meaningful and robust:
- What does the procedure require?
- When does the procedure need to be followed?
- Where do the activities take place?
- Whom does the procedure apply to?
- Why is the procedure carried out?
- How are the activities carried out?
Finally, although procedures have been discussed as being ‘written’, process charts or flow charts can be used instead.
Level 3 – Environmental work instructions/specific routines
It is not mandatory for the organization to include environmental work instructions in its documentation hierarchy if it is not appropriate to the business. However, in an organization with many processes, comprising of levels of alternative routes or recipes, there may be a need for separate, more specific and detailed ‘routines’ for operators. Otherwise, they may find it difficult to locate the relevant section contained within just one long procedure. This could lead to an environmental incident. Therefore, a work instruction at the point of the operation is a good idea. Anote above a drainage sink, to remind operators that locally produced acidic waste liquids must not be poured down the sink, is a type of work instruction. If work instructions become obsolete, and they are followed by an operator, then an environmental incident might occur. Obviously such instructions must be controlled as to revision status and location on the site.
Level 4 – Forms and documents
very organization uses forms be they hard copy or electronic. Forms allow personnel to record information in a structured manner so that other personnel can read and use this information. Forms also remove the requirement for the individual to remember every piece of information given. This means that less errors will occur in the management system as the system is not dependent on the frailty of the human memory. Well-designed forms can act as a prompt for individuals to record the correct quantity of information as well as the quality that is, the usefulness of that information. Therefore, it makes sense to control the information demanded by the form so that nothing important is overlooked. Forms may be revised many times throughout their life to cope with changing circumstances. Such forms should be controlled, so that if a form is revised this should be indicated on it (Revision 1, 2, etc.). Of course, the organization should review the ‘significance’ of the information on the forms and if it is deemed to be trivial, then there is no need to control such a form. It is good practice for any organization to review all the forms it uses, make a list and analyse what function each form performs. Most organizations who perform this task actually end up with less forms in circulation. The remaining forms are more focused in their purpose. The reference to ‘documents’ covers all other ‘reading matter’ that the organization refers to in its environmental operations and decision making processes. This could include copies of international standards, machine operation manuals, codes of practice, tables of calculations, etc. Again, the organization should review which documents are significant in terms of the information they contain and, where appropriate, ensure that they are given a controlled status. These manuals, procedures, work instructions and appropriate forms must ultimately be issued to personnel in a controlled fashion and this is addressed by the next sub-clause.
- Does your organisation’s environmental management system documentation include the environmental policy, objectives and targets?
- Does your organisation’s environmental management system documentation include a description of the scope of the environmental management system?
- Does your organisation’s environmental management system documentation include a description of the main elements of the environmental management system, their interaction and reference to related documents?
- Does your organisation’s environmental management system documentation include documents and records required by the Standard?
- Does your organisation’s environmental management system documentation include documents, including records, necessary for the effective planning, operation and control of processes related to its significant aspects?
- How is EMS documentation maintained?
Implementation document ( Not mandatory but helps in fulfillment of requirement):
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