ISO 14001-Clause 4.6 Management review
ISO 14001 Requirements
Top management shall review the organization’s environmental management system, at planned intervals, to ensure its continuing suitability, adequacy and effectiveness. Reviews shall include assessing opportunities for improvement and the need for changes to the environmental management system, including the environmental policy and environmental objectives and targets. Records of the management reviews shall be retained.
Input to management reviews shall include
a) results of internal audits and evaluations of compliance with legal requirements and with other requirements to which the organization subscribes,
b) communication(s) from external interested parties, including complaints,
c) the environmental performance of the organization,
d) the extent to which objectives and targets have been met,
e) status of corrective and preventive actions,
f) follow-up actions from previous management reviews,
g) changing circumstances, including developments in legal and other requirements related to its environmental aspects, and
h) recommendations for improvement.
The outputs from management reviews shall include any decisions and actions related to possible changes to environmental policy, objectives, targets and other elements of the environmental management system, consistent with the commitment to continual improvement.
ISO 14001-Clause 4.6 requires that the organization’s top management shall, at planned intervals that it determines, review the environmental management system to ensure its continuing suitability, adequacy and effectiveness. Again, common sense dictates that once a system is implemented, there should be a review process to test whether what was planned does happen in reality. Just as a person should have periodic physical exams, your EMS must be reviewed by management from time to time to stay “healthy.” Management reviews are the key to continual improvement and to ensuring that the EMS will continue to meet your organization’s needs over time. Management reviews also offer a great opportunity to keep your EMS efficient and cost-effective. For example, some organizations have found that certain procedures and processes initially put in place were not needed to achieve their environmental objectives or control key processes. If EMS procedures and other activities don’t add value, eliminate them. The key question that a management review seeks to answer is: “Is the system working? i.e., is the EMS suitable, adequate and effective, given our needs?”
There is no correct way to perform an environmental management review – it must suit the organization’s culture and resources. As the Standard refers to ‘top’ management, this does indicate that a certain level of seniority of personnel should be present at such reviews, to demonstrate commitment. There are two kinds of people who should be involved in the management review process: people who have the right information / knowledge and people who can make decisions. Determine the frequency for management reviews that will work best for your organization. Some organizations combine these reviews with other meetings such as director meetings while other organizations hold “stand-alone” reviews. For ISO 9000 purposes, management reviews are typically held once or twice per year.Regardless of what approach your organization takes, make sure that someone takes notes on what issues were discussed, what decisions were arrived at, and what action items were selected. Management reviews should be documented. The management review should assess how changing circumstances might influence the suitability, effectiveness or adequacy of your EMS. Changing circumstances may be internal to your organization i.e., new facilities, new materials, changes in products or services, new customers, etc. or may be external factors such as new laws, new scientific information, or changes in adjacent land use
There are certain minimum areas to be reviewed and one option, used by most organizations, is to have a standard agenda for each meeting. The first point on the agenda should be a review of the Environmental Policy. This is the ‘driver’ for the whole system. Senior management should be able to examine it and say with confidence that what was planned (say 12 months ago) as stated in the policy, has occurred or that substantial progress has been made. Thus a typical agenda could be:
- Are the objectives stated in the Environmental Policy being met?
- Does the organization have the continuing capacity to identify environmental aspects?
- Does the system allow the organization to give a measure of significance to these aspects?
- Have the operational controls that were put in place achieved the desired levels of control?
- Are effective corrective actions taking place to ensure that where objectives are in danger of slippage, extra resources ensure a return to the planned time-scale?
- Are internal audits effective in identifying non-conformances?
- Is the environmental policy sufficiently robust for the forthcoming 12 months?
It could be argued that during the early months of the implementation period (perhaps prior to certification) these cyclical reviews are not appropriate and they should focus on just the progress of the implementation of the system. This is a reasonable viewpoint but, as the system approaches maturity, a review as above is beneficial at intervals of 6 to 12 months. It would be prudent for the organization to perform one full management review, following the procedure, prior to the on-site audit, to demonstrate evidence of implementation to the certification body. If it is concluded that the set objectives are being met, the organization is well on its way to minimizing its significant environmental impacts and thus complying with the requirements of the Standard.
Questions to Ponder During Management Reviews
- Did we achieve our objectives and targets? (if not, why not?) Should we modify our objectives?
- Is our environmental policy still relevant to what we do?
- Are roles and responsibilities clear and do they make sense?
- Are we applying resources appropriately?
- Are the procedures clear and adequate? Do we need others? Should we eliminate some?
- Are we monitoring our EMS (e.g., via system audits)? What do the results of those audits tell us?
- What effects have changes in materials, products, or services had on our EMS and its effectiveness?
- Do changes in laws or regulations require us to change some of our approaches?
- What stakeholder concerns have been raised since our last review?
- Is there a better way? What else can we do to improve?
Once you have documented the action items arising from your management review, be sure that someone follows-up. Progress on these items should be tracked. As you evaluate potential changes to your EMS, be sure to consider your other organizational plans and goals. Environmental decision-making should be integrated into your overall management and strategy.
Finally, the concept of continuous improvement is much misunderstood. An organization may have an objective to reduce its amount of waste to landfill. A target of 50% reduction may have been achieved over a period of some 3 years – a commendable environmental achievement. It could be, however, that to reduce this further (to demonstrate continuous improvement) would not be cost effective, perhaps the law of diminishing returns starts to operate at this level of reduction. The organization may well suffer financially to continue in this direction. The intention of ISO 14001 is to recognize this and really wants the organization to then focus on a different area of improvement. Operational controls will be in place to maintain the reduced waste to landfill quantities. Management can look elsewhere in its processes for improvement.
Thus, over a long period of time, the organization can demonstrate improvements, year upon year, although of course the improvements will be in different areas or departments of the organization. It is achieved by continually evaluating the environmental performance of the EMS against its environmental policies, objectives and targets for the purpose of identifying opportunities for improvement. And, although we are talking about continuous improvement in terms of reduction of tangible waste or measurable and costed aspects (reduction of use of electricity, fuel, etc.), continuous improvement in the EMS is allowed. Some organizations have, for example, recognized shortfalls in measurements. Thus an environmental objective could be to improve the accuracy of the data they receive for electrical energy consumption. They may only have a site wide figure. The objective is to find methods to obtain energy consumption from each piece of plant. They can then focus more easily on less efficient plant for replacement for example. Such an environmental objective does in itself not reduce electricity consumption, but the system is improved allowing the possibility of reducing energy use in the future. Overall, the EMS will have been enhanced. One organization may decide that, due to its processes, it cannot detect quickly enough if they are going out of consent with their effluent treatment, resulting in higher effluent treatment charges rather than prosecution from the authorities. An objective would be to investigate methods and or new detection equipment to prevent this occurring in the future.
- Has your organisation’s top management (at planned intervals) reviewed the environmental management system, to ensure its continuing suitability, adequacy and effectiveness?
- Does the review include assessing opportunities for improvement and the need for changes to the Environmental Management System, including the environmental policy and targets?
- Do the inputs to management review include results from internal audits and evaluations of compliance with legal and other requirements?
- Do the inputs to management review include communication from external parties, including complaints?
- Do the inputs to management review include the environmental performance of the organisation?
- Do the inputs to management review include the extent to which the objectives and targets have been met?
- Do the inputs to management review include the status of corrective and preventive action?
- Do the inputs to management review include follow-up actions from previous management reviews?
- Do the inputs to management review include changing circumstances, including developments in legal and other requirements related to its environmental aspects, and
- Do the inputs to management review include recommendations for improvement?
- Do the outputs from the management review include decisions and actions related to possible changes to the environmental policy, objectives, targets and other elements of the environmental management system, consistent with the commitment to continual improvement?
- Are the records of the management reviews retained?
|Example of Management Review meeting Report|
|Example of Performance Review meeting Report|
Evidence/Implementation document ( Not mandatory but helps in fulfillment of requirement):
|Example of Procedure for Management Review Meeting|
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