EHS Management

Got an EMS? Better Keep Good Records

The ISO focus is more on adopting a set of universally accepted procedures than being in compliance with local or national environmental laws. So, you don’t have to be in full compliance with environmental laws at the time you seek certification, but you must have a set of documented procedures in place that are designed to bring your organization into compliance.

EMS Documents You Need

Documents are essentially written procedures that tell your employees what they need to do and how to do it. Here are some examples of documentation:

  • Environmental policy. This is your organization’s vision to your employees and the outside world.
  • EMS manual and corporate procedures. These are instructions to employees on how to conduct various business operations without adversely impacting the environment.
  • Directives from top management. These are specific communications from senior management on its commitment to the process.
  • Inspection and report forms. These documents lay out the steps on how to verify that your operations are in conformance with ISO 14001 standards as well as other legal requirements.
  • Guidance documents. These are reference documents from outside sources that can help your employees meet ISO standards and legal requirements.

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Documents Commonly Found at a Company’s Headquarters

  • Structure and responsibility matrix. This document identifies who is responsible for what tasks.
  • Corporate training plan. This document lays out the training requirements for all employees. Note that not all employees are required to get the same level of environmental training. Training must be tailored to the job function of the employee.
  • Contractor audit checklist. These are procedures on how to select your vendors and contractors. This is a very important task when it comes to selecting the waste hauler and the ultimate disposal site for your hazardous wastes. Poor choices or lack of due diligence can result in enormous liability for your organization under the Superfund law.
  • EMS audit program. This document spells out the who, what, when, where, and how as they pertain to internal environmental audits. They can cover both compliance audits and management audits.
  • Management review program. This document commits your senior management to a process of reviewing your internal audit results and making the necessary refinements to your EMS as a result of the review.

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Documents Commonly Found at Plants or Satellite Areas

  • Environmental permits. It is absolutely critical that employees are made aware of the environmental permits that affect their operations. How else are they going to behave responsibly if they don’t even know the parameters of their operations?
  • Training plans for plant personnel. Different employees need to receive different levels of training. For example, the forklift truck driver responsible for moving hazardous wastes around the plant will likely get more training than other employees.
  • Weekly waste storage inspection form. This form is designed to help you demonstrate your compliance with legal requirements as a hazardous waste generator. (Note that once the form is filled out, it becomes a “record.”)
  • Compliance audit checklists. These checklists assist you in completing an environmental compliance audit of your operation. As with the inspection form, your audit results become part of your environmental records.

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, or visit the website at


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