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ISO 14001:2015 Clause 7 Support

7 Support

ISO 14001:2015 Clause 7 Support is all about the execution of the plans and processes that enable an organization to meet their EMS. Simply expressed, this is a very powerful requirement covering all EMS resource needs. Organizations will need to determine the necessary competence of people doing work that, under its control, affects its environmental performance, its ability to fulfil its compliance obligations and ensure they receive the appropriate training. In addition, organizations need to ensure that all people doing work under the organization’s control are aware of the environmental policy, how their work may impact this and implications of not conforming with the EMS. Finally, there are the requirements for ‘documented information’ which relate to the creation, updating and control of specific data.

Clause 7, Support, has five sub-clauses .

7.1 Resources

The organization should provide the resources needed for the establishment, implementation, maintenance and continual improvement of the environmental management system.

As per Annex A (Guidance on use of ISO 9001:2015 standard) of ISO 9001:2015 standard it further explains:

Resources are needed for the effective functioning and improvement of the environmental management system and to enhance environmental performance. Top management should ensure that those with environmental management system responsibilities are supported with the necessary resources.Internal resources may be supplemented by external providers. Resources can include human resources, natural resources, infrastructure, technology and financial resources. Examples of human resources include specialized skills and knowledge. Examples of infrastructure resources include the organization’s buildings, equipment, underground tanks and drainage system

Explanation:

Clause 7.1 requires that organization “provide resources need for the establishment, implementation, maintenance and continual improvement of the environmental management system..” The term “resource” is most often used to imply human or financial resources, but there are many types of resources. Resources can also include equipment, materials, specialized skills, and facilities. Resources in this clause means all of the human, financial, and material resources necessary to implement your EMS. Ensuring adequate resources for your EMS involves three general steps: i) identifying resource needs; ii) preparing a budget that addresses the needs; and iii) tracking EMS costs on an ongoing basis to ensure that resources continue to reflect current needs.
As a first step in ensuring that appropriate resources are available for the EMS, top management must be made aware of, and understand. the resource needs of the organization. You must identify what resources the EMS will require for proper functioning since you would be most familiar with EMS requirements.To identify EMS resource requirements. you will need to assess the level of effort your facility’s current environmental tasks require, as well as the effect of corporate plans, forecasts, new product development plans, production plans. and capital expenditure plans. It is important to consider business forecasting and new development plans when evaluating required resources because they can have a significant impact on environmental issues. For example. the top management of a semiconductor fabrication facility may be considering doubling the size of the facility’s operations. From an environmental management perspective. this has important implications for resources because such an expansion will typically increase the “regulatory footprint” of the facility. This might involve more environmental operating permits (e.g., air permits, wastewater permits. etc.) and increased use of hazardous materials and generation of hazardous waste, which might trigger additional regulatory requirements. To manage this increase in regulatory requirements, additional resources, personnel. and skills might be required. It may also require new capital expenditures. such as a new air scrubber and a continuous air emission monitor, or result in a change to the maintenance requirements for existing equipment because of the increased load on pollution control equipment.

Once the required resources have been identified. you should then develop a budget based on the current level of required resources.Most companies formulate resource budgets covering a one- to five- year period. An EMS budget should include all labor, capital expenses, and other items (such as specialized consultants) required to run your EMS. In addition to preparing a budget for the EMS. you should develop a system for keeping track of EMS costs on an ongoing basis. In many organizations, EMS activities are often charged to overhead and the costs may be difficult to identify among all of the other overheads. This creates a problem because unless you can identify what you spent on activities such as EMS auditing or management review  you will find it difficult to allocate sufficient resources for future programs. One practical way of tracking required resources and costs associated with the proper functioning of your EMS is to assign cost codes to each category of environmental-related work at your facility, making sure to include management and auditing (internal and external) activities among these. Employees involved in environmental activities can then track the hours and resources they spend on various tasks and charge the time spent to the various job codes. By evaluating such information you can. over the course of several years, develop a clear understanding of the time and resources required for tasks within your EMS. Allocating and tracking costs does not prevent you from moving resources around to resolve immediate or unforeseen needs and gives you more effective control of costs. Tracking EMS costs over the course of several years will also enable you to determine whether the system is operating efficiently and provide benchmarking information with which to determine if your system is being “continually improved“ . Clause 7.1 does not require any type of resource forecasting or documenting. The clause simply requires that resources be provided, and you are free to address this in whatever way best suits your particular situation.  Using the cost code approach would facilitate record keeping because the accounting records generated would in effect “‘document“ the resource requirements of the EMS. Without such documentation, it will be difficult to demonstrate to a certification auditor that your facility has allocated adequate resources to implement the EMS.

7.2 Competence

The organization must determine the necessary competence of persons doing work under its control that affects its environmental performance and its ability to fulfill its compliance obligations. The organization must ensure that these persons are competent on the basis of appropriate education, training and experience. They must determine training needs associated with its environmental aspects and its environmental or management system and where applicable, take actions to acquire the necessary competence, and evaluate the effectiveness of the actions taken. The organization must retain appropriate documented information as evidence of competence.  Applicable actions can include the provision of training to, the mentoring  of employees, reassignment of currently employed persons or the hiring or contracting of competent persons.

As per Annex A (Guidance on use of ISO 9001:2015 standard) of ISO 9001:2015 standard it further explains:

The competency requirements of this international Standard apply to persons working under the organization’s control who affect its environmental performance, including persons:

  1. whose work has the potential to cause a significant environmental impact;
  2. who are assigned responsibilities for the environmental management system, including those who:
    1. determine and evaluate environmental impacts or compliance obligations;
    2. contribute to the achievement of an environmental objective;
    3. respond to emergency situations;
    4. perform internal audits;
    5. perform evaluations of compliance.

Explanation:

This Clause requires that “ . . . persons are competent on the basis of appropriate education, training and/or experience.” Your overall goal is to produce knowledgeable, skilled, and aware employees who assist your facility in achieving its stated goals and objectives. You have the responsibility as part of your EMS, to develop an approach to judge the competence of employees to accomplish their assigned tasks. This can be achieved through establishing minimum levels of education and experience for specific positions or tasks and/or through competency testing after training or other methods such as mentoring, reassigning of employees to ensure employee knowledge. Tests may be written or oral quizzes or may involve demonstrations (e.g.. putting on personal protective equipment, or responding to a mock emergency). If written or oral quizzes are selected as the test method, it‘s important that the reading and education level of all participants be determined ahead of time so as not to introduce test bias. Whatever the testing mechanism selected, you must have some means of documenting test results. This will become part of your record- keeping process . Further, if  any employee is conducting  an inspection or monitoring  program  or is conducting an EMS audit and you find that the  employee is not competent to conduct his or her job. you are required to take appropriate corrective action. Until that corrective action (such as retraining or any other means) is taken. you must ensure that the employee is appropriately supervised so that his or her lack of competence does not damage the effective implementation of the EMS.

This Clause requires the organization to:

  • identify the knowledge and skills necessary to achieve environmental objectives (i.e., training needs analysis);
  • implement training to provide the appropriate knowledge and skills; and
  • ensure that employees doing work that may have a significant impact on the environment are competent.

The Standard requires that the organization shall identify training needs and this clause requires that all personnel whose work may create a significant impact upon the environment have received appropriate training. There are two excellent reasons for training employees about environmental management and your EMS:

  • Every employee can have an impact on the environment.
  • Any employee can have good ideas about how to improve environmental management efforts.

Although it is not specifically stated as a requirement, it also addresses regulatory-required and regulatory-derived training. Organizations conforming to ISO 14001 have committed to complying with applicable Compliance obligation which includes environmental laws and regulations, and this commitment includes implementing any training required by the regulations or required to implement the procedures necessary to achieve compliance. The specific training requirements that apply to an organization will be a function of that organization’s activities, products, and services, and consequently, the elements of that organization’s EMS. That is the training requirements are driven by an organization’s significant environmental aspects, Compliance obligations, Operations, objectives and targets, environmental management programs, etc.

Training Requirements within an IS0 14001 EMS

training-requirements

The specific training requirements are driven by the general EMS elements, the significant environmental aspects, and any legal requirements that apply. Training for an individual employee will also be determined by that person’s roles and responsibilities within the EMS and by any environmental objectives and targets with which he or she is involved. Prior to assuming their roles within the EMS and being granted operating autonomy, employees must be judged competent to perform their roles successfully. The result of this training is, hopefully, knowledgeable, skilled and aware employees. Practitioners and auditors have interpreted the training requirements into

  • Job-specific training; and
  • Regulatory-required training.

1.Job-specific Training

Job-specific training includes training required for specific jobs that are directly related to operations or equipment within an organization that can have an impact on the environment. The intent of job-specific  training is to ensure that employees who have such jobs are  knowledgeable about the environmental issues involved in their day-to- day activities. and what specifically they must do to ensure that the  environment is protected in accordance with the environmental policy. Job-specific training will normally apply to operational level  employees. Those employees with “front-line” responsibilities who  are involved in operating equipment or machinery. monitoring  environmental indicators, and maintaining environmentally related machinery (e.g., air scrubbers and water treatment equipment) must be trained in the appropriate procedures for performing these work  activities. In addition, job-specific training may be conducted for those  employees with specific EMS responsibilities. For instance, in order to  fulfill the requirements of Compliance obligations which deals with legal and  other requirements the person designated as being  responsible for ensuring that the organization has identified the  applicable regulatory requirements may require job-specific training.  Likewise. personnel involved in emergency response or conducting  EMS audits, may also require training. Job-specific training includes training on:

  • significant environmental aspects associated with specific job  tasks;
  • established environmental objectives and targets and operational control involved with specific  job tasks;
  • specific roles and responsibilities for job tasks related to  environmental issues;
  • established operational procedures (and potential  consequences of departure from them); and
  • emergency preparedness and response requirements.

This type of training is generally very practical in nature and specific  to particular groups of employees and their assignments. For example,  employees operating metal plating equipment must understand how to  operate the equipment in an environmentally sensitive manner (e.g..  how to avoid spilling plating solutions and how to operate plating baths  to reduce the amount of hazardous waste generated) and how to meet  permit-specific compliance requirements. They must also understand  what to do when equipment fails and how to address environmental  releases or other incidents. This includes knowledge of whom to  contact within the organization when things go wrong or when they  have questions. Job-specific training provides the training necessary to achieve the  competence required by this Clause and may be used to periodically refresh existing employees‘ knowledge as well as to provide new employees with a baseline level of knowledge. Usually. regulatory-  required and regulatory—derived training involves job-specific tasks and is incorporated into job-specific training.

To identify job-specific training needs, you should focus on identification of job titles or roles associated with the four primary drivers of job-specific training:

  • significant environmental aspects;
  • established environmental objectives and targets and established operational procedures; and
  • associated environmental management programs;
  • assignments of responsibility within the EMS itself.

(i) Significant Environmental Aspects

ln identifying job-specific training needs associated with significant  environmental aspects. you should start with the significant  environmental aspects and determine which of the related job functions and duties influence EMS performance. Some significant environmental aspects involve job activities that have very obvious environmental components. For example. the operation, maintenance and repair of environmental abatement equipment such as air scrubbers or wastewater treatment equipment, by a maintenance worker has very obvious implications with respect to the environment. If done incorrectly, there is the potential for a very real and direct impact to the environment in the form of water or air pollution. However, there are other job activities related to significant environmental aspects that have no direct impact on the environment but do have a potentially significant impact on overall environmental performance. An example of this type of job activity is the operation of equipment (e.g.. metal plating equipment) that uses hazardous materials and generates hazardous waste—the amount of hazardous waste generated by poorly conducted operations affects environmental performance. ln addition there are job activities that have no direct involvement with operations. but that involve actions or decisions that can significantly affect environmental performance. For example, activities performed by engineers, such as the design of equipment and selection of operating processes, can be beneficial or detrimental to environmental performance, depending on the choices made. Similarly, the job activities of purchasing agents, whose work involves selection of raw materials and other product inputs, also have varying degrees of environmental impact.

(ii) Objectives

You should review your environmental objectives and management programs to determine what training and skills are necessary to accomplish them and who should be trained. In some cases no additional training will be required. For example. an objective of lowering energy usage by replacing older less-efficient lighting with new lighting will require little, if any, staff training. However. in other cases. job-specific training may be essential. Waste reduction programs often involve new processes that require retraining of workers to be effective.

(iii) Operational Procedures

You should also review your documented operational procedures to determine what training and skills are necessary to accomplish them and who should be trained. In some cases no additional training will be required. However, in some instances. detailed instrument calibration procedures, for example, training may be required. Often the documented operational procedure itself will serve as the primary training tool in that the training will involve going through the steps of the procedures in an “on-the-job” setting.

(iv) EMS Duties

The final driver for job-specific training in an EMS is assignments of responsibility within the EMS itself. As mentioned above, certain duties specifically required by your EMS may require training. Depending on the size and complexity of your facility. personnel at your facility may require training to ensure that they are competent to conduct activities in your EMS. For example, personnel involved in EMS audit programs will need to be trained in how to conduct and document the audits.

2. Regulatory-required Training

Regulatory-required training is training that is specifically required by federal, state (or provincial), and local regulations. For example, many countries have specific training requirements for  employees who handle, use, or store hazardous materials. The intent of this training is to ensure that employees who are involved  in job activities required by laws or regulations know how to conduct  their work tasks in compliance with these laws and regulations. This type of training would apply to all employees at an organization  who have duties that are required by federal. state (or provincial). or local laws or regulations.

Criteria for EMS training

Each person and function within your organization can play a role in environmental management. For this reason, your training program should cast a wide net. Everyone in the organization should be trained on the environmental policy, significant environmental impacts of their work activities, key EMS roles and responsibilities, procedures that apply to their activities, and the importance of conformance with EMS requirements. All personnel should receive appropriate training. However, training is just one element of establishing competence, which is typically based on a combination of education, training, and experience. For certain key roles which includes tasks which can cause significant environmental impacts, you should establish criteria for measuring the competence of individuals performing those tasks.

 Thus the organization must satisfy the following four criteria:

  1. Ensure that training needs are identified:

    This can be performed via appraisals. In most companies this is an annual event – at the very least for salary review purposes. From this training needs will be identified and a plan of either internal or external training planned. All individuals will need some level of training in the requirements of the environmental policy and a background to the requirements of ISO 14001. Some individuals will need specific training in emergency response. Others may need their roles to be changed and defined. An internal quality assurance auditor may well need to be
    ‘converted’ to an environmental systems auditor via an external training course.

  2. Ensure that these planned needs are met:

    There must be a system to ensure that such individual training plans are carried out as intended. Procedures will be needed to describe such mechanisms, as well as including a broader description of how the organization’s training strategy is structured. In addition to specific external courses or seminars, internal workshops and briefings are an acceptable vehicle for training. Internal environmental newsletters are also part of the range of tools available.

  3. Verify that the training has achieved its purpose i.e. increased awareness:

    This verification can be performed via feedback from training sessions: either a written report from the individual or a simple questionnaire to complete. Some organizations will ask personnel to undertake simple ‘tests’ to measure the effectiveness of the training. Other ways of verifying ‘awareness’ could be through the internal audit system. Asking questions of personnel during such audits will give an indication of their knowledge. One  of the challenges can be the measurement of ‘continuous improvement’ within training. Clearly, measurable targets can be set for delivering the training, i.e. records of attendance would show who has attended such sessions. However, how can an organization ‘measure’ whether the knowledge (awareness) of personnel has ‘improved’ compared with their knowledge of say, 12 months ago?

  4. Verify that following training, the individual is competent at applying the awareness gained to their particular job:

    This can be achieved by monitoring an individual’s work, noting any improvements in work or, conversely, monitoring any persistent failure to absorb such training for example, by not being aware of the consequences of departure from a specific work instruction. Contractors, working on behalf of the organization, must also be subject to training requirements and this must be addressed in the training procedures. The  employees of the contractor should have a certain level of training , that level to be determined by the organization. For both contractors and the organization itself, it must be kept in mind that the concept of significance must be applied to any training plans or program. The individual who is in an environmental front-line position – whose actions have the potential to cause a major impact on the environment – should have priority in environmental training followed by a more intensive scrutiny of awareness and competence than the individual whose actions have little potential to impact on the environment. Further, if for example an individual is trained to operate a pH meter to check effluent pH, clearly both awareness and competence can be verified by giving the individual a sample of liquid of known pH and asking him to test it. If the results are correct it would tend to demonstrate that the training was successful.

A critical first step in developing your training program is assessing your training and skill needs. In assessing these needs, you should consider both general and specific aspects. For e.g., What EMS procedures affect Operator’s daily work and what happens if they aren’t followed? What environmental impacts might Operator’s work cause? What broader understanding of environmental issues and our EMS does Operator need? Look at the training you conduct already, for compliance with environmental and health and safety regulations and other purposes. You may find that your existing training efforts go a long way towards satisfying the requirements for the EMS. Because of the level of effort involved in a training program, this is one EMS area where you don’t want to start from scratch. Many employees may already be qualified on the basis of their experience and previous training. All training should be documented. Since some employees may  require training on how to run a process safely, on the job training certainly plays a role. Plan and schedule training opportunities carefully.  While finding enough time for training can be a challenge, there may be creative ways to make “more time” . Use venues like safety meetings, staff meetings, and tool box meetings to provide “training” and reinforce key messages. New employees can pose a significant training challenge. Consider developing an EMS training package for new employee orientation. Even better, videotape one of your current EMS training courses to show new employees. In reviewing training needs, don’t forget to consider the qualifications and training needs of your environmental manager and your trainers. Professional certification programs may be appropriate for certain functions.  Factor your EMS skills requirements into your recruiting, selection, and new employee orientation efforts. Establishing competency for various tasks can be a challenge. Competency criteria for jobs that can cause significant environmental impacts should be as objective as possible. Consider “job aids” to supplement training or help establish competence. Examples of job aids include written or pictorial job procedures, decision tables or flow charts.

Key Steps in Developing a Training Program

Step 1: Assess training needs requirements
Step 2: Define training objectives
Step 3: Select suitable programs and methods
Step 4: Prepare training plan (who, what, when, where, how)
Step 5: Implement training program
Step 6: Track training (and maintain records)
Step 7: Evaluate training effectiveness
Step 8: Improve training program (as needed)

Evaluation of Training

ln order for your training program to be effective and improve your facility’s environmental performance,  you must periodically evaluate your EMS training. To get a true sense of how effective your training is, you should consider evaluation of EMS training on several levels:

  • Are the trainees happy with the training?
  • Does the training teach the required skills or concepts?
  • Are the skills and concepts used on the job?
  • Does the application of the skills and concepts have positive effects?

The first two items can be evaluated through employee interviews, course or training evaluations, and testing employees‘ knowledge of the required activities as part of the training. The second two items are a little more difficult to evaluate. Evaluation of whether the skills and concepts are actually used on the job should be addressed as part of your EMS audit program. The audit of training will typically involve inspections and interviews to determine that the skills learned in training are actually applied. The effect of the training on your facility’s performance should be evaluated as part of your management review process. The ideal training is liked by trainees, is effective, provides the skills that are used on the job. and provides skills that have a positive impact on an organization‘s environmental performance.

7.3 Awareness

The organization must ensure that persons doing work under the organization’s control are aware of the environmental policy, the significant environmental aspects and related actual or potential environmental impacts associated with their work. They must be aware of their contribution to the effectiveness of the environmental management system, including the benefits of enhanced environmental performance and the implications of not conforming with the environmental management system requirements including not fulfilling the organization’s compliance obligations.

As per Annex A (Guidance on use of ISO 9001:2015 standard) of ISO 9001:2015 standard it further explains:

Awareness of the environmental policy should not be taken to mean that the commitments need to be memorized or that persons doing work under the organization’s control have a copy of the documented environmental policy. Rather, these persons should be aware of its existence, its purpose and their role in achieving the commitments, including how their work can affect the organization’s ability to fulfil its compliance obligations.

Explanation:

The intent of this Clause  is to ensure that employees at all levels of the organization understand the Policy and principles of the EMS and the ways in which their job activities impact the environment and the achievement of EMS goals which obviously includes meeting compliance obligations. All personnel within the organization should have at least a basic understanding of the environmental issues associated with the organization’s operations, while personnel whose work may directly affect environmental performance should be trained and competent to complete their assigned tasks. Employees can only assist the organization in achieving its environmental objectives and improving environmental performance if there is adequate awareness and they possess the appropriate knowledge and skills. This leads to one of the central themes of IS0 14001: by informing employees of the impact that each facility operation has on the environment and their roles in the successful management of those impacts, improved environmental performance is inevitable. Employees who understand the consequences of their actions will individually make more environmentally friendly decisions. Employees must understand how to perform their responsibilities consistent with the EMS and understand how incorrect performance of  their job activities will affect the environment.

Everyone in your organization must have a very basic awareness of the EMS. Therefore, all personnel at your facility should receive EMS awareness training. EMS awareness training includes basic training that addresses an organization’s EMS focusing on the environmental policy, the importance of conforming with EMS requirements, and general roles, responsibilities, and authorities within the EMS. The intent of this type of training is to ensure that all employees have a base level of understanding regarding the environmental issues associated with the organization’s operations and how these issues are being addressed. EMS awareness training should include:

  • presentation of the environmental policy and general continual improvement, prevention of pollution, and compliance obligations ;
  • presentation of the organization’s significant environmental aspects;
  • discussion of the programs, practices, and procedures involved in the EMS; and
  • identification of key personnel and departments involved with the EMS and their functions.

EMS awareness training is typically provided when the organization initially introduces its EMS and periodically thereafter. All new employees should be given EMS awareness training as part of their introduction into the organization. Because EMS awareness training involves all employees, it will likely involve the greatest number of people within an organization. The clause requires that the training result in employee awareness of:

  • the importance of conforming with EMS requirements;
  • significant environmental aspects associated with work activities within the organization;
  • specific roles and responsibilities involved in the EMS; and
  • potential consequences of not following established EMS procedures.

The goal of EMS awareness training is to ensure that employees:

  • are aware that the organization has an environmental policy and is committed to prevention of pollution, continual improvement, and compliance obligations;
  • are aware that the organization has identified certain environmental aspects as targets for improvement (i.e. significant environmental aspects); and
  • understand the goals and principles of the EMS and the ways in which their job activities impact the environment and the achievement of the established objectives.

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