The Baseline Assessment involves an Initial Environmental Review (IER) and Gap Analysis (GA). The baseline assessment helps to establish the company's current level of environmental performance by conducting the IER and also helps to identify the "gaps" needed to close to comply with ISO 14001 requirements. The baseline assessment also helps to estimate the cost and manpower that will be involved.
Once the initial baseline assessment is completed, management will decide what the scope of the EMS will be and develop the organization’s environmental policy statement. The environmental policy will naturally be based on what is important to the organization in terms of vision and mission.
An early step in the process of developing an EMS is conducting a baseline analysis to establish the organization’s current methods for managing environmental concerns.
Next, management will decide on the scope of the EMS and develop the organization’s environmental policy statement. The environmental policy will naturally be based on what is important to the organization in terms of vision and mission.
When an organization implements an EMS, it has to make the decision about where the EMS will apply. The scope of the EMS is commonly referred to as the "fenceline." For instance your fenceline might include the following:
Generally, the scope will be the facility's entire operation. However, for large companies or facilities, a specific production operation, production line, or support activity may have its own EMS. It's also critically important management provides the resources needed for implementation.
An EMS begins with a strong environmental policy statement. The policy statement lays the groundwork for the EMS planning phase. It describes the company's approach to managing its environmental affairs and reflects its commitment to protecting human health and the environment. It acts as a contract between the personnel of the organization and company stakeholders. To help ensure an effective EMS, top management should pledge complete support and make a commitment to provide whatever resources are needed.
Developing an environmental policy helps to lay the groundwork for the EMS planning phase. In addition to the environmental policy, successful EMS implementation also requires:
EMS policy statements vary greatly, depending on the size and nature of the business. Here are a few samples for smaller companies:
For larger public- and private-sector organizations, the following policy statement might be use:
The International Organization for Standardization (ISO) develops and publishes international standards. ISO 14004:2016, Environmental management systems – General guidelines on principles, systems and support techniques, specifies requirements for an environmental management system to enable an organization to develop and implement a policy and objectives which take into account legal requirements and other requirements to which the organization subscribes, and information about significant environmental aspects. It applies to those environmental aspects that the organization identifies as those which it can control and those which it can influence. It does not itself state specific environmental performance criteria. (Source: ISO)
The Environmental Policy statement is the central focus of the environmental management system and should clearly communicate the following:
Employers must have a clear vision of who they are and what they want for the future. Once they know “who they are” as an organization, they can better plan what they need to do to achieve that vision with a concise mission statement. It’s important to understand core values about the environment are not merely priorities. Core values are non-negotiable: they don't change.
The commitment to control and improve environmental performance with respect to the environment leads to the development of Environmental Objectives and Targets. Once those items have been delineated the rest of the environmental management system is devoted to accomplishing the objectives and targets which fulfill the Environmental Policy.
Every organization has unique interactions with and impacts on the environment. These unique interactions are relevant to the nature of the activities, products and services the organization provides. The unique nature of the help to define the “context of the organization.”
An organization attempting to comply with the requirements of ISO 14001 must be able to demonstrate it is fully aware of all relevant environmental issues and their potential impact and importance. The organization should review at a minimum the following issues:
No distinct list will be appropriate to all organizations. The organization must develop its own methodology to investigate relevant environmental issues and their potential impact and importance.
Environmental Objectives are specific and defined goals that need to be achieved in order to meet the requirements of the Environmental Policy. Environmental Targets are detailed EMS quantifiable results that arise from and are usually stated within objectives. We'll be discussing these two important concepts in more detail in the next module.
Each Environmental Objective must be traceable back to the Environmental Policy statement. In order to be acceptable under the ISO 14001 standard every action, requirement, procedure, etc., contained within the environmental management system must have its roots in the Environmental Policy statement.
It's important to remember that if you can't trace specific environmental objectives back to the Environmental Policy statement it must be assumed that the Environmental Policy statement is not accurate. The Environmental Policy Statement must include objectives that address the organization's environmental aspects and impact.
The Compliance Obligations Requirements Procedure describes how the organization gathers information, analyzed it, and identifies the requirements that apply to operations. Like other EMS procedures, it describes the who, what, where, when, why, and how for an activity. Your company may be regulated primarily under the Resource Conservation and Recovery Act (RCRA), the Clean Air Act (CAA), and the Clean Water Act (CWA).
You may also identify other requirements that your company voluntarily implements. For example, you may be required to adhere to the company's policy to implement pollution prevention, improve environmental performance through objectives and targets, and communicate with the public on your environmental management progress.
ISO 14001 does not contain a specific clause that requires unconditional compliance with all applicable laws and regulations. What is required is as follows:
A continued pattern of noncompliance may lead to nonconformance with ISO 14001 due to a lack of an adequate "system to maintain compliance". If the organization subscribes to any codes of practice or voluntary guidelines the Environmental Policy statement will also need to include these agreements.
Top management, preferably the President or CEO, should sign the Environmental Policy statement. In addition, the Environmental Policy statement should be maintained in a manner consistent with Document Control procedures within ISO 14001.
This requirement is really a subset of the ISO 14001 section Training, Awareness and Competence. All employees within the organization must:
ISO 14001 encourages communication with external stakeholders. When a complete Environmental Policy statement is crafted by the organization, an opportunity is created to discuss openly the organization's Environmental Objectives. These objectives, along with mission and core values of the organization, have the potential to foster an open dialogue with outside parties.
View sample EMS Policy Statement developed by the Virginia Department of Environmental Quality
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