Implementing an EMS — LRQA Guidance

“In today’s global economy, organizations are increasingly called upon to demonstrate sound management of economic, social and environmental issues. Evidence suggests that a focus on this 'triple bottom line' results in advantages in financing, insurance, marketing, regulatory treatment, and other areas.”

www.iso.ch

Why is ISO 14001 good for you?

There can be no dispute that we have damaged our planet, and continue to do so at an alarming rate. Thankfully, our appreciation of this has evolved and our understanding of the difference we can make is gradually becoming second nature.

More and more companies are beginning to understand the impact their operations have on the environment, both on a local and global scale. Many have decided to do something about it, and have implemented environmental management systems (EMS’s) to control these impacts. These impacts stem from far beyond the factory gates or office desks and include the supply chain and subcontracted activities. As a result, there is increasing pressure in the market place as ’green‘ companies are beginning to favour other ’green‘ companies.

ISO 14001 is an international standard environmental management system model, which requires an organisation to effectively manage its environmental impacts, through commitments to pollution prevention, legal compliance and continual improvement. Certification to this standard demonstrates that you are making a difference.

This article provides some practical guidance and advice for those tasked with implementing an environmental management system, with a view to gaining certification to ISO 14001. This article complements ’Implementing an EMS - a consultant’s viewpoint’ also on this website. We would advise you to read both in order to gain a balanced perspective.

This article has been written by James Morgan, EMS Lead Assessor. James joined LRQA from the Environment Agency in November 2002 and holds a degree in Environmental Science from UCW Aberystwyth.

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Environmental policy: your contract with the outside world

Your environmental policy is the only part of your EMS which must be freely available to the public and endorsed by your organisation’s top management. Within this document, your organisation must commit to 3 principles:

• Pollution prevention: “Use of processes, practices, materials or products that avoid, reduce or control pollution, which may include recycling, treatment, process changes, control mechanisms, efficient use of resources and material substitution.” (ISO 14001, clause 3.13)
• A commitment to comply with applicable legal and other requirements
• A commitment to continual improvement: “Process of enhancing the Environmental Management System to achieve improvements in overall environmental performance in line with the organisation’s environmental policy.” (ISO 14001, clause 3.1)

An EMS which has been well implemented and maintained in accordance with the requirements of ISO 14001 is the vehicle for realising these policy commitments. Remember that all policy commitments are binding - failure to demonstrate compliance with policy commitments = failure to comply with ISO 14001.

Commonly encountered problems include:

• Policy statements which are not supported by the EMS.
• Lack of definition of mechanism for making the policy available to the public or to "all persons working on behalf of the organisation." 'Generic' policy statements which could be applicable to any sector.
  

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Planning for success

“Give us the tools and we will finish the job.”

Winston Churchill

Whether you’re starting from scratch, or creating an EMS based on your existing quality management system, time and resource (personnel and finance) will be required to achieve your goal. Without the full and continued support of top management and the organisation as a whole you will not succeed - communication is your key!

To help you plan your project, we have defined an implementation planner defining the typical key stages and activities leading to your certification, and details of services offered by LRQA which may be of assistance.

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Where are you now?

An initial environmental review is your opportunity to establish a baseline. The aim of this review is to enable you to identify the significant environmental aspects associated with your activities, products and services, past, present and future. The review is also your opportunity to identify relevant environmental legislation and other requirements and to ascertain what you must do to ensure compliance.

The article 'Implementing an EMS - A Consultant’s Viewpoint' refers in more detail to the information needed to complete your review.

Your key outputs from this process will be your register of significant environmental impacts and your register of applicable legal and other requirements - for example, relevant codes of practice; customer requirements etc. From these two key areas, your management system will begin to take shape.

Commonly encountered problems:

• Many organisations confuse activities with aspects. Remember that an aspect is an “element of an organisation’s activities, products or services which can interact with the environment.” ISO 14001, clause 3.3
• Failure to evaluate the significance of an aspect under normal, abnormal and emergency operating conditions
• Failure to identify the aspects of design processes (where applicable)
• A lack of understanding of exactly how each piece of legislation or other requirement is applicable to the organisation and what is needed to ensure compliance.
  

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Making the changes

So, you’ve listed your significant aspects and your relevant legal and other requirements. The next step will involve ensuring that you have processes in place to control and/or improve your significant aspects and to ensure compliance with legal and other requirements.

You may have documented procedures already in place, which will just need cross reference from your EMS manual, but in most cases, new documented procedures will need to be created and implemented, as well as documented monitoring procedures.

A good way to begin drafting procedures is to talk to the people already involved in the process. Ask them for their opinions - are these new procedures workable? Do they achieve what was originally intended? In addition, top management will at this stage need to define the organisation’s environmental objectives and supporting management programmes.

Once defined, the EMS will need to be implemented, the major part of which will involve communicating with and training those within your organisation.

In order to succeed, everyone in your organisation will need to be aware of not only what they need to do, but why they need to do it. They will need to understand that their individual actions will contribute towards the success or failure of the EMS in achieving its policy commitments. In addition to training in specific procedures and environmental awareness, more specialised training will need to be implemented, for example, do not assume that your QMS auditors will be able to effectively audit your EMS. There are some significant differences, for which specialised knowledge will be required.

LRQA offers a range of suitable training courses, including public and in-company training options, that can be tailored to suit your organisation’s needs - refer to the EMS Implementation Planner.

Commonly encountered problems:

• Lack of cross reference from significant aspects to control and monitoring procedures & objectives and targets.
• Lack of cross reference from legal registers to the mechanisms employed to ensure compliance and to relevant legal documents such as discharge consents.
• Lack of knowledge of relevant procedures amongst employees.
• Poorly structured management programmes which don’t adequately support the environmental objectives.
• No evidence that emergency procedures are periodically tested.
• It is very common for the EMS representative to take on too much - we can’t over emphasise the fact that the whole organisation must share the responsibility for the implementation of the EMS.

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Is it working?

In order to demonstrate that you are effectively controlling and/or improving your significant environmental aspects, you will need to monitor them. The documented monitoring procedures required will depend entirely on your definition of significance.

In addition, you will also be expected to periodically evaluate compliance with legal and other requirements in order to support your policy commitment.

Commonly encountered problems:

• Monitoring procedures are not documented. Organisations often fail to monitor/ demonstrate compliance with all conditions of discharge consents, IPC permits etc (regulators may say that you don’t need to monitor certain conditions, but until they state that you don’t need to comply, you will be expected to demonstrate compliance under ISO 14001 - remember your policy commitments!)
• An extremely common problem is the misinterpretation of what is meant by “periodic evaluation of compliance,” (relating to legal and other requirements). Remember your policy statement, which contains: "a commitment to comply with legal requirements and with other requirements." You should have processes in place to ensure compliance with every relevant legal and other requirement. Periodic evaluation of compliance is your mechanism for periodically checking that you are in fact fulfilling these policy commitments. Ask yourself this question: “Do I have such confidence in our system for the periodic evaluation of compliance, that I am happy to report to our Top Management, our regulators and our external EMS assessor that we are 100% compliant, and that I can provide the evidence to support this?” If the answer is no - you will need to review your processes.

Why do you need to audit your EMS?

You need to have the confidence that the planned arrangements you have in place to achieve your policy commitments are working effectively. You will need to compile a suitable audit programme, and ensure that your auditors are suitably qualified to conduct these audits effectively. Your audit scopes should sufficiently cover all relevant clauses of the standard, and the audit reports produced should provide an accurate picture of the effectiveness of planned arrangements, highlighting corrective/preventive actions which need to be considered.

Why do we need to raise corrective and preventive actions? The answer may seem obvious, but all too often, organisations appear to address the symptomatic problems raised, only for the same problem to reappear later on. All problems have root causes, and an effective system for managing corrective and preventive actions should ensure that the root cause has been traced and that suitable changes have been made to the EMS to prevent the problem recurring.

Commonly encountered problems:

• Root causes not addressed.
• Corrective/preventive actions not effectively closed out.
• Non-audit related corrective/preventive actions (e.g. external complaints, leaking oil bund etc) not being dealt with in accordance with established procedure (quite often the relevant procedure will only make reference to audit findings).

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The review

“It is never wise to appear more clever than you are. It is sometimes wise to appear slightly less so.”

William Whitelaw, former Home Secretary

Periodically, your top management will be required to critically review the effectiveness of the EMS in achieving the company’s environmental policy commitments.

In order to do this, you will need to provide them with the information required to demonstrate that the planned arrangements are effective.

Key questions which will need to be asked include:

• Is the system delivering?
• What improvements are needed?
• What resource is needed to facilitate these improvements?
• Is the system ready for certification?

Commonly encountered problems:

• Inadequate scope of coverage- therefore ineffective review, reporting by exception- you will need to be able to demonstrate through review minutes that you have adequately reviewed the EMS.
  

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Certification

When choosing your certification body, you will want to ensure that they are accredited by a national body. In the UK, the national body is the United Kingdom Accreditation Service. For more information, visit the UKAS website at www.ukas.com.

Certification is an external verification of your EMS, to ensure that it meets with the requirements of the internationally recognised EMS standard, ISO 14001.

Your choice of certification body says a lot to your customers about how seriously you take your management systems. You need to choose a certification body that can help you develop your management system to reach its potential. With LRQA you will be allocated an account manager – or business advisor if on the small business’ scheme – who will discuss the best way to approach certification.

All LRQA assessors go through a rigorous selection and training programme followed by continual professional development and are all registered lead auditors with IRCA, (International Register of Certificated Auditors) the UK’s premier auditor registration body, providing you with the best the certification industry has to offer.

This gives you the assurance that by choosing LRQA as your certification body you will get a thorough but fair assessment supporting the ongoing development of your management system. In addition, as the LRQA brand is recognised globally, it will provide purchasers – wherever in the world they are based - with the confidence that your management system meets the requirements of ISO 14001.

If you are a UK based organisation employing up to 30* employees (this figure could be exceeded depending on the nature of the business – please call for details) you may be able to apply for our ISO 14001 small Business scheme. This gives you the benefit of paying by direct debit to aid cash flow.

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