Sunday, August 30, 2009

THE REQUIREMENTS OF ISO 14001:2004 WITH RESPECT TO LEGAL COMPLIANCE

ISO 14001:2004 requires an organization to make a “commitment” in its environmental policy to comply with applicable legal requirements that relate to its environmental aspects. The organization shall establish, implement and maintain a procedure(s) for periodically evaluating compliance with applicable legal requirements that is consistent with realising this commitment.
The specific clauses of ISO 14001:2004, which are most important with respect to legal compliance are the following EMS elements:
1) public environmental policy commitment to legal compliance (sub-clause 4.2);
2) identification and having access to applicable legal requirements and other requirements related to its environmental aspects (sub-clause 4.3.2 a));
3) how those legal requirements apply to the organisation’s environmental aspects (sub-clause 4.3.2 b));
4) objectives/targets/programs (sub-clause 4.3.3)
5) how legal obligations are routinely managed and monitored (sub-clauses 4.4.6 and 4.5.1);
6) evaluation of legal compliance (sub-clause 4.5.2);
7) corrective and preventive actions where necessary (sub-clause 4.5.3);
8) internal audit (sub-clause 4.5.5); and
9) management review (sub-clause 4.6).

Implementing ISO 14001

ISO 14001 is an internationally recognised standard that provides a framework for a strategic approach to corporate environmental management. This standard gives organisations the means to identify and control their environmental impacts, improve performance and achieve their objectives and targets. The standard is independently audited, giving it great strength and integrity.
Due to its widespread adoption (e.g. Barclays, Credit Suisse and UBS in the financial sector), it now acts as a common reference for communication about environmental issues. ISO 14001 provides assurance to stakeholders on environmental claims and helps organisations meet requirements laid down by clients and investors.
Adoption of ISO 14001 is being driven by stakeholder concerns as well as the significant benefits on offer to adopters. Few companies are now exempt from government, client and investor demands for accountability and improved environmental performance. With brand and reputation on the line, it is a risky strategy to ignore these concerns.
However, choosing how to act is not a straightforward decision. Companies that rushed to announce their green credentials without independent verification and transparency fell foul of greenwash accusations and suffered perhaps more damage to their reputation than had they not acted in the first place. In response to this, many companies are now choosing to implement internationally recognised and independently audited environmental management systems such as ISO 14001.
The benefits of implementing ISO 14001 are extensive:
It immediately enhances corporate reputation and sends a clear signal of commitment to corporate responsibility. Accusations of greenwash are prevented by the transparent and robust approach of the standard.
Proactive environmental management increases attractiveness to investors, especially for Socially Responsible Investment (SRI), an area already accounting for £9 billion investment per year in the UK alone.
ISO 14001 accreditation may also bring financial benefits through increased market share. Firms can differentiate themselves from competitors as responsible companies as well as securing the rewards of first mover advantage in new markets. In addition, many buyers are now implementing sustainable procurement codes and stipulating conditions in Requests for Information (RFIs) where suppliers are required to have environmental credentials. Gaining ISO 14001 accreditation ensures access to environmentally demanding but high reward markets.
Financial benefits are not limited to increased investment and sales. Implementation of an EMS may produce significant cost savings that actually negate the initial outlay. With energy and waste prices rising sharply, environmental responsibility can produce a win:win opportunity.
Perhaps the most significant benefit for many will be the positive effect on attracting and retaining staff. With intense competition for the best staff, corporate responsibility is becoming a key criterion against which employers are judged.
Finally, responsible environmental management is quickly becoming a necessary condition for business, a socially accepted norm of behaviour. Those who fail to follow these norms risk damage to their reputation and the possibility of their social licence to operate being revoked.
A standard as thorough and robust as ISO 14001 has an equally thorough implementation process with extensive requirements for procedures and auditable document trails. Implementation follows the Plan-Do-Check-Review cycle and key required procedures are detailed in the diagram below. Implementation will entail the creation of at least 20 procedures and supporting documents. The procedures are all company-specific and must be tailored to suit individual operations. It is this level of detail that gives the standard such strength and integrity.

Saturday, August 29, 2009

Emergency Preparedness and Response In ISO 14001

Emergency Preparedness and Response In ISO 14001
Under the Emergency Preparedness and Response requirement of ISO 14001:2004 (§4.4.7), the organization is required to establish procedures for identifying the potential for and responding to emergency situations and accidents that can have an impact on the environment.
Identification of Potential Emergency and Accident Situations – Experience indicates that organizations infrequently have a preexisting procedure for identifying potential emergency and accident situations.The norm is to establish emergency and accident responses for a variety of emergency and accident situations irrespective of the potential for their occurrence. But ISO 14001 is specific about requiring a procedure to identify the potential for emergency situations and accidents. Adhering to the requirement of the procedure is a valuable exercise that helps organizations identify weaknesses in their own emergency planning and to plan for that which is most likely to occur.Because many environmental impacts of an emergency or accident situation are secondary in nature, it appears that all potential emergency or accident situations need to be identified before a determination of environmental impacts can be made. An organization that attempts to identify potential emergency or accident situations based on a review of its environmental aspects would likely miss the environmental impact potential of, say, an automobile accident.
There are five steps implied by the emergency preparedness and response requirement:
1) Identify the potential for emergency situations and accidents of all kinds;2) Paying particular attention to the potential environmental impacts of accidents and emergency situations, identify how the organization can prevent and mitigate associated adverse environmental impacts;3) Determine how the organization and its employees should respond to emergency situations and accidents;4) Periodically simulate emergency situations to test response capabilities; and,5) Review and revise procedures based on experience derived from actual and simulated emergency situations and accidents.
Accident and Emergency Situation Identification – In order to identify potential for and responding to emergency situations and accidents, the organization should develop a procedure for systematically identifying accident and emergency situations, evaluating their probability of occurrence, their likely consequences, and their severity.Organizations often engage risk management specialists to assist in the identification of potential emergency or accident situations that could lead to human injury, environmental damage, or economic loss. While many checklists are available to facilitate this kind of evaluation, there is virtually no substitute for physical evaluation of facilities by knowledgeable personnel, whether employees or outside professionals.
Emergency Response Procedures – The organization is required to develop procedures for responding to emergency situations and accidents when they occur. Typically, response procedures include identifying public emergency response agencies and their capabilities, identifying individuals within the organization who are trained and able to provide assistance in emergencies, establishing an emergency communications network, and providing emergency lighting, signage, and equipment. Because Emergency Response Procedures are based on identified potential emergency situations and accidents specific to the organization, the emergency response plan will be unique for each organization.
Periodic Testing – The value of conducting emergency response exercises lies not only with simulating situations that could occur but also in identifying flaws in the response plan. Practice drills can be the most effective test of the system to give employees, emergency response personnel, and management the opportunity to walk through the plan and gain familiarity with its procedures. While a full-dress response exercise is valuable, testing of procedures can be effectively done on much smaller scales and still provide the benefits of testing. Above all, the organization should not let the impracticality of a full-dress exercise keep it from testing sub elements of the emergency response plan.
Review and Revise – ISO 14001 calls for continual improvement of the EMS. Periodically reviewing and revising emergency response plans based on the experience gained from the occurrence of emergency situations or accidents or in testing response plans is an example of continual improvement.
Written Response Plans – Many written emergency response plans are too cumbersome to be of value in an emergency situation – their value depends entirely upon previous training of persons who will be called upon to execute them. Yet, many organizations fail to provide the emergency response training necessary to make the plans functional.Keeping in mind that even the simplest, most direct emergency response plan requires training for effective implementation, an alternative for organizations to consider is establishment of abbreviated, readily available Immediate Response Directions established for each kind of potential emergency situation or accident. Such an emergency response plan might consist of a laminated card prepared for each potential emergency situation or accident and providing specific responsibilities and associated actions for employees and visitors, supervisors, emergency coordinators, and emergency directors.

Thursday, August 27, 2009

REQUIREMENTS OF ISO 14001

REQUIREMENTS OF ISO 14001
In order to effectively implement and benefit from an ISO 14001 EMS, it is important to
have an understanding of the standard’s requirements. A quick review of the standard
shows that it is structured following the Plan, Do, Check, Improve philosophy of the
Total Quality Management movement, as follows:

PLAN
4.2 Policy
4.3 Planning

DO
4.4 Implementation and Operation

CHECK
4.5 Checking and Corrective Action

IMPROVE
4.6 Management Review

Within these five elements are 17 sub-elements stating the various requirements.

4.2 Policy

4.3 Planning
4.3.1 Environmental Aspects
4.3.2 Legal and Other Requirements
4.3.3 Objectives and Targets
4.4.4 Environmental Management Programs

4.4 Implementation and Operation
4.4.1 Structure and Responsibility
4.4.2 Training Awareness and Competence
4.4.3 Communications
4.4.4 EMS Documentation
4.4.5 Document Control
4.4.6 Operation Control
4.4.7 Emergency Planning and Response

4.5 Checking and Corrective Action
4.5.1 Monitoring and Measurement
4.5.2 Nonconformance, Corrective, and Preventive Action
4.5.3 Records
4.5.4 EMS Audit

4.6 Management Review
Within these 17 sub-elements are all of the requirements, or “shalls”, necessary to
conform to ISO 14001. There is no substitute for reading the standard in terms of
recognizing the requirements. As a matter of fact, no auditor should embark on an audit
without having easily available the criteria to which they are doing the audit. However,
below we briefly summarize the key points of the sub-elements. This summary is not
intended to be a replacement for ISO 14001, and should not be used exclusively as such
during an audit.

Detailed Section by Section Summary

4.2 Policy
ISO 14001 requires that the organization have a policy statement to drive the EMS.
These tend to be short, one page or less documents, and simply affirm the commitments.
There is no expectation that specific details be noted in the policy. For example, the
commitment to pollution prevention can simply be stated saying, “we are committed to
prevention of pollution”. The policy must be clearly endorsed by top management and
be available to the public and employees. Although the availability to the public can be
rather passive; i.e. “is here if they want it”, there is an expectation that the employee
awareness is more proactive. Section 4.2 of ISO 14001 lists the other requirements of the
policy.

4.3.1 Environmental Aspects
This element requires a procedure that not only identifies the aspects and impacts, but
also provides for determination of significance, and keeping the information up to date.
ISO 14001 does not prescribe what aspects should be significant, or even how to
determine significance. However, it is expected the organization will develop a
consistent and verifiable process to do so.

4.3.2 Legal and Other Requirements
This is a requirement for a procedure that explains how the organization obtains
information regarding its legal and other requirements, and makes that information
known to key functions. This is not the assessment or compliance audit requirement, but
rather a more up front determination of requirements.

4.3.3 Objectives and Targets
There is no requirement for a procedure in this element, only that objectives and targets
be documented. It does require that certain items be considered in developing the
objectives, such as legal requirements and prevention of pollution. It is sometimes
easiest to develop a procedure anyway for this element to be able to verify these
considerations were made.

4.3.4 Environmental Management Programs (EMP)
EMPs are the detailed plans and programs explaining how the objectives and targets will
be accomplished. These EMPs usually note responsible personnel, milestones and dates,
and measurements of success. Noting monitoring and measurement parameters directly
in the EMP facilitates conforming to 4.5.1 on Monitoring and Measurement discussed
below.

4.4.1 Structure and Responsibility
ISO 14001 requires that the relevant management and accountability structure be defined
in this element. This usually takes the form of an organizational chart. Also, the
organization must denote the Management Representative who is responsible to oversee
the EMS and report to management on its operation.

4.4.2 Training Awareness and Competence
The key point in this element is that personnel must receive applicable training regarding
the EMS. Specific requirements are itemized in ISO 14001, and include general,
company-wide items such as knowing the policy, to more function-specific training on
aspects and emergency response. An organization usually responds to this element with a
training matrix, cross-referencing to training materials and records.

4.4.3 Communications
Procedures are required for both internal and external communications. Note that ISO
14001 only requires procedures, and allows the organization to decide for itself the
degree of openness and disclosure of information. Whatever the decision in terms of
disclosure, that decision process must be recorded.

4.4.4 EMS Documentation
This requirement is simply that the organization has documented the system in either
electronic or paper form such that it addresses the elements of the standard and provides
direction to related documentation. Not all ISO 14001-required procedures need to be
documented, as long as the system requirements can be verified.

4.4.5 Document Control.
Procedures are required to control documents, such as system procedures and work
instructions, and to ensure that current versions are distributed and obsolete versions are
removed from the system.

4.4.6 Operational Control
This element is the one which connects the EMS with the organization as a whole. Here,
the critical functions related to significant aspects and objectives and targets are identified
and procedures and work instructions created to ensure proper execution of activities.
Requirements for communicating applicable system requirements to contractors are also
addressed.

4.4.7 Emergency Planning and Response
Although typically addressed through conventional emergency response plans, this
element also requires that a process exist for identifying the potential emergencies, in
addition to planning and mitigating them. A linkage to the aspects analysis, where
impacts are assessed, is appropriate. Emergency incidents include those that may not be
regulated, but may still cause significant impact as defined by the organization.

4.5.1 Monitoring and Measurement
Procedures are required describing how the organization will monitor and measure key
parameters of operations. These parameters relate to the significant aspects, objectives
and targets and legal and regulatory compliance. In order to properly manage the system,
measurements must be taken of its performance to provide data for action. Responses to
this element usually cross reference to many other specific procedures and work
instructions describing measurement and equipment calibration. It is in this element that
we find the requirement for what is commonly referred to as a compliance audit.

4.5.2 Nonconformance, Corrective, and Preventive Action
This element requires procedures for acting on Non-conformances identified in the system,
including corrective and preventive action. Non-conformances may be identified through
audits, monitoring and measurement, and communications. The intent is to correct the
system flaws. Typically, Corrective Action Report (CAR) forms are the norm, noting the
nonconformance, the suggested fix, and closure of the action when completed. Note that
this requirement does not imply in any way that the party identifying the nonconformance
must be the one to suggest the fix. Instead, it is expected that the system provide for the
information to be routed to the most appropriate party to address the concern.

4.5.3 Records
Records are expected to exist to serve as verification of the system operating. For
example, records include audit reports and training records. Unlike controlled
documents, records are “once and done” documents, resulting from the execution of some
process or procedure. Procedures in this element are required for the maintenance of
records.

4.5.4 EMS Audits
ISO 14001 requires that the system provide for internal audits. This procedures(s) will
include methodologies, schedules, and processes to conduct the audits. Interestingly, the
EMS audit will in essence, audit the audit process itself!

4.6 Management Review
This element requires that periodically, top management will review the EMS to ensure it
is operating as planned. If not, resources must be provided for corrective action. For
areas where there are no problems, the expectation is that with time, management will
provide for improvement programs. Usually there is no detailed procedure for this
element, although records of agendas, attendance, and agreed upon action items are
maintained as verification.

Wednesday, August 26, 2009

Templates for Quality Manuals and Forms

Using templates for ISO 14001 quality manuals, procedures and forms can have huge benefits for an organization. Templates are usually in the form of existing and proven manuals, procedures and forms. Follow the link for more information on the use of Templates.


The ISO 9000 quality manual and the ISO 14000 quality procedures are a vital part of any ISO 14001 quality system.

You can get a huge head start by purchasing a good template quality manual (a sample quality manual that you can

use as a good example and that you can modify to make it your own quality manual). There are numerous

companies that sell ISO 9000 quality manuals that you can use as templates to create your own quality manual.

We urge you to carefully evaluate them before making a purchase decision as we found the majority to be

convoluted, bureaucratic and cumbersome.

Monday, August 24, 2009

ISO 14000 – Environmental Program Management

The ISO 14000 series of standards has received widespread attention, and, like ISO 9000, it is becoming a requirementfor domestic and global organizations.

This document is intended to provide a baseline understanding of the ISO 14000 standards and to discuss the current status of this important standard.

The International Organization for Geneva, Switzerland, is composed of 92 European Union (EU) to establish universal quality standards. Over time, ISO Standardization (IOS), headquartered in member countries. Adherance to standards developed by the IOS is voluntary. However, countries and industries may adopt the IOS standards. Until approximately 15 years ago, IOS focused on traditional standards-setting activities. In 1987, IOS published the ISO 9000 series standards that were used with the 9000 became recognized as a positive indicator of quality and a prerequisite to establishing/maintaining business relationships within and outside the European Union.

In the United States, both the American National Standards Institute and the American Society of Quality Control are privately funded organizations that have adopted ISO 9000, Quality Management, and the ISO 14000 standards.

ISO 14000 is the generic title given to 14040, ISO 14041, and ISO14050 have the 14000 series of standards. ISO 14001, ISO 14004, ISO 14010, ISO 14011, ISO 14012, ISO 14020, ISO been published as international standards. The ISO 14000 series of standards consists of the following 18 subjects that can be grouped under two major headings:
14001 Specification with Guidance for Use
14004 General Guidelines on Principles,
14010 General Principles of Environmental Auditing
14011 Audit Procedures
14012 Environmental Auditing ? Qualification Criteria
14015 Environmental Site Assessments
14031 Evaluation of Environmental Performance ? Guidelines
14032 Evaluation of Environmental Performance ? Case Studies
14020 Goals and Principles of All Environmental Labeling
14021 Environmental Labels and Declarations ? Terms and Definitions
14024 Environmental Labels and
14025 Type III Labeling
14040 Life Cycle Assessment ? Principles and Framework
14041 Life Cycle Assessment ? Inventory Analysis
14042 Life Cycle Assessment ? ImpactAssessment
14043 Life Cycle Assessment ? Interpretation
14048 Life Cycle Indicator Format
14050 Guide on the Principles of Terminology Work

At the current time, the ISO 14000 as International Standards are referred to
Standards that have not been published as Draft International Standards (DIS). Most DIS are in the final review period before publication. If a particular standard is of interest and is not final, a copy of the DIS may be available for review.

The Development of EMS Standards

The world’s first standard for environmental management systems (EMS) – BS 7750 – wasdeveloped and published by the British Standards Institution (BSI) in 1992. This standard was the model for the ISO 14000 Series developed by the International Organization for Standardization (ISO). ISO 14001, which establishes the requirements for an EMS, was finalized in 1996. BS 7750 was also the basis for the European Union’s Eco-Management and Audit scheme, known as EMAS.
ISO is an international standard and therefore must incorporate the different interests ofmany countries. This standard clearly has the weakest requirements. By contrast, EMAS is the most stringent and detailed standard reflecting the high environmental standards of German interests and companies which played a key role developing it.
Because ISO 14001 and EMAS are both based on BS 7750, all three standards arequite similar in their approach. If your organization complies with BS 7750 today, little effort will be needed to fullfill the requirements of ISO 14001 or EMAS. Be aware however, that EMAS emphasizes public environmental reporting.
Today there are two major areas in the evaluation of environmental management practice.One area focuses on organizational issues, and the other on products, services and processes.

1. Organization Evaluation
a. Environmental Management Systems (ISO 14001, 14004)
b. Environmental Performance Evaluation (ISO 14014, 14015, 14031)
c. Environmental Auditing (ISO 14010, 14011, 14012, 14013, 14014)

2. Products, Services and Processes

a. Life Cycle Assessment (ISO 14040, 14041, 14042, 14043)

b. Environmental Labeling (ISO 14020, 14021, 14022, 14023, 1402X)

c. Environmental Aspects in Product Standards (ISO 14060)