ISO 14001-Clause 4.5.4 Control of records
ISO 14001 Requirements
The organization shall establish and maintain records as necessary to demonstrate conformity to the requirements of its environmental management system and of this International Standard, and the results achieved.
The organization shall establish, implement and maintain a procedure(s) for the identification, storage, protection, retrieval, retention and disposal of records.
Records shall be and remain legible, identifiable and traceable.
ISO 14001-Clause 4.5.4 states the organization shall establish and maintain procedures for the identification, storage, protection, retrieval, retention and disposition of environmental records. It is as well to remember that a record of an activity is invariably required some time after the event has occurred; when the person who created or added to the record has left the organization and that everyone connected with the ‘incident’ or ‘occurrence’ cannot remember what happened. The value of records management is fairly simple, you should be able to prove that your organization is actually implementing the EMS as designed. While records have value internally, over time you may need to provide evidence of EMS implementation to external parties such as customers, a registrar, or the public. Records management is often viewed as bureaucratic, but it is hard to imagine a process or system operating consistently without keeping accurate records. Basic records management is straightforward, you need to decide what records you will keep, how you will keep them and for how long. You should also think about how you will dispose of records once you no longer need them. These records shall include training records and the results of audits and reviews. Records need to be kept by any organization to demonstrate that previous activities have been in compliance with legislation, including:
- Discharge consents to sewer
- Process authorizations and variation notices
- Controlled waste consignment notes
- Special waste transfer notes
- Other necessary records include: accidents, incidents, training, calibration, performance monitoring, internal audits, training, management reviews.
ISO 14001-Clause 4.5.4 also requires that records are legible, easily identified, easily retrievable and protected from damage or loss. The minimum length of time that they are kept should be documented. The approach taken by most organizations is to review what records they need to keep, not all records need to be kept but any record that has an environmental implication should be reviewed as to whether it needs to be retained, where they are kept, and for how long. A procedure can consist merely of a list detailing the above; this has the advantage of being easy to maintain and audit both by internal and external auditors. Records, of course, also refer to electronic storage. A means of protecting such information through regular back-ups and storage off-site must be established. As some of the information should be ‘readily available’, elaborate password systems must take this into account by allowing access to those who are authorized. In designing your Record management system focus on records that add value and avoid bureaucracy. If records have no value, then don’t collect them. The records you choose to keep should be accurate and complete. You may need to generate certain forms as you develop your EMS. These forms should be simple and understandable. Consider combining your records management processes for environmental and health & safety records. Establish a records retention policy and stick to it. Make sure that your policy takes into account records retention requirements specified in applicable environmental regulations. In designing your records management system, be sure to consider who needs access? to what records? in what circumstances?
Examples of Types of Records you may maintain
- legal, regulatory and other code requirements
- results of environmental aspects identification
- reports of progress towards meeting objectives and targets
- permits, licenses and other approvals
- training records
- EMS audit and regulatory compliance audit reports
- reports of identified nonconformities, corrective action plans and corrective action tracking data
- hazardous material spill / other incident reports
- communications with customers, suppliers, contractors and other external parties
- results of management reviews
- sampling and monitoring data
- maintenance records
- equipment calibration records
- Has your organisation established, implemented and maintained procedures for the identification, storage, protection, retrieval, retention and disposal of environmental records?
- How are these updated?
- Do these records include those that are necessary to demonstrate conformity to the requirements of the standard and include records of competence, training & awareness?
- Do you have records of communication?
- Do you have records of evaluation of compliance with legal and other requirements?
- Do you have records of monitoring and measurement?
- Do you have records of corrective & preventive action?
- Do you have records of Internal audits?
- Do you have records of Management review?
- Are the records legible, identifiable and traceable?
- How do you store the environmental records in such a way that they are readily retrievable and protected against damage, deterioration or loss?
|Example of Procedure for Control of Records|
Evidence/Implementation document ( Not mandatory but helps in fulfillment of requirement):
|Example of format for Master list of Forms and Formats|
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