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.

Origins of the ISO’s Work

The ISO is a federation of non-governmental organizations established in 1947 to develop international standards, improve international communication and collaboration, and facilitate the exchange of goods and services. The federation is currently comprised of close to 100 national standards bodies (member bodies) from countries representing approximately 95 percent of the world’s industrial production.

The headquarters of the ISO secretariat is in Geneva, Switzerland.2 The ISO’s involvement in establishing environmental standardsbegan in 1991 after organizers for the UN Conference on Environment and Development (held in Rio de Janeiro in 1992) asked whether or not ISO would be attending the conference and whether it was involved in any environmental activities. As a result, the ISO established a Strategic Advisory Group on the Environment (SAGE) in 1991 to assess the need for international environmental management standards.3 SAGE recommended that ISO proceed with an environmental standard by 1992 and that a technical committee be established to carry it through. On June 1, 1993, ISO’s Technical Committee 207 (TC 207) held its first plenary meeting.

TC 207 was directed to establish environmental standards in five areas of environmental management:
- environmental management systems; environmental auditing and related
- environmental investigation; environmental labeling; environmental performance evaluation; and life-cycle assessment.

Consequently, TC 207 was divided into five subcommittees (SCs) for each category of standard and one SC to cover the terms and definitions of the standards. In addition, a working group, which reports directly to TC 207, was formed to deal with the environmental aspects in product standards. The five SCs have two or more working groups (WGs) that report to them (unlike the WG on product standards previously mentioned which reports directly to TC 207).

The key factor that has propelled the ISO 14000 series of standards forward throughout the early 1990s is the increase in national environmental standards. Examples of these standards include some two dozen eco-labeling schemes worldwide (see Annex 1), the British Standards Institute’s BS 7750 (Specification for Environmental Management Systems), the Canadian Standards Association’s Z750 (A Guide for a Voluntary Environmental Management System), and the EU EMAS (Eco-Management and Audit Scheme). Other similar environmental management standards have been developed by the French Standards Association, the South African Bureau of Standards and the Spanish Standards Association.

With the proliferation of environmental standards, concerns have been expressed that these standards would fragment international markets and unduly favor the companies of the countries or of the regions where these standards were developed, unless they were developed by authoritative and broadly based international bodies. The ISO was to serve this role.

Identification of environmental aspects and impacts

An organization’s policy, objectives and targets should be based on knowledge about the environmental aspects
and significant environmental impacts associated with its activities, products or services. This can ensure that the
significant environmental impacts associated with these aspects are taken into account in setting the environmental
objectives. The relation between environmental aspects and impacts is one of cause and effect. An environmental
aspect refers to an element of an organization’s activity, which can have a beneficial or adverse effect on the
environment. For example, it could involve a discharge, an emission, consumption or reuse of a material, or
noise. An impact refers to the change which takes place in the environment as a result of the aspect. Examples of
impacts might include contamination of water or depletion of a natural resource.

The identification of environmental aspects and the evaluation of environmental impacts is a process that can be
dealt with in four steps:

Step 1: Select an activity or process. (The selected activity or process should be large enough for meaningful
examination and small enough to be sufficiently understood.)

Step 2: Identify environmental aspects of the activity product or service. (Identify as many environmental aspects
as possible associated with the selected activity or process.)

Step 3: Identify environmental impacts. (Identify as many actual and potential, positive and negative,
environmental impacts as possible associated with each identified aspect.)

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 ENVIRONMENTAL MANAGEMENT

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

ISO 14001 is often seen as the corner stone standard of the ISO 14000 series. However, it is not only the most well known, but is the only ISO 14000 standard against which it is currently possible to be certified by an external certification authority. Having stated this, it does not itself state specific environmental performance criteria.

This standard is applicable to any organization that wishes to:

- implement, maintain and improve an environmental management system
- assure itself of its conformance with its own stated environmental policy (those policy commitments of course must be made)
- demonstrate conformance
- ensure compliance with environmental laws and regulations
- seek certification of its environmental management system by an external third party organization
- make a self-determination of conformance

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

ISO 14001 is often seen as the corner stone standard of the ISO 14000 series. However, it is not only the most well known, but is the only ISO 14000 standard against which it is currently possible to be certified by an external certification authority. Having stated this, it does not itself state specific environmental performance criteria.

This standard is applicable to any organization that wishes to:

- implement, maintain and improve an environmental management system
- assure itself of its conformance with its own stated environmental policy (those policy commitments of course must be made)
- demonstrate conformance
- ensure compliance with environmental laws and regulations
- seek certification of its environmental management system by an external third party organization
- make a self-determination of conformance

ISO 14001 ENVIRONMENTAL MANAGEMENT SYSTEM AUDIT

In order to be in conformance with this provision of ISO 14001 an organization must be able to answer the overall question: “How does the organization conduct environmental audits of the EMS?”. In order to answer that question four specific tasks must be addressed under the Management System Audit section of the standard.

First, the organization must develop a program and related procedures that define an audit plan of the environmental management system. In addition the program must define frequency of the audit process. Second, the procedures must specify the methodology of the audit process, including the qualifications of the auditors. Third, the audit reports must be submitted to top management. Fourth, the audit reports must provide recommendations directed at correcting any reported nonconformance that was discovered in the audit process.

The audit process discussed in this section of the standard is directed at internal audits. The standard is silent on the frequency issue. Generally accepted practice with a mature ISO 14001 system is a total audit of the system once a year. In the implementation phase of an environmental management system a more frequent audit process might be appropriate. In addition any part of the environmental management system that has been previously determined to be in nonconformance should be audited with an increased frequency. The methodology of the audit process required by the standard requires two distinct steps:

A. determine whether the environmental management system conforms to the requirements of ISO 14001, and
B. that the system has been managed as described in the Environmental Policy statement, the Environmental Objectives and Targets, and the related work descriptions and procedures.

It is critical that an audit report that relates a nonconformance be forwarded to top management promptly. The internal audit staff must be competent with respect to the requirements of ISO 14001.

ISO 14001 Standard

ISO 14001 Standard – Environment Management System