Planning
The next step is planning—by far the most difficult step. You need to identify all the significant environmental aspects of your operation. ISO 14001 defines an “environmental aspect” as an “element of an organization’s activities, products, or services that can interact with the environment.” So, you need to look at what you do throughout your company that affects the environment, such as air emissions, wastewater discharges, hazardous waste generation, heat generation, consumption of raw materials, and recycling of waste products.
The best way to do this is to involve your line supervisors and have them go through the process of identifying these environmental aspects. The more people involved in the process, the more ownership your employees have. An effective EMS also requires bottom-up involvement in addition to top-down support.
The term “significant” is not defined in the ISO 14001 standard. It is up to your team to determine what is significant and what is not. Don’t get hung up on an endless legalistic argument over this term. A general rule of thumb is to consider both the severity and frequency of the impact resulting from a specific aspect.
As part of the planning step, you need to set up your organization’s pollution prevention goal. Whatever your goals may be, make sure they are realistic and implementable. And make sure you have the resources to meet the goal. If your goals are so high and lofty that your company fails to meet them during the first year, it may have a demoralizing effect on your employees. Take small steps. You can always set higher goals later. Remember that your EMS is a living document—a work in progress.
Implementation
The next phase is implementation. Here you set out the procedures by which your company implements its planned goals and objectives. This is where the rubber meets the road. All your procedures must be clearly documented. Management of documents is an essential element of an EMS. You need to have someone in charge of updating your procedures and ensuring that outdated procedures are removed from use. For example, you will need to set out procedures on how you stay current on environmental regulations that affect your operations. There is nothing more dangerous than using outdated regulations.
Records control is also paramount. Your EMS must ensure your environmental records are accurately kept and easily accessible to those who need them. Bear in mind that “documents” and “records” are not the same. Documents tell you what you need to do. Records are proof that you have done it. The difference between “documents” and “records” is that documents can be changed and records cannot. Your standard operating procedures are documents; your monthly discharge monitoring reports are records.
Your implementation step will also include emergency planning and training of employees. Prevention of chemical accidents should be a top priority in your EMS. The key is to assign specific responsibilities to individuals. Know what chemicals you have on hand, and develop contingency plans to deal with them before you have a spill.
In terms of training your employees, your EMS should identify who should receive what level of environmental training. Both the operator who generates and handles hazardous wastes and the clerk who fills out the hazardous waste manifests require training—but not at the same level of intensity.
Your training requirements and procedures should be clearly spelled out in your documents. Evidence of training received should be contained in your records.
ISO 14001 is predicated on the continual improvement concept of “plan, do, check, and act.” This concept must be part of your policy. Now that you have planned and implemented an EMS, it is time to check it by performing an audit. You must ensure you have the financial resources and management commitment to fix any problems you uncover in the audit in a timely fashion. This is particularly critical if your audit uncovers some serious noncompliance legal issues. Failure to correct known violations quickly can and will be used against you in enforcement cases.
ISO standards require you to keep detailed records of all your audit results if you are planning on getting certified. Having an EMS in place without the certification will still get you many of the benefits. Regardless of whether you have certification, you should always do everything you can to fix any uncovered problems in a timely manner.
The last step in the continuous improvement cycle is for your senior management to review the status of your EMS and make improvements as needed. Your environmental coordinator in charge should play a lead role in this effort. It is recommended that you do a complete review of your EMS at least once a year.
This article is adapted from an article written by Norman Wei, owner and principal instructor at Environmental Management and Training, LLC. You can contact Mr. Wei at norman@proactenv.com, or visit the website at www.proactenv.com.