Sustainability in Business

Documentation Requirements for Environmental Management Systems according to the requirements of ISO 14001:2015

Introduction

Many organizations tend to over-document when they design and implement management systems in general. Environmental management systems (EMS) based on the requirements of ISO 14001:2015 are no exception. Although there are a few mandatory documents required by the standard, it leaves the choice of other documents to be created to the discretion of the company implementing the system.

Mandatory Documents

According to the requirements of the standard, the following documents have to be created:

Document	Clause Nr
Scope of the environmental management system	4.3
Environmental policy	5.2
Procedure for the identification and evaluation of environmental aspects (especially criteria for determining significance)	6.1.2
Environmental objectives and plans to achieve them	6.2.1
Operational control procedures (as required)	8.1
Emergency planning and response plan or procedure (if applicable)	8.2

There are also a number of records that are mandatory records that needs to be kept:

Record	Clause Nr
List of interested parties and their needs and expectations	4.2 / 6.1.3
Risks and opportunities to be addressed (risk register)	6.1.1
Compliance obligations records	6.1.3 / 9.1.2
Competence records	7.2
Evidence of communication	7.4
Evidence of performance monitoring	9.1.1
Compliance evaluation records	9.1.2
Internal audit records	9.2
Management review records	9.3
Non-conformities and corrective action records	10.2

Some of the requirements for records are not very specific. It entirely depends on specific applicable issues, e.g. Evidence of performance evaluation. It is up to the company to decide what records would be applicable. Just remember that in some cases there may be legal requirements for specific records to be kept. An example would be a company that generates hazardous waste and disposes of it, where the permit conditions will determine which records must be kept, e.g. type, volume, disposal date, how and where it was disposed of, etc.

Organizations are left with the choice of which records exactly will be kept, but the records need to serve as evidence of conformance to the requirements of the standard, as well as compliance with legal and statutory and regulatory requirements.

 Non-mandatory documentation

The following documents are often created and included in the EMS of organizations, simply because they would add value to the system. They are created for at least two purposes:

•         They help to make the implementation and maintenance of the EMS “easier” and more effective      
•         They serve as proof of diligence and also proves to the auditor that the system conforms to all the standard requirements, and that the system is effective and efficient.

Typical examples of non-mandatory documents are:

Document	Clause Nr
Determining the context of the organization	4.1
Identifying interested parties and determining their needs and expectations	4.2
Competence determination and training procedure	7.2
Induction training (awareness training)	7.3
Procedure for the control of documented information	7.5
Procedure for monitoring and measurement	9.1
Procedure for the evaluation of compliance	9.1.2
Internal audit procedure	9.2
Procedure for nonconformances and corrective actions	10.2

In practice we have found that some of the documents are not created in a procedural format, but as a matrix or a template (e.g. communication matrix, template for determining the context of the organization, etc).  Always consider what would work best for your organization.

ISO 14001:2015 does not require us to document all procedures. Processes are slightly different. Several processes are mandatory to have in place to enable us to create certain records, as outlined under mandatory records (e.g. records for monitoring performance information, such as effective and efficient management of potential significant environmental impacts, etc). For this reason many companies document these processes and associated procedures. Ask yourself two questions:

•    Do we need a written procedure to ensure consistency between employees?
•    Would we be able to better demonstrate the effective implementation of our EMS if we document certain processes and procedures?

If the answer is yes, it would be better to document processes and procedures. Remember that clause 4.4 requires that the organization has to implement, maintain and continually improve an environmental management system, including the processes which are required and their interactions in accordance with the requirements of the standard. But base it on identified risks and opportunities, both organizational and operational.

•           Organizational: Mostly based on the results of the context evaluation and evaluation of the needs and expectations of interested parties, including business impacts as a result of environmental issues
•           Operational: Aspects and impacts identified by analyzing the operational processes and procedures of the organization

More information on documentation issues will follow in future articles.

I want to acknowledge the Advisera Training Academy for the very helpful information that they made available in this regard, some of which was used for this article.

Please visit out website at www.sheqmanagementsystem.co.za.

You can contact me directly at koosgouws10@gmail.com.

Until next time!

 Koos