EMS Document Control
You have to keep all your EMS-related documents controlled and up to date. Here’s what’s required:
- All EMS documents must be carefully controlled and be easily accessible to persons who need them.
- They must be periodically reviewed, revised, and approved by management.
- Obsolete documents must be promptly removed. For example, there is nothing worse than keeping a set of outdated environmental regulations as a reference document.
Your environmental policy also needs to be reviewed and made accessible to all employees. If you have set up environmental objectives, they can be updated or amended when the circumstances arise. Here are some other documents that your may have to update regularly:
- Applicable environmental law and regulations pertaining to your operations
- EMS manual
- Emergency response procedures
- Operational procedures for employees
- Document retention policy
- Responsibility matrix as assigned to employees
Tip: The most effective way to have a workable document control system is to assign someone with the responsibility of keeping an index of when revisions were made and track who has copies and where they are being kept.
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Managing EMS Records
Records are essentially written evidence that something has been done. Some documents turn into records once they are filled out. The key difference between documents and records is that you can change your documents but you cannot or should not change your records.
Make it easy on yourself. As you develop your EMS, try to keep the amount of records you keep to a minimum. Don’t go overboard with collecting data just for the sake of collecting data.
There are two types of records. One type consists of internal written material that you have set up as part of your EMS. Many of these internal records are voluntary and not required by law. For example, you may have internal audit checklists that you use periodically to verify the compliance status of your operations. Once these checklists are used in an audit, they become records that should not be changed. You need to make a judgment on how much of these discretionary internal records you want to generate and maintain–bearing in mind any legal liability that comes with having a long paper trail. ISO 14001 will require you to maintain a certain amount of records as part of the certification process. You have to strike a balance.
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The other types of records are those specifically required by law. You have little choice in this matter. If you have a wastewater discharge permit or an air emissions permit, the laws require you to maintain certain records for inspection by government agencies. You cannot alter these records without incurring severe civil and/or criminal penalties. Many of these environmental records are also required by law to be kept on file for a certain time period. Once the period expires, you have the option of destroying these records or continuing to keep them.
One set of records you should always keep is your hazardous waste manifests. The law requires you to keep them for 3 years. There is no reason you should destroy these records after the 3-year period because the government already has copies of your manifests on file. You want to hold on to your own records in case there is a dispute on what and how much of your waste ended in a Superfund site.
Your records must be legible, identifiable, and traceable as well as easily retrievable. You should have a system in place to protect against damage or loss of records. A retention policy should also be established for destroying sensitive records within the confines of legal requirements.
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 email@example.com, or visit the website at www.proactenv.com.