Establishing an ISO 14001:2015 Environmental Management System
A Point of View from Stage 1 Certification Audit
30 October 2016
By Raymond Cabanilla
B.S. Environmental Science, QEMS Lead Auditor
Objective: This paper aims to give you a feedback and idea on what are the expectations of the third party auditors in establishing the company’s Environmental Management System with the guidance of ISO 14001:2015 Standard.
In my own perspective of achieving the intended outcomes of the Environmental Management System (EMS) pertaining to the company’s environmental performance- A holistic approach must be considered. Details of your EMS shall be “interlinked” with each other. The Plan-Do-Check-Act (PDCA) Cycle Model should be applied through the course of EMS so that it will be much easier for us to see the interrelatedness of each processes.
“START ESTABLISHING THE EMS RIGHT!”
ISO Clause 4.1 & 4.2 Understanding the context of the organization and Identifying the needs & expectations of the interested parties… must be designed with the company’s internal & external issues. These issues must be defined relevant to the organization. For example, an employee had an issue of dust emission on the pavement while walking through his workplace- this could be an internal issue (an issue within the organization’s scope). From the derived issue, the organization can now formulate a policy, objective, corrective action plan and action plan for its continual improvement.
External issues should have direct impacts to the organizations relating to the compliance obligations. Compliance obligations are not only for legal requirements to both regulatory and statutory agencies but also include the requirement of interested parties that the organization has chooses to comply with. For example, the impact community have an issue of the company’s noise generation however the current noise is 50 dB which already complies with the legal requirement (see the conflict?). And that the impact community requirement is 10 dB. So the organization will now formulate a policy, objective, corrective action plan and opportunities for improvement that will comply or satisfy the requirement of the interested party which is the impact community.
Tips on identifying an internal and external issues is to answer this question: “What makes it difficult to the organization to say it is an issue?” Also, if the interested party concern have no requirements to your organization… Do not insist or invent a requirement! It is also important that these requirements must be specific and realistic for the organization to be able to get the relevant recommendations.
Please be noted that the Clause 4.1 & 4.2 is the backbone or root basis in defining you Environmental Policy, Scope, Objectives Targets & Programs (OTP), Risk Assessment, and Operational Controls & Influence. Wherein, the planning stage is critical because it affects the overall Environmental Management System.
Now that the organization have derived the internal & external Issues relevant to EMS and understand the context and its processes. Identifying the environmental aspects, compliance obligations and impacts are the next steps.
Environmental aspects are the activities/products/services that affect your environment in terms of Land, Water, Air, Flora, Fauna, Humans and Natural Resources. When defining the relevant aspects, there are three operating conditions related to the activities that must be considered, the following conditions are: normal, abnormal & emergency. Let’s say that normal is X, e.g. the product is delivered through pipe using electricity (resource aspect) at a normal condition. However, the pipe overheated under circumstances and that a cooling system via water sprinkler was additionally applied, so we can say that the abnormal is X+Y because we have included another resource aspect which is the water sprinkler. And that emergency condition is an environmental incident related to the activities which has actual medium to large scale impacts to the environment so we can say that emergency is X+Y+Z(environment trouble).
Then, have your own criteria of determining significant aspects wherein this has something to do with the degree of negative impacts to the environment either water, air or land pollution/degradation and it could be a resource depletion.
Once the organization have identified the significant aspects, next requirement is to conduct risk assessment. The very reason why we need to conduct risk assessment is to reduce the probability from happening and/or the severity consequences of the identified significant aspects. Moreover, other than significant aspects -compliance obligations and other issues pertaining to 4.1 & 4.2 should also be treated for risk assessment. This is to know the risks of not complying with the compliance obligation’s specified requirements. Also, have a different criteria for conducting risk assessment to significant aspect, compliance obligations and other issues relevant to the context of the organization.
Set an Environmental Objectives, Targets & Programs (OTP) out of the derived consequences of your risk assessment as one of the considerations. Again, Environmental Policy as the framework of determining relevant OTPs should be in place with the requirement of Clause 4.1 & 4.2.
Environmental OTPs should be related to significant aspects (e.g. zero environmental incident or spillages or less emissions), compliance obligations (e.g. to ensure 100% compliance) and internal & external issues relevant to EMS (e.g. 100% competency assessment related to EMS roles & responsibilities of employees & contractors) which have possible medium-high risk ratings.
Environmental performance or outputs relating to the formulated OTPs must be measurable and have engineering approach of interpreting the gathered data. For example, your OTP is to reduce 10% solid waste generation. Wherein the organization must look for an independent variable directly proportional to the solid waste generation as the dependent variable (e.g. Kgs of solid waste vs. Production Output per metric tons) and have it with a graphical representation.
Evaluation of the environmental performance will be validated and verified through an audit such as internal audit, third party and/or interested party audit. So it is important the data results must be in place or should be supported with evidences. Then, environmental performance audit results should be discussed in the Management Review. This is to discuss its effectiveness and to identify the resources needed so that the top management can decide regarding on how to allocate these resources for continual improvement of the EMS implementation.
Lastly, you may say that company’s Environmental Management System is effective when the set OTPs and intended results are met and fulfilled, compliance obligations are in place and you have achieved continual improvement i.e. reducing significant aspects and its negative impacts.