ISO 14001-Clause 4.4.6 Operational Control
ISO 14001 Requirements
The organization shall identify and plan those operations that are associated with the identified significant environmental aspects consistent with its environmental policy, objectives and targets, in order to ensure that they are carried out under specified conditions, by
- establishing, implementing and maintaining a documented procedure(s) to control situations where their absence could lead to deviation from the environmental policy, objectives and targets, and
- stipulating the operating criteria in the procedure(s), and
- establishing, implementing and maintaining procedures related to the identified significant environmental aspects of goods and services used by the organization and communicating applicable procedures and requirements to suppliers, including contractors.
To ensure that your environmental policy is followed and that your objectives are achieved, certain operations and activities must be controlled. Where an operation or activity is complex and/ or the potential environmental impacts are significant, these controls should take the form of documented procedures. Procedures can help your organization to ensure regulatory compliance and consistent environmental performance. Procedures can also play a key role in employee training.Documented procedures should cover those situations where the absence of procedures could lead to deviations from the environmental policy or your objectives and targets. Determining which operations should be covered by documented procedures and how those operations should be controlled is a critical aspect of developing an effective EMS. In deciding which activities need to be controlled, look beyond routine production on the shop floor. Activities such as maintenance, management of on-site contractors, and relationships with suppliers or vendors could affect your organization’s environmental performance significantly.
The ISO 14001-Clause 4.4.6 requires identification of operations and activities that are associated with the identified significant environmental aspects of the organization in line with the environmental policy, its objectives and targets. In effect, procedures are required to control and verify all functions, activities and processes which have or could have, if uncontrolled, a significant impact direct or indirect on the environment. Environmental impacts of the organization’s suppliers come under the controls exercised under ISO 14001-Clause 4.4.6, as do those of contractors coming on-site or contractors used by the implementing organization. This is especially so if the supplier’s or contractor’s methods of working are known to conflict with the organization’s environmental policy. Contractors may not be aware of the environmental consequences of certain actions for example, dumping their waste into skips without segregation, or operating noisy drills in the evening when the organization may in fact have come to some arrangement with their neighbours not to do so. Many organizations have induction sessions for contractors as a matter of course for example, on health and safety issues so environmental awareness could be included in this existing mechanism. However, the principle of significance should be considered when deciding what controls to put in place. For example, the contractor who comes on-site to clean office windows should receive less attention than the contractor who is laying new cables or drainage pipes on-site. Organizations with existing ISO 9000 quality assurance ‘process control’ procedures should avoid merely relabeling some of these process control procedures as ‘operational control’.
Start by looking at the environmental aspects and potentially significant impacts which you identified earlier. Identify the processes from which these significant impacts arise, and consider what types of controls might be needed to prevent or manage these impacts. If you have flowcharts of these processes, identify the points in each process where some type of control may be appropriate. Prepare draft procedures and review them with the people who will need to implement them. This will help to ensure that the procedures are accurate and realistic.Look at procedures you already have in place to comply with environmental and health & safety regulations. Some of these may be adequate to control significant impacts or could be modified to do so. Develop a chart to keep track of what is needed. The more highly skilled and trained your employees are, the less critical procedures will be. The more complex the work or the greater the potential impact on the environment, the more important these procedures will be. Once you have identified operations that require control, consider what kinds of maintenance and calibration may be appropriate. However, the need for maintenance on equipment that could have significant environmental impacts should be obvious, and the need to plan and control such maintenance should not be overlooked. This does not mean that an elaborate preventive or predictive maintenance program is needed in all cases. Assess your existing maintenance program and its effectiveness before making significant changes.Some of your identified environmental aspects may be related to the chemicals, raw materials, or other goods and services you obtain from vendors/suppliers. Likewise, the activities of your contractors can affect your environmental performance. Communicate your expectations including any relevant procedures to these business partners. If your organization uses a “work team” concept, ask the work teams to draft procedures for their areas or to modify existing procedures for EMS purposes.
Examples of operational control procedures
Procedures should state who is responsible for ensuring legal compliance when waste is removed from site. The procedure should reference how the appropriate documentation is completed correctly and filed away for the prescribed period of time. Locations for the storage of waste should be described and instructions as to how segregation of waste is to be carried out described. Procedures should detail further whether certain waste skips need to be protected from high winds and rain – which could blow or dissolve and wash some waste materials down surface water drains. Inspections of waste skips on site should be inspected for rust. Such deterioration could decrease their load bearing capacity or integrity, which could allow waste materials to fall onto public roads when being transported to the landfill site. Best practice is to also conduct audits of waste carriers and landfill sites. This can range from a desktop review of waste carrier and landfill licences, to a physical audit of tracing an actual waste removal from site to the landfill site. Such an audit trail would also involve checking records and documentation, such as waste transfer notes. Landfill site licences generally are very specific in describing what is accepted at each site, and detail requirements for generating and maintaining records of waste. This can be further extended to inspection of the waste carriers transport, i.e. lorries and wagons for roadworthiness and whether the driver has a spillage kit and is trained to use it in the event of a spillage onto a public road. These are all best practical steps to prevent pollution and also avoid adverse publicity from the media and unwanted attention from the regulatory body.
The European Directive on packaging waste places requirements on companies to recover certain percentages of waste and recycle set amounts. Companies can administer this themselves or join a compliance scheme. A procedure for the operational control of this waste should detail the responsible person who collects the data on packaging waste. Additionally,details of the prescribed time intervals for submission of this data to the regulatory authority should be included.
Contractors coming on site
The procedure should detail the requirements for contractors working on the site. A good practice is to show a brief video presentation of the organizations environmental procedures, followed by a test of understanding. Additionally, information packs should be issued containing for example:
- Site contact names and internal phone numbers (for environmental issues)
- What to do in an emergency
- list of actions which would be unacceptable such as disposal of waste into the site drainage system, burning of waste and not leaving the engine of vehicles running unnecessarily
Sub-contractors should sign a document as evidence they have understood the above.
A procedure for the purchasing department could include a list of the environmental responsibility criteria required of the organization’s suppliers. Meeting such criteria would be a part of purchasing negotiations between the organization and the supplier. The objective would be to stipulate grades of material that have low environmental impacts in production, use and disposal. Of course, the organization cannot merely use environmental criteria and nothing else. As stated earlier, the purpose of the Standard is not to prevent a business being successful. The commercial activities of the organization are paramount and must always come first in any decision-making event. If the business closes down then there is no environmental management system! For example, the procedure could detail that all existing suppliers be sent a questionnaire about their environmental probity as a first objective to obtain initial information. The procedure would then be written along the lines previously described.
Although bunding is built around storage vessels with the purpose of preventing leakage of the contents and, therefore, avoiding an environmental incident, in reality it may create a false sense of security. Maintenance may not be carried out because of this misplaced sense of security. The operational control procedure should be in the form of an inspection programme, and details of what action to take in the event of any damage to a bund wall.
Procedures for the inspection and maintenance of pipework and especially pipe joints should be implemented. It would be beneficial to identify which sections of pipe joints etc. could have the most significant environmental impact in the event of a failure and programme in extra inspections in these areas.
Monitoring for compliance with site licences
Although the regulatory authorities may periodically sample emissions or effluent, they would probably only issue a report or a concern in the case of non-compliance. Near misses or trends would not be a part of their reporting structure. Clearly to only rely on such reports creates environmental risks for the organization and it would therefore be best practice to have an operational control in place to periodically measure the parameters and note if there are any adverse trends emerging.
The Standard requires that any planned or new developments are considered and planned in advance so that the environment will not be compromised. Thus procedures need to be in place to give guidance in the instances of:
Construction work: Procedures should detail the forward planning and investigations necessary prior to any construction work on site. For intended excavations, operational controls should detail the responsibility for carrying out surveys not only for buried pipelines and any contaminated land, but also any ancient monuments or historic sites. The procedure should detail contacts and experts who could assist in identifying any protected species, trees and hedgerows, SSSI sites, marine habitats or controlled waters. This could include the names of agencies to be contacted if wildlife habitats are to be disturbed and any local liaison groups if the construction is in a built-up or residential neighbourhood.
Procedures should include some of the above considerations and if old buildings are the subject of demolition, then an asbestos survey should be carried out first. Such operational controls should also detail the steps to take in the event of discovering asbestos and the appropriate abnormal or emergency plans.
In the context of ISO 14001, housekeeping is taken to mean ‘the visual appearance of the site’. Procedures should focus on defining locations for movable items, defining locations for redundant equipment, where tools should be stored, locations for discarded items and waste, etc. Housekeeping inspections should be detailed as to frequency and measures of compliance. Measuring the compliance of housekeeping can be subjective, and best practice involves the use of photographs to define the level of housekeeping required, area by area. With the advent of digital photography this method of measurement is becoming widespread. Given that poor levels of housekeeping can contribute to the cause of accidents in the workplace, then some effort should be put into developing robust procedures. The certification bodies give this aspect of ISO 14001 what may seem too much attention but it is a visible sign of environmental improvement and sends a positive message to all stakeholders.
- How has your organisation identified and planned those operations that are associated with the identified significant environmental aspects in line with its policy, objectives and targets?
- How have these activities been planned, including maintenance, in order to ensure that they are carried out under specified conditions that includes establishing, implementing and maintaining documented procedures to cover situations where their absence could lead to deviations from the environmental policy and the objectives and targets?
- How have these activities been planned, including maintenance, in order to ensure that they are carried out under specified conditions that includes stipulating operating criteria in the procedures?
- How have these activities been planned, including maintenance, in order to ensure that they are carried out under specified conditions that includes establishing, implementing and maintaining procedures related to the identified significant environmental aspects of goods and services used by the organisation and communicating applicable procedures and requirements to suppliers and contractors.
|Example of Procedure for Operational Control|
Implementation document ( Not mandatory but helps in fulfillment of requirement):
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