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ISO 14001:2004 Revision:
Implementation and Operation
by Capaccio Environmental Engineering, Inc.
The ISO
14001:2004 revision has now been released for twelve
months and the May 15, 2006 deadline for re-certifying
existing registrations is rapidly approaching.
Organizations that are newly registering their
Environmental Management System (EMS) to ISO 14001 are not
subject to this deadline, but will be required to meet all
of the requirements of the ISO 14001:2004 revision. In
this article, we continue
our series reviewing the changes by section with a
discussion of how the ISO14001:2004 revision impacts
section 4.4 “Implementation and Operation”.
As with
other changes to the standard, an initial review of the
“Implementation and Operation” section reveals a number of
ostensibly minor changes in wording. Yet upon further
examination, these subtle changes significantly affect the
interpretation of the intent behind various requirements
within the standard. We have noted in
previous articles that the ISO 14001:2004 revision is
an improvement because it provides greater clarity on
these requirements. However, it is important that
organizations that are upgrading their certifications (or
that are going for their initial certifications) review
and fully understand the impact of these changes so that
they can ensure the requirements are appropriately
addressed within their environmental management systems.
Below, we specifically review the impacts of changes from
ISO14001:1996 to ISO 14001:2004 for sections
4.4.1 “Structure and Responsibility”,
4.4.2 “Training, Awareness, and Competence”,
4.4.3 “Communication”,
4.4.4 “Environmental Management System Documentation”,
4.4.5 “Document Control”,
4.4.6 “Operational Control”, and
4.4.7 “Emergency Preparedness and Response”.
Review of the changes & impacts:
Section 4.4.1 Resources Roles, Responsibility and
Authority
The seemingly simple change
of the title from “Structure and Responsibility” to
“Resources Roles, Responsibility and Authority” actually
signifies a much stronger emphasis on resources and
authority in the new version of the standard. The
backbone of the entire EMS is contingent upon top-level
management commitment, without which the EMS is not
sustainable. ISO management system standards have always
focused on “say what you do, and do what you say”. The
commitments expressed in the environmental policy
(required by Section 4.2 of the standard) are meaningless
without the appropriate structure to implement the
system. The addition of “implement” to “maintain, and
improve” as part of the responsibilities for management
underscores the need for the organization to be able to
demonstrate that the resources are available to actually
put the plan in place. By adding “organizational
infrastructure” to potential resources of “human,
specialized skills, technology and financial”, the revised
standard makes clear that the EMS must have depth within
the organization such that it is incorporated into core
operations and is not just an adjunct area of the
business. In essence, the changes in this section
emphasize the need to demonstrate management commitment by
not only assigning responsibility and creating an
organizational structure for environmental management, but
more importantly, by providing the required resources and
authority to enable the necessary actions to implement,
sustain, and continually improve the EMS.
Section 4.4.2 Competence, Training, and Awareness
By moving the word
“competence” to the beginning of the title of this
section, the 2004 revision signals the greater importance
of competence. Just identifying training needs and
providing training is no longer sufficient to conform to
the new standard. An organization now must also be able
to provide evidence of competence by maintaining training
records (e.g., quiz or test results indicating that a
specified minimum proficiency requirement has been
achieved).
Another significant
addition, is the inclusion of “those working on behalf of
the organization”, such as contractors and suppliers, in
the requirement to demonstrate competence. At a minimum,
the organization must ensure that “all persons working for
or on its behalf” are aware of the EMS policy, the
requirements of the EMS, their roles and responsibilities
within the EMS, the significant environmental aspects and
corresponding impacts of their work activities, the
benefits of improved performance, and the consequences of
deviation from the applicable EMS requirements.
Therefore, an organization will need to take these
additional requirements into account when identifying,
implementing, and documenting training needs for both
employees and contractors/suppliers.
Section 4.4.3 Communication
The “Communication” section
requirements is clarified within EMS ISO 14001:2004 by
adding “implement” to “establish and maintain” a procedure
for communication, meaning that solely having a
communication procedure is insufficient for meeting the
requirements of this section of the standard. For
internal communications, the revised wording of the new
standard clarifies the need to actively implement
communications. Such communications may be implemented
through meetings, bulletin boards, newsletters, emails,
memos, events, etc.
For external
communications, it continues to be important to respond to
relevant communications. An organization also continues
to have flexibility to determine whether or not to
communicate externally about its significant environmental
aspects. However, the new version of the standard clearly
states the need to document the organization’s decision
with respect to externally communicating its significant
environmental aspects and impacts (although this
requirement was implied in the Annex to the 1996 version
of the standard, it was not clearly stated in the original
wording), thereby providing objective evidence of their
decision. If the organization decides that it will
communicate these environmental aspects and impacts
externally, then it must develop, document, and execute a
method for the external communication (i.e., The
organization must have a documented communications
procedure, and it must be able to provide evidence of
demonstrating implementation of this procedure).
Section 4.4.4 Documentation
In ISO 14001:2004, the
title of section 4.4.4 has been changed from
“Environmental Management System Documentation” to the
more encompassing term “Documentation”, and the section
itself more clearly identifies required documentation.
Specifically, the revised standard explicitly states that
an organization must document its:
- Environmental Policy
- Objectives and Targets
- “Scope of the
Environmental Management System” (i.e., the operations,
activities, and services covered by the EMS)
- “main elements of the
EMS” and the “interaction” among the main elements,
including related documents (typically, this would be
accomplished via an EMS manual summarizing the main
elements of the system and their interaction, and
pointing to related documentation for details).
- “Documents as defined by
the ISO 14001 Standard, including records”
- Documents, including
records, determined by the organization, that “confirms
the effective planning, operation and control of
processes” related to “significant environmental
aspects”.
Section 4.4.5 Control of Documents
The intent of this section
is to ensure that organizations create and maintain
documents in a manner sufficient to implement and sustain
the environmental management system.
In the ISO14001:2004
revision, the title is changed from “Document Control” to
“Control of Documents”, placing a greater emphasis on
controlling documents. The revision adds “implement” to
the requirement to “establish and maintain” a procedure
for controlling documents, again emphasizing the need to
demonstrate evidence that the procedure is in use. The
revised standard also provides more detail on the
expectations for a document control system to ensure that
the current documents are in use and have been
appropriately reviewed and approved by management.
Re-approval of revised documents is now also included in
this requirement. In addition, the revisions and the
revision status of documents must be clearly identified.
Another change is that organizations are now required to
ensure that “documents of external origin” are identified
and their distribution controlled, if these documents are
determined by the organization to be necessary for the
“planning and operation of the environmental management
system”. Examples of external documents include
environmental operating permits, vendor operation and
maintenance manuals for pollution abatement equipment,
etc. Thus, it will be necessary for organizations to
develop a process, or incorporate into an existing
process, the control and distribution of external
documents.
Previously in ISO14001 1996
“relevant documents” were to be available at all locations
essential to the effective functioning of the EMS. Now
the ISO 14001:2004 revision has refined the wording in
this requirement from “available at all locations” to
“available at points of use” to clarify that the documents
must be available at the specific location where the
procedures are used. Thus, organizations should review
their document availability process to ensure that
relevant documents are accessible by appropriate personnel
at all locations where used.
Section 4.4.6 Operational Control
Updates to this section
reflect a stronger emphasis on the “planning” and
“control” components of operational control.
Specifically, the revision requires that organizations
consider potential for deviations as part of their
planning process, and that they develop and implement
sufficient controls to prevent such deviations from
occurring. Instead of relying on an alarm indicating that
the deviation has already occurred, measures need to be
put in place to ensure that appropriate actions are taken
prior to the occurrence of a non-conformance. For
example, if you have a calendar indicating submittal
deadlines for legal and other requirements, you would
need to have some type of control mechanism in place to
ensure that these dates are met (finding out that a report
is due next week, or worse yet last week, when it takes
several months to put the report together is
insufficient!). In this example, a control could be
scheduling process milestones that are reviewed and
tracked to ensure that the organization is on-target for
the critical regulatory due date. Likewise, an
organization may specify operational set points within a
pollution abatement system to ensure that emissions are
within permitted criteria, as well as backup systems or
operations to prevent releases when problems are
detected. The ISO14001:2004 revision also continues to
stress the importance of ensuring that procedures are
in-use by adding “implement” to “establish and maintain”
to the operational control requirements. An organization
should review the documented definition of ”Operational
Control” for alignment with ISO 14001:2004 and ensure
procedures and processes meet the criteria and, where
necessary, make appropriate changes.
Section 4.4.7 Emergency Preparedness and Response
The “Emergency,
Preparedness and Response” section is updated in ISO
14001:2004 to further clarify the intent of these
requirements. As with the operational control section,
the emergency preparedness and response section emphasizes
the need to plan for both potential and actual
emergencies. The ISO14001:2004 revision adds a
requirement for the definition of “how” the company will
respond to both “actual” and potential emergency
situations in its “Emergency Preparedness and Response”
procedure. Again, the ISO14001:2004 revision adds
“implement” to “establish and maintain” documented
Emergency Preparedness and Response procedures, making
clear that these must be working documents. In addition
to the existing requirements for periodically testing
these procedures where practicable, the revision now adds
the requirement to “periodically review” Emergency
Preparedness and Response procedures themselves to ensure
that operational and site changes and other pertinent
situations are addressed. Thus an organization will need
to define and document the time expectation for the
periodic document review.
In Summary
ISO
14001:2004 Standard Update
The
changes to the various subsections of ISO 14001 Section
4.4 “Implementation and Operation” include both
refinements in wording to clarify the ISO expectations for
meeting the requirements of the standard, as well as
specific additions to the requirements. These changes
emphasize the need for demonstrated top management
commitment, as well as the need to provide evidence of
effective implementation of the EMS. To avoid being taken
by surprise in your upcoming registration audit, it is
important to read these revisions carefully and review
your Environmental Management System (EMS) to ensure that
these subtleties are appropriately captured within your
systems and procedures. Companies that are registered
to the ISO 14001:1996 standard will need to upgrade their
system and be re-certified to the ISO 14001:2004 standard
no later than May 15, 2006.
We will
work through understanding the remaining elements and
continue our drive towards the checkered flag of an ISO
14001:2004 compliant system in future E-blasts. Stay
tuned!
If you
are interested in learning more about the IS014001:2004
revision or Capaccio Environmental Engineering, Inc.
ISO14001:2004 Revision Services, please contact
Paula Esty at 508-970-0033 ext. 128 or click
here to
request more information.
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