Home » ISO 14001:2004 EMS » ISO 14001-Clause 4.5.1, 4.5.2

ISO 14001-Clause 4.5.1, 4.5.2

ISO 14001-Clause 4.5 Checking and corrective action

Checking refers to verifying that planned actions and activities take place. Thus a robust internal audit system could be the method for this verification, but other mechanisms could be used such as reviews of reports indicating failures or delays to action plans. Corrective action within an organization is required when the above checks demonstrate failures to meet targets, with preventive measures put in place to prevent recurrence of the same failure.

ISO 14001-Clause 4.5.1, 4.5.2

ISO 14001-Clause 4.5.1 Monitoring and measurement

ISO 14001 Requirements

The organization shall establish, implement and maintain a procedure(s) to monitor and measure, on a regular basis, the key characteristics of its operations that can have a significant environmental impact. The procedure(s) shall include the documenting of information to monitor performance, applicable operational controls and conformity with the organization’s environmental objectives and targets.
The organization shall ensure that calibrated or verified monitoring and measurement equipment is used and maintained and shall retain associated records.

ISO 14001-Clause 4.5.2 Evaluation of compliance

ISO 14001 Requirements

4.5.2.1 Consistent with its commitment to compliance, the organization shall establish, implement and maintain a procedure(s) for periodically evaluating compliance with applicable legal requirements.
The organization shall keep records of the results of the periodic. evaluations,

4.5.2.2 The organization shall evaluate compliance with other requirements to which it subscribes. The organization may wish to combine this evaluation with the evaluation of legal compliance referred to in 4.5.2.1 or to establish a separate procedure(s).
The organization  shall keep records of the results of the periodic evaluations,

 Explanation:

Monitoring in the sense of ISO 14001 means that the organization should check, review, inspect and observe its planned activities to ensure that they are occurring as intended. So the management programme or programmes for environmental improvement cannot be said to be achieving anything unless the starting.
This requirement of the Standard is for an organization to establish and maintain 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. It is important to understand the differences between monitoring and measurement to comply fully with the Standard. Monitoring generally means operating processes that can check whether something is happening as intended or planned. In some respects auditing processes address this, but also operational control procedures will apply. Thus if an operational control states that housekeeping audits will occur twice weekly then this is a monitoring process, i.e. the site is checked weekly for ‘good housekeeping practices’. This could also involve ‘visual’ checking of the integrity of bunding around solvent storage tanks for example. Measurement tends to mean that the size or magnitude of an event is measured, calculated or estimated with a numerical value assigned. This could include procedures for weighing wastes sent to landfill; amount of gas or electricity consumed per week, measuring noise levels at the site boundary etc. Additionally, any equipment used to calculate or estimate such numbers should be suitably calibrated so that a high level of confidence is gained that the numbers are indeed a true representation of the facts. An EMS without an effective monitoring and measurement program is like driving at night without the headlights on — you know that you are moving but you can’t tell where you are going. Monitoring and measurement enables you to:

  • gauge your environmental performance;
  • analyze root causes of problems;
  • identify areas where corrective action is needed; and,
  • improve performance / increase efficiency.

ISO 14001-Clause 4.5.2 Evaluation of compliance which links to clause 4.3.2 Legal and other requirements to ensure that breaches of such applicable environmental legal requirements do not occur. This clause is best addressed by having robust procedures in place to periodically review the level of compliance to those operational controls, or work instructions, which specify activities to ensure legal compliance. Thus, as an example, a work instruction may detail that samples of effluent are checked daily in the site laboratory to check that heavy metal concentrations are not progressively rising, which could lead to a breach of the consent parameters, hence a breach of legislation. By auditing such an instruction and reviewing results obtained, then an evaluation can be performed. Audit checklists should indicate clearly that compliance was verified. If during this audit an area is identified where there is not full compliance with legislation, then corrective and preventive actions should be identified and executed to ensure a return to full compliance.
In short, monitoring helps you manage your business better. Pollution prevention and other strategic business opportunities are identified more readily when current and reliable data is available. Your organization should develop procedures to:

  • monitor key characteristics of operations and activities that can have significant environmental impacts;
  • track performance (including how well you meet your objectives and targets);
  • calibrate and maintain monitoring equipment; and,
  • through internal audits, periodically evaluate your compliance with applicable laws and regulations.

Monitoring and measuring can be resource-intensive. One of the most important steps you can take is to clearly define your needs. While collecting information is clearly important, resist the urge to collect data “for data’s sake.” Review the kinds of monitoring you do now for regulatory compliance and other purposes such as quality or health and safety management. How well does this serve your EMS purposes? What additional monitoring or measuring might be needed? You can start with a relatively simple monitoring and measurement system, then build on it as you gain experience.

Monitoring key process characteristics: Many management theorists endorse the concept of the “vital few” — that is, that a limited number of factors can be measured to determine the outcome of a process. The key is to figure out what those factors are and how to measure them. Root cause analysis is one way to identify what those factors might be.

Most effective environmental measurement systems use a combination of process and outcome measures. Outcome measures look at results of a process or activity (such as the amount of waste generated or the number of spills that took place). Process measures, on the other hand, look at “upstream” factors, such as the amount of paint used per unit of product or the number of employees trained. A combination of process and outcome measures may be right for your organization.

Equipment calibration: Identify process equipment and activities that truly affect your environmental performance. As a starting point, look at the key process characteristics you identified earlier. Some companies choose to put key monitoring equipment under a special calibration and preventive maintenance program. This can help to ensure accurate monitoring and lets employees know which instruments are most critical for environmental monitoring purposes. In some cases, it may be more cost-effective to subcontract calibration and maintenance of monitoring equipment than to perform these functions internally.
Assessing regulatory compliance: Determining your compliance status on a regular basis is very important. You should have a process to systematically identify, correct, and prevent violations. Performance of the compliance management program should be considered during EMS management review Elements of Compliance Management Program are:

  • Organization policies and standards that describe how employees are to meet the regulations
  • Assignment of responsibility for compliance oversight
  • Processes to systematically ensure that policies and standards are carried out (e.g., monitoring and auditing)
  • Appropriate incentives and disciplinary procedures
  • Prompt disclosure of findings
  • Prompt and appropriate correction of problems

Evaluating environmental performance: Go back and look at your significant environmental aspects and the objectives and targets associated with those significant aspects. What information will you need to determine if the company is achieving its objectives and targets?
Focus on things that you can do something about. Start by selecting a few performance indicators that are:

  • simple and understandable
  • objective
  • verifiable
  • relevant to what your organization does (i.e., its activities, products, and services)

Make sure you can commit the necessary resources to track this information over time. It is OK to start small and build over time as your company gains experience in evaluating its performance. Keep in mind that no single measurement will tell your organization how it is doing in the environmental area. People respond best to information that is meaningful to “their world.” Putting environmental information in a form that is relevant to their function increases the likelihood they will act on the information. Be sure to link your measurement program with your communications program and other elements of the EMS such as management reviews.
The distinction between audits and environmental performance evaluation can be confusing. The figure below is intended to explain the two concepts. Both are important to your EMS.

Audits Environmental Performance Evaluation
periodic Ongoing
sample of data frequent
Independent Line Function
verifies conformance assesses performance

Audit Checklist:

ISO 14001-Clause 4.5.1 Monitoring and measurement

  1. Has your organisation established, implemented and maintained a procedure(s) to monitor and measure, on a regular basis, the key characteristics of its operations that can have a significant impact on the environment?
  2. How does this procedure include the recording of information to monitor performance,relevant operational controls, and conformity with the organisation’s environmental objectives and targets?
  3. How is monitoring and measuring equipment calibrated or verified and maintained?
  4. Are calibration or verification records retained?.

ISO 14001-Clause 4.5.2 Evaluation of compliance

  1. Has your organisation established, implemented and maintained a procedure(s) for periodically evaluating its compliance with the applicable legal and other requirements?
  2. Are the records of the results of these periodic evaluations maintained?

Mandatory Procedure:

ISO 14001-Clause 4.5.1 Monitoring and measurement

pdf Example of Procedure for Performance Monitoring and Measurement

ISO 14001-Clause 4.5.2 Evaluation of compliance

pdf Example of Procedure for Evaluation of Compliance

Mandatory Records:

ISO 14001-Clause 4.5.1 Monitoring and measurement

 

pdf Example of formats for Instrument calibration history card

 

ISO 14001-Clause 4.5.2 Evaluation of compliance

 

pdf Example  of Legal and Other Requirements Register
pdf Example of  Compliance Monitoring Chart

 

Implementation document ( Not mandatory but helps in fulfillment of requirement):

pdf Example of template Environmental Measurement Indicators Log and Calibration log

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