ISO 14001 Standards – Emergency Preparedness and Response Plans

ISO 14001 Section 4.4.7, Emergency Preparedness and Response, requires that organizations establish and maintain procedure(s) to:

1. Identify potential accidents and emergencies

2. Respond to accidents and emergencies

3. Prevent and mitigate the environmental impacts that may be associated with accidents and emergencies.

Section 4.4.7 also requires that organizations review and revise, when necessary, their emergency preparedness

and response procedure(s), especially after an accident or emergency situation. Organizations must also periodically test such procedures where practicable.

Most organizations have already developed and implemented emergency response plans to comply with various federal and state regulations that require such plans. Examples of federal regulations that require such plans include:

• Resource Conservation and Recovery Act (RCRA) Contingency Plans

• Spill Prevention, Control, and Countermeasures (SPCC) Plans

• Facility Oil Response Plans under the Oil Pollution Prevention Act of 1990

• Employee Emergency and Fire Prevention Plans under Occupational Safety and Health Administration (OSHA).

Some states have regulations that require similar emergency response plans. For instance, the state of Pennsylvania requires certain facilities to develop and implement a Preparedness, Prevention, and Contingency (PPC) Plan in addition to federal requirements.

The ISO 14001 requirements are similar to the requirements of most regulatory emergency plans. Whether your facility has emergency response plans or not, you should review the following sections to ensure you meet the ISO 14001 emergency response requirements.

ISO 14001 Section 4.4.7, Emergency Preparedness and Response, requires that organizations establish and maintain procedure(s) to:

1. Identify potential accidents and emergencies

2. Respond to accidents and emergencies

3. Prevent and mitigate the environmental impacts that may be associated with accidents and emergencies.

Section 4.4.7 also requires that organizations review and revise, when necessary, their emergency preparedness

and response procedure(s), especially after an accident or emergency situation. Organizations must also periodically test such procedures where practicable.

Most organizations have already developed and implemented emergency response plans to comply with various federal and state regulations that require such plans. Examples of federal regulations that require such plans include:

• Resource Conservation and Recovery Act (RCRA) Contingency Plans

• Spill Prevention, Control, and Countermeasures (SPCC) Plans

• Facility Oil Response Plans under the Oil Pollution Prevention Act of 1990

• Employee Emergency and Fire Prevention Plans under Occupational Safety and Health Administration (OSHA).

Some states have regulations that require similar emergency response plans. For instance, the state of Pennsylvania requires certain facilities to develop and implement a Preparedness, Prevention, and Contingency (PPC) Plan in addition to federal requirements.

The ISO 14001 requirements are similar to the requirements of most regulatory emergency plans. Whether your facility has emergency response plans or not, you should review the following sections to ensure you meet the ISO 14001 emergency response requirements.

ISO 14001 – Application to Small and Medium Size Enterprises

ISO 14001 – Application to Small and Medium Size Enterprises

Most of the development and application of EMS has taken place in large companies. The use of such systems in small and medium-size enterprises (SMEs) has been limited—although it is in this segment of industry that some of the largest benefits might be anticipated, because of the difficulty of regulating large numbers of small firms and the potential efficiency improvements that are believed to exist. In practice, however, the characteristics of the typical SME make the adoption of EMS difficult: most SMEs do not have a formal management structure, they lack technically trained personnel, and they are subject to severe short-term pressures on cash flow.

Anecdotal evidence indicates that an EMS cannot be used to drive improved performance in a poorly organized SME. Targeted training in management and quality control can improve overall performance, including its environmental aspects, and can provide a basis for more specific EMS development. Many firms can reap significant benefits from introducing quality management concepts, even where they are not aiming at formal certification. Any steps in this direction should be encouraged.

An EMS, as normally envisaged, builds on existing production and quality management systems. Where such systems are weak or ineffective, as is often the case in enterprises that have poor environmental performance, a better management framework has to be established before focusing on the details of the EMS. The costs of establishing an EMS will therefore obviously depend on the starting point in terms of both management systems and environmental performance.

The ecoefficiency savings can, in some cases, pay for the costs of establishing the EMS, particularly if most of the planning and organizational work is carried out in-house. However, a poor performer will very likely have to invest in production upgrading or pollution control in order to meet environmental requirements, and these costs can be significant.

A full EMS can be complex and can require an appreciable commitment of operational resources.

However, the final system can be reached reasonably through a series of discrete steps, starting from a basic, simple procedure and becoming more comprehensive and sophisticated as capabilities and resources allow. In this way, even a small enterprise can begin to put in place the basic elements of an ISO 14001 system and can develop them at an appropriate pace. Once the basic EMS is in place, it is possible to carry out a gap analysis and to make a balanced judgment on the costs and benefits of seeking certification.

A related issue is the coverage of the EMS. Certification is normally for specific sites or facilities.

A large enterprise may have a number of different sites and production facilities and may choose to seek certification only for a subset of the sites.

Nonconformity, Corrective Action and Preventive Action in ISO 14001 EMS

The intent of §4.5.3 is that the organization put in place procedures for 1) identifying actual and potential nonconformities to EMS requirements, 2) taking appropriate corrective or preventive action, and 3) reviewing the effectiveness of corrective or preventive actions taken.
The nonconformity requirement of ISO 14001:1996 was a passive requirement in that it was only triggered when a nonconformity came to the attention of the organization through one of the other EMS procedures, such as the EMS audit or management review. ISO 14001:2004, however, requires that the organization establish and maintain procedures to identify actual or potential nonconformities, determine their causes, take action to avoid recurrence or occurrence, record results, and review effectiveness of corrective or preventive actions.

How the organization goes about identifying actual or potential nonconformities is up to it to determine. From the standpoint of registration auditors, it would seem that they would want to see a specific procedure requiring members of the organization to conduct some kind of periodic checklist driven, walk-through inspection for nonconformities. In addition, the procedure should allow for submission of nonconformities by any member of the organization. Actual nonconformities are usually fairly evident and relatively easy to investigate because there is a tangible occurrence with which to deal. The organization should also want to evaluate minor instances of nonconformity that, while not significant in and of themselves, if they occurred under different circumstances, could lead to a significant deviation from the EMS. Such “near misses” could be identified by the occurrence of a sudden, unexpected event, a failure to achieve an objective or target, or a deviation from the Environmental Policy.
Potential nonconformities are more difficult to identify and correct. Here, application of Failure Mode and Effects Analysis would be appropriate for organizations having that capability.

When investigating nonconformities, organizations should focus on identifying underlying root causes, not just the immediate manifestation of the problem. If a chemical storage drum leaks, the organization should take action, first, to mitigate the damage and, then, to determine why the leak occurred; e.g., improper or negligent handling, mechanical failure, or lack of a leak detection system. Corrective or preventive actions should then focus on eliminating the cause through training, communication of procedures, use of leak-resistant drums, or installation of a leak detection system.

Other ISO 14001 sections, principally Emergency Preparedness and Response, Internal Audit, and Management Review, are tools that the organization implements in order to help identify instances of actual or potential nonconformity. The underlying principle of these sections is that the identification of nonconformities should be made by the organization through diligent application of these tools, not from the occurrence of an environmental event, a customer or community complaint, or investigation by a regulatory authority. While §4.5.3 does not specifically mention disciplinary action, in many cases disciplinary action or the threat of disciplinary action is appropriate to prevention of future nonconformities. Many organizations have written codes of conduct that give employees notice that deviations from the codes will not be tolerated and that prescribed penalties can result for infractions. These codes can be expanded to include penalties for deviations from the EMS. If so, penalties should be commensurate with the violation itself and should acknowledge the nature of the environmental damage, the degree of negligence, prior conduct, and the forthrightness of the employee being disciplined. Any such code and its remedies should be administered fairly and consistently and should have as its objective correction and prevention of EMS nonconformities, not punishment of employees.
Finally, identification, investigation, and correction of nonconformities leads to the need to revise documented procedures.

Key Elements of ISO 14001

The Resources, Roles, Responsibility, and Authority; Legal and Other Requirements; Evaluation of Compliance; and Nonconformity, Corrective Action and Preventive Action elements of ISO 14001 are all essential to the ongoing effectiveness of the EMS. This section describes how they function within the overall scheme.

1. Resources, Roles, Responsibility, and Authority (ISO 14001:2004, ?4.4.1)

?4.4.1 of ISO 14001 establishes three important requirements:

1. That management ensure the availability of resources to establish, implement, maintain, and improve the EMS;

2. That roles, responsibilities, and authorities be defined, documented, and communicated in order to facilitate effective environmental management; and

3. That top management appoint a management representative(s) who, irrespective of other responsibilities, will have responsibility and authority for implementing and maintaining the EMS and for reporting to top management on the performance of the EMS.

Ensuring Availability of Resources – Provision of resources for the EMS is almost always an issue within organizations. Although top management usually understands and accepts, at least in principle, the requirement to provide resources, the level of management that makes decisions on capital deployment and operating budgets often does not subscribe to the same requirement. Making the case for resources typically requires the implementation team or management representative to quantify intangibles such as the avoided cost of regulatory fines or the value to the environment of reducing environmental impacts.

When considering the requirement to provide resources, especially financial resources, it may be important to recognize that ISO 14001 requires the provision of resources for the establishment, implementation, maintenance, and improvement of the EMS, not necessarily resources to correct or prevent environmental impacts or to register to ISO 14001. When contemplating the cost of implementing ISO 14001, organizations, again, should think in terms of three separate cost categories:

1) Internal labor and external consultant costs to establish, implement, maintain, and improve the policy and procedural elements of ISO 14001;

2) Capital costs for correction or prevention of environmental impacts; and

3) Costs of registration to ISO 14001, if the organization elects to register.

Roles, Responsibilities, and Authorities – In the past, some organizations have employed a practice of not delegating responsibility and authority for environmental affairs to specific management representatives, reasoning that if the responsibility was diffused throughout the organization, no one person could become personally accountable for non-compliance with regulations or for environmental liabilities. §4.4.1 of ISO 14001 limits such ‘willful ignorance’ by requiring top management of the organization to appoint “specific management representative(s)” to ensure that the EMS is implemented and that top management be apprised of EMS performance. It also requires that the delegation of responsibility and authority be documented and communicated, thus eliminating circumstances where responsibility and authority for the EMS are diffuse or uncertain.

When §4.4.1 is read together with the requirement of the Environmental Policy for a commitment to comply with applicable legal requirements, §4.3.2, Legal and Other

Requirements, requiring a procedure for identifying legal requirements (following), and §4.5.2, Evaluation of Compliance, requiring a procedure for evaluating regulatory compliance, it is evident that the management representative is also responsible for ensuring that the organization is in compliance with applicable regulations. While this responsibility and authority can be delegated, the chain of delegation begins with top management and is passed to the management representative, effectively eliminating any uncertainty as to who is responsible and authorized to ensure regulatory compliance.

EMS Organizational Structure – There is an almost universal norm for the management structure of the EMS organization under ISO 14001. It begins with the top management position, proceeds to the top manager’s leadership team, and then to an EMS implementation team that is generally chaired by the management representative. The departments making up the relevant functions and levels of the organization and environmental, safety, and health professionals comprise the typical implementation team.

Defining Roles, Responsibilities, and Authorities for the EMS – In defining, documenting, and communicating EMS roles, responsibilities, and authorities, it makes sense to begin with top management and proceed through all of the positions having EMS responsibilities. Following is a generic example of how roles, responsibilities, and authorities might be documented and communicated in an EMS Procedures Manual:

Plant Manager

Authority: The Plant Manager has the authority, responsibility, and accountability for managing all aspects of ABC Company’s activities, products, and services at the Anytown facility.Source: Senior Vice President, Manufacturing, ABC Company, Inc.

EMS Responsibilities: Under the requirements of ISO 14001, the Plant Manager shall be specifically responsible for:

1) Defining the Environmental Policy;

2) Delegating authority and responsibility for the establishment, implementation, maintenance, and improvement of the EMS;

3) Providing human, technological, infrastructure, and financial resources and specialized skills; and

4) Periodically reviewing the EMS for suitability, adequacy, and effectiveness and directing changes as necessary to achieve the goals for an EMS and the commitment to continual improvement.

Leadership Team

EMS Responsibilities: The Leadership Team shall advise the Plant Manager on the exercise by

the Plant Manager of his/her responsibilities for the EMS.

Management Representative, Implementation and Maintenance Responsibilities

EMS Authority: The Plant Manager delegates to the Manager, ______ _______, the authority

to establish, implement, maintain, and improve the Environmental Management System and to

ensure that it conforms to the requirements of ISO 14001. In the context of ISO 14001, the

Manager, _____ _________, shall be the Management Representative.

Implementing ISO 14001

ISO 14001 is an internationally recognised standard that provides a framework for a strategic approach to corporate environmental management. This standard gives organisations the means to identify and control their environmental impacts, improve performance and achieve their objectives and targets. The standard is independently audited, giving it great strength and integrity.

Due to its widespread adoption (e.g. Barclays, Credit Suisse and UBS in the financial sector), it now acts as a common reference for communication about environmental issues. ISO 14001 provides assurance to stakeholders on environmental claims and helps organisations meet requirements laid down by clients and investors.

Adoption of ISO 14001 is being driven by stakeholder concerns as well as the significant benefits on offer to adopters. Few companies are now exempt from government, client and investor demands for accountability and improved environmental performance. With brand and reputation on the line, it is a risky strategy to ignore these concerns.

However, choosing how to act is not a straightforward decision. Companies that rushed to announce their green credentials without independent verification and transparency fell foul of greenwash accusations and suffered perhaps more damage to their reputation than had they not acted in the first place. In response to this, many companies are now choosing to implement internationally recognised and independently audited environmental management systems such as ISO 14001.

The benefits of implementing ISO 14001 are extensive:

It immediately enhances corporate reputation and sends a clear signal of commitment to corporate responsibility. Accusations of greenwash are prevented by the transparent and robust approach of the standard.

Proactive environmental management increases attractiveness to investors, especially for Socially Responsible Investment (SRI), an area already accounting for £9 billion investment per year in the UK alone.

ISO 14001 accreditation may also bring financial benefits through increased market share. Firms can differentiate themselves from competitors as responsible companies as well as securing the rewards of first mover advantage in new markets. In addition, many buyers are now implementing sustainable procurement codes and stipulating conditions in Requests for Information (RFIs) where suppliers are required to have environmental credentials. Gaining ISO 14001 accreditation ensures access to environmentally demanding but high reward markets.

Financial benefits are not limited to increased investment and sales. Implementation of an EMS may produce significant cost savings that actually negate the initial outlay. With energy and waste prices rising sharply, environmental responsibility can produce a win:win opportunity.

Perhaps the most significant benefit for many will be the positive effect on attracting and retaining staff. With intense competition for the best staff, corporate responsibility is becoming a key criterion against which employers are judged.

Finally, responsible environmental management is quickly becoming a necessary condition for business, a socially accepted norm of behaviour. Those who fail to follow these norms risk damage to their reputation and the possibility of their social licence to operate being revoked.

A standard as thorough and robust as ISO 14001 has an equally thorough implementation process with extensive requirements for procedures and auditable document trails. Implementation follows the Plan-Do-Check-Review cycle and key required procedures are detailed in the diagram below. Implementation will entail the creation of at least 20 procedures and supporting documents. The procedures are all company-specific and must be tailored to suit individual operations. It is this level of detail that gives the standard such strength and integrity.

ISO 14001 STANDARD

ISO 14001 is in fact a series of international standards on environmental management. It provides a framework for the development of an [url=htttp://www.iso9001store.com/]environmental management system[/url] and the supporting audit programme.

The ISO 14001 series emerged primarily as a result of the Uruguay round of the GATT negotiations and the Rio Summit on the Environment held in 1992. While GATT concentrates on the need to reduce non-tariff barriers to trade, the Rio Summit generated a commitment to protection of the environment across the world.

After the rapid acceptance of ISO 9000, and the increase of environmental standards around the world, the International Standards Organisation (ISO) assessed the need for internationalenvironmental management standards. They formed the Strategic Advisory Group on the Environment (SAGE) in 1991, to consider whether such standards could serve to:

Promote a common approach to environmental management similar to quality management;
Enhance organizations’ ability to attain and measure improvements in environmental performance; and
Facilitate trade and remove trade barriers.
In 1992, SAGE’s recommendations created a new committee, TC 207, for international environmental management standards. This committee and its sub-committees included representatives from industry, standards organizations, government and environmental organizations from many countries. What developed was a series of ISO14000 standardsdesigned to cover:

-environmental management systems
-environmental auditing
-environmental performance evaluation
-environmental labelling
-life-cycle assessment
-environmental aspects in product standards

ISO 14001 was first published as a standard in 1996 and it specifies the actual requirements for an environmental management system. It applies to those environmental aspects over which an organization has control and where it can be expected to have an influence.

ISO 14001 is often seen as the corner-stone standard of the ISO 14000 series. It specifies a framework of control for an Environmental Management System and is the only ISO 14000 standard against which it is currently possible to be certified by an external certification body. However, it does not in itself state specific environmental performance criteria.

Role of Governments in ISO 14001 Standards

Role of Governments in ISO 14001 Standards

Although ISO 14001 is a set of voluntary standards that individual companies may or may not choose to adopt, governments can clearly have a role in providing information, establishing the necessary framework and infrastructure, and, in some cases, helping companies to develop the
basic capabilities to adopt ISO 14001. There are wo particular areas in which government action would be useful:
(a) providing information on he sectors and markets where ISO 14001 certification s a significant issue and assisting sector rganizations to develop appropriate responses, and
(b) helping to establish a certification framework, ased on strengthening national standards organizations and encouraging competitive private sector provision of auditing and certification
services. At present, the World Bank is having discussions with a number of countries about how assistance could be provided with these issues.

Governments should see EMS approaches as part of a broad environmental strategy that includes regulatory systems, appropriate financial incentives, and encouragement of improved industrial performance. Such encouragement can really only be effective where there is cooperation at the government level between the relevant departments, including industry and trade, as well as environment. There is a growing interest in integrating environmental management issues into productivity or competitiveness centers designed to promote SME performance, but little information exists on experience to date.