ISO 14000 DO’S, DON’T’S, AND HOW TO’S

Prepared by
Robert L. Westly, P.G., and K. Mark Tumlin
SCS Engineers, December 2000

This article discusses some of the do’s, don'ts, and how to’s of ISO 14001. In general, an ISO 14000 EMS is the portion of an overall organization management system that includes organizational structure and associated practices and responsibilities for implementing and maintaining environmental policy.

All of the ISO 14000 standards are guidance documents, with the exception of ISO 14001. The basic foundation of ISO 14001 is continuous environmental improvement through the planning, implementation and review of management system; this standard is commonly referred to as the "Plan – Do – Check – Act " process. ISO 14001 contains EMS requirements that may be objectively audited for certification/registration purposes and/or self-declaration process.

There are five main elements associated with the EMS, as outlined in ISO 14001:

Environmental Policy - The organization commits to regulatory compliance, pollution prevention, and continuous environmental improvement in its environmental policy. The policy is endorsed by top management and made available to employees and the public.

Planning - When developing its plan, those activities of the organization that have significant environmental aspects are identified together with their potential environmental impacts. For example, the production of electricity (an activity) by a utility using fossil fuels (an aspect) has the potential impact of air pollution.

Implementation and Operation - Setting objectives and targets by themselves will not guarantee success. Programs to achieve these goals have to be implemented. This involves committing resources (people and money) to get the job done. The organization must appoint an EMS manager and ensure that employees are made aware of the EMS.

Checking and Corrective Action - To ensure that the programs are on track to meet their targets, systematic checks (audits) of the EMS are required. These audits can either be conducted internally (first party) or externally (third party). The intention of the audit is to identify areas for improvement within the EMS and to allow corrections to ensure that the organization meets its targets.

Management Review - The audit reports are submitted to senior management (the same people that endorsed the environmental policy) for review. Based on this view, they may revise the policy, objectives, and targets.

The following presents some do’s, don’t, and how to’s regarding implementation of an ISO 14001 EMS. These are intended to supplement the requirements of ISO 14001 and not repeat them. They assume that the reader knows or will learn the requirements of ISO 14001 and use what follows as insights into implementing those requirements.

DO’s

Identify the person that will be responsible for your ISO 14001 EMS and grant that person the authority that directors of other strategic business systems in your company hold (e.g., Vice President, Accounting).

Decide that the ISO 14001 EMS is the environmental management system your company wants to implement and why. Back into your environmental aspects evaluation by reviewing your existing environmental management programs.

Prepare an EMS manual, even though the current version (1996) of ISO 14001 does not require this manual. Obtain third-party review of your ISO 14001 EMS, whether you pursue registration or not.

Make your ISO 14001 EMS pay for itself. Develop "green accounting" processes to track costs and revenues.

Get qualified help if you do not have internal expertise in implementing an ISO 14001 EMS.

DON’T’S

An ISO 14001 EMS will become one of your strategic business systems. Do not ignore it and expect it to perform up to expectations.

Do not prepare your EMS in a vacuum – make your EMS plans known to employees.

Do not implement an EMS which is too comprehensive.

An EMS is a group process. Therefore, do not expect an EMS to be successful without the effort of the entire organization.

HOW TO’S

There are probably as many how to’s for implementing an ISO 14001 EMS at a facility as there are facilities. The following provides a series of steps often taken to attain third-party registration of an ISO 14001 EMS. The EHS manager typically is the person responsible for implementing an organization’s EMS and this is reflected in the following steps toward implementing and ISO 14001 EMS.

The EHS manager begins to educate himself/herself about ISO 14000 and ISO 14001 in particular. This can include attending short seminars or workshops all the way to attending an ISO 14001 Lead Auditor training class.

The EHS manager obtains a copy of ISO 14001 and possibly ISO 14004 (the key guidance document for implementing an ISO 14001 EMS).

The facility conducts a "gap" analysis of its existing (default) EMS to evaluate the gap between what exists and what is required by ISO 14001.

A core group of personnel are assembled to assist the EHS manager in preparing EMS and a brainstorming session is held to identify environmental aspects and work out a procedure for identifying aspects and significant impacts.

An EMS manual is prepared where ISO 14001 components missing from the existing EMS are implemented (team effort).

An internal audit, possibly with consultant assistance, is performed to confirm the operation of the ISO 14001 EMS and corrective actions are taken for nonconformance findings.

A certified ISO 14001 Registrar is retained by the organization. The Registrar’s lead auditor is interviewed by the EHS manager to approve his or her qualifications and the audit team is selected with the agreement of the EHS manager.

The facility submits written documents to the lead auditor demonstrating the presence and operation of an ISO 14001 EMS.

The lead auditor performs a review of the documents and makes a pre-audit visit to the facility to assess it readiness for a conformance audit to ISO 14001.

The facility makes necessary corrective actions from the auditor’s preliminary findings.

The audit team conducts its ISO 14001 conformance audit and reports results to the registrar.

The registrar reviews the audit results and awards a certificate of conformance to the facility, assuming that the audit is successful.

The lead auditor conducts surveillance audits every six months and conducts a recertification audit every three years.

The historical command and control management of business by environmental regulators is changing to a more proactive role of process management to improve environmental performance. With the expansion of markets, more economic pressure is being applied to organizations to implement environmental management. Therefore, implementation of an ISO 14001 EMS allows you to compete in the international market. Hopefully, the do’s, don’t’s, and how to’s of this article will assist you in this endeavor.

 
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