Accelerated EMS Session 4 – 28 January 2008.

Accelerated EMS Session 4 – 28 January 2008

Agenda - WIP Review Policy – complete Aspects and Impacts – complete
Legal and Other Drivers – complete Objectives and Targets – working draft Environmental Action Plan – working draft Ownership – Structure and Responsibilities – final draft

Agenda - WIP Review Training, Awareness and Competence - draft Communication - draft EMS Record Keeping – started, more today Your system – based on the template provided is one way….

Today – Month 4 EMS Map Document Control Procedures Emergency Actions

Environmental Policy environmental policy (ISO14001:2004)
overall intentions and direction of an organization related to its environmental performance as formally expressed by top management NOTE The environmental policy provides a framework for action and for the setting of environmental objectives and environmental targets.

Aspects ISO14001 Definition of an Aspect: ‘An element of an organisation’s activities, products or services that can interact with the environment’. An aspect has the potential to impact on the environment to a greater or lesser degree E.G. Activity = Car Use Aspect = Fuel Consumption Note that fuel consumption is not the only aspect related to car use - possibly open this upto the groups to suggest some other aspects. E.G. Oil consumption, Tyre consumption, Fume Emissions, noise, visual intrusion, congestion, parts consumption, end of life disposal (possibly more related to the car as a product, but use creates the need and ware). Other possible aspect examples: Activity = cleaning machinery, Aspect = Water Consumption, water discharge, solvent use. Product = Plastic key rings, Aspect = oil consumption, energy consumption, use of highly toxic monimers, distribution of products, use of packaging materials, generation of solid waste, VOC emissions. . Service = Vehicle maintenance, Aspect = use of oils and lubricants, consumption of parts, production of waste, energy consumption, noise genration.

Impacts ISO14001 definition of an Impact: ‘Any change to the environment, whether adverse or beneficial, wholly or partially resulting from an organisation’s aspects’ The actual physical change in the environment resulting from an aspect E.G. Activity = Car Use Aspect = Fuel Consumption Impact = Increase of CO2 in the atmosphere (global warming) Make the point that each activity, product or service might have a number of aspects, and each aspect might have a number of impacts. Ask the group to suggest some more impacts related to fuel consumption. E.G. Resource depletion, Emissions of CO, NOX, SO2, Particulate Matter, VOC release - increasing ground ozone, disruption to habitats and ecosystems through extraction, energy consumption in refining and distribution. Make the point that impacts need to be identified even if they are not common or planned. Note different situations Normal, Occasional, Abnormal, Emergency Introduce people to Aspects and Impacts card exercise to get people moving around. (see Aspects and Impacts card exercise guide notes).

Some Common Approaches
RISK BASED CRITERIA BASED ISSUES BASED Risk based: Often employs scoring methodology - most traditional of approaches. Can use frequency x severity x scale x duration or impact x probability. Probability needs considering when situations are abnormal or emergency, whereas the first approach is probably better suited to normal and occasional situations. Symbols or colours could be used in place of scores. Risk based approaches do not really allow for inclusion of external issues in the assessment process without becoming very unwieldy and subjective. Criteria based approaches select a number of key criteria and make assessment against each of these. Scoring approaches or simple yes no answers are most commonly used possibly in conjunction with some form of weighting. Symbols and colours can also be quite effective. Issues based assessments focus on external issues, environment, risks, financial opportunities, market forces, views of interested parties, and organisational values. Possibly majoring on more specific issues such as local community reaction, pressure group interest, shareholder interest. Scores colours or symbols can be used. Purists would argue that issues based approaches are diluting the emphasis on environment, but in many organisations these will be the main drivers of activity and should be acknowledged in any assessment which then informs actions.

Significance Assessment
Top Tips: Make it appropriate for your organisation Don’t make it too involved - remember, it’s a means to an end! You’ve got to keep it up to date! Recognise subjectivity and try to minimise it Conduct a ‘Sanity Check’ on the results Mention to delegates that the guidance notes explain significance assessment in more detail and that there are some examples outlined of three different approaches.

The legal register While a legal register is NOT a specific requirement of ISO 14001, many organisations see it as the most practical way to manage the issue Can provide a framework to help check and ensure compliance Provides a structure for the procedure of identification and compliance checking which IS required by the standard Discuss the concept of a legal register. Explain that this IS NOT A REQUIREMENT but that a lot of organisations find this the best way to approach, document and demonstrate what they have done. As such it can help you meet a few requirements of the standard in one go. (Tutor may wish to refer back to slide 20)

Objectives &Targets: The Role of Indicators
Demonstrate that targets have been achieved Help you track progress against targets Help you identify problems, opportunities, and solutions Support your objectives and targets with suitable indicators Indicators should form an integral part of the development and setting of objectives and targets. We have already identified that objectives and targets should be measurable so indicators just formalise that measurement process to ensure that the information is consistent and reliable. Indicator development might well shape the wording or nature of the target or even the objective - as the indicator will be based on what can be measured realistically and to what level of detail. Indicators should report regularly enough to provide information on which decisions can be taken for action - if they are not regular enough for the target in question they will not provide opportunity to take corrective action and may not allow analysis to show root causes of problems. Think, if they had used indicators when building the tower of Pisa it would have been upright (weak Joke). Indicators are used to tell them how much the tower moves per year - thus allowing them to take necessary action.

Steps to Setting Objectives, Targets, and Indicators
1) Identify broad aims from policy 2) Consider significant aspects and impacts 4) Draft targets to support objectives 3) Draft objectives Explain process to follow when setting O&Ts following through arrow boxes on screen - stress importance of O&Ts being supportive of the policy and consistent with one and other. Mention that when quantifying O&Ts this might need to be an iterative process with establishing indicators (particularly at target level where more detail will be specified). The indicators you establish might dictate the terminology used for targets and objectives as we should be striving for indicators to be measurable and achievable. Initiate open discussion with group asking for suggestions on possible objectives for the two scenario companies (use one flip chart for each) - this might be difficult without policies for the scenario companies so possibly you could ask companies to come up with possible O&Ts for their own organisations. Stress importance of focussing on policy commitments not just O&Ts. Also emphasise the importance of having a hierarchy of detail, and setting O&Ts which are not too short lived. Typical policy commitments to help discussion if needed. Legal and contractual compliance, Pollution prevention, Waste minimisation, Improvements in resource efficiency, Increased use of recycled or sustainable materials, Training of employees, Working with suppliers, Communications and reporting, Establishing an EMS, Establishing and reviewing objectives and targets 5) Identify indicators to track against targets 6) Check all elements for consistency

Environmental Management Programmes
ISO14001 states: ‘The organisation shall establish and maintain programme(s) for achieving its objectives and targets’ ISO14001 requires: Designated responsibility The means The time-frame New projects to be incorporated The organisation shall establish and maintain (a) programme(s) for achieving its objectives and targets. It shall include (a) designation of responsibility for achieving objectives and targets at each relevant function and level of the organisation; (b) the means and timeframe by which they are to be achieved. If a project relates to new developments and new or modified activities, products or services, programme(s) shall be amended where relevant to ensure that environmental management applies to such projects. What do you have to do? Objectives, targets, incorporating significant aspects and impacts. How are going to achieve this? Operational control procedures, training, awareness, communications, feedback, auditing, EPE, reviews. Who needs to be responsible? Who is going to be involved? What skills/training will be needed? What resources will be required? Within what timescales? - use of Milestones The plan must be kept up to date - reflecting any changes in the organisation. The EMP(s) can very much build on the plans developed at the start of level one from the baseline assessment if these address O&Ts developed. But include more detail and formalise responsibilities.

Building the EMS Aspects & Impacts Legislation POLICY Objectives
Indicators Targets Environmental Management Programme Slide aimed at helping delegates position where EMPs fit in the context of the EMS. Indicators (click) - we have looked a t developing indicators which support targets and help us track progress. We have identified that we need to determine actions [click] which will help us achieve targets, and these are formalised into EMPs [click]. Actions

Environmental Management Programme Template
Objective Env improvement or control Objective Reference No. Target What by when Link to Policy or Significant aspects Supporting Indicator(s) What Broad Outline of Programme Where and to Who will the programme apply

Relevant Documentation Additional Resources Required
How Required Actions to meet above Objective and Target Who Responsible Person(s) When Target Date Relevant Documentation Additional Resources Required

EMS Structure Mapping your EMS

EMS Structure An EMS comprises a large number of components and documents To the untrained eye the EMS can appear to be a collection of components and documents that have no obvious links or structure. There are many components of an EMS which are common to all management systems

Management System Overlaps
Policy Planning Documentation Training & Communications Auditing Records Checking & corrective action Management review Continual Improvement Health & Safety Quality Environment

EMS Structure The EMS cascades down from the POLICY, ASPECTS and IMPACTS, and LEGISLATION Your POLICY covers the most significant ASPECTS and IMPACTS OBJECTIVES and TARGETS support the commitments of the POLICY. INDICATORS track progress against TARGETS ACTIONS enable the organisation to meet their TARGETS. ACTIONS might require PROCEDURES to help control them. The EMP outlines activities for the operation of the EMS, and RESPONSIBLITIES for carrying these out. The EMP highlights resource requirements.

EMS Structure Your POLICY covers the most significant ASPECTS and IMPACTS OBJECTIVES and TARGETS support the commitments of the POLICY. INDICATORS track progress against TARGETS ACTIONS enable the organisation to meet their TARGETS. ACTIONS might require PROCEDURES to help control them. The EMP outlines activities for the operation of the EMS and RESPONSIBLITIES for carrying these out. The EMP highlights resource requirements.

A Typical EMS Structure
Aspects & Impacts Legislation POLICY Objectives Indicators Targets Environmental Management Programme Procedures Where controls are needed USE THIS DIAGRAM TO MAKE THE LINK BETWEEN ELEMENTS OF LEVELS This will assist in exercise 1. Actions

Mapping your EMS Why is mapping important? Mapping your EMS allows:
Links and overlaps between the various components and documents that form your EMS to be identified. Links and overlaps between your EMS and other management systems to be identified components and documents of other management systems to be identified that can be used in the EMS To employees who are not familiar with management systems, an EMS may appear to be a collection of documents with no obvious links or purpose. If this is the case, when the Management Representative takes a holiday or even leaves the company, the EMS is likely to fall apart

Mapping your EMS Why is mapping important? (cont)
Mapping your EMS allows: Gaps in the EMS to be identified, for example: What has yet to be developed; Any missing components and documents (by comparison with the requirements) Mapping your EMS therefore reduces the amount of work that has to be done and prevents duplication of documents e.g. procedures

Mapping your EMS How do I map my EMS?
Identify the specific components and documents that are key to your EMS Work down the hierarchy. Start by identifying aspects and impacts, move on to legislation, policy commitments, objectives, targets, procedures etc Identify any links and areas of potential duplication between the components and documents you have identified Identify key components and documents of other management systems Identify any areas of overlap and duplication

Exercise 1 Mapping Your EMS
Start with the EMS Map provided as part of the course Exercise 1: Mapping your EMS: Delegates will be required to map out on the Flip Chart prepared for introductions session the key elements of their EMS as developed to date and how they relate to one another. They can also incorporate any elements that they know will need developing in future. The delegates can use more than one Flip Chart sheet if they feel this is necessary but it should be kept within reason. Post it notes (or coloured cards) will be provided for delegates to mark up each element - suggest that these are used as it will allow for initial brain storming ideas to be re-arranged by the delegates for presenting back. Once the key elements have been mapped, get delegates to identify relationships with other management systems in their organisation. Delegates have 20 minutes to prepare the map - feedback will be informal and facilitated by the presenter (15 mins) NOTE: STRONG FACILITATION MIGHT BE NEEDED

Ownership Structure – two tiered Responsibility Steering Committee
Action Team Responsibility Committee Environmental Manager Team Roles Others as delegated

ISO14001 Requirements Defined Documented Resources provided
Structure & Responsibilities Defined Documented Resources provided Management Rep Management Rep Responsibilities EMS implementation and maintenance Reporting ISO requirements: Structure & responsibilities Roles, responsibilities and authorities shall be defined, documented and communicated in order to facilitate effective environmental management. Management shall provide resources essential to the implementation and control of the EMS. Resources include human resources and specialised skills, technology and financial resources. The organisation’s top management shall appoint a specific management representative(s) who, irrespective of other responsibilities, shall have defined roles, responsibilities and authority for: Ensuring that the EMS requirements are established, implemented and maintained in accordance with the international standard. Reporting on the performance of the EMS to top management for review and as a basis for improvement of the EMS. The requirements need to be accommodated. The first requirement is wide reaching and this is covered in the next slides.

Defining Roles, Responsibilities & Authorities
What needs to be done ? Who will be responsible for doing it ? Is this a new role ? What authorities do individuals have? ISO14001 requires you to define, document, and communicate RRAs First ask what needs to be done under the EMS – e.g. reviewing legislation, updating the register, planning and providing training, implementing procedures, etc. Some of these tasks will be specifically required by the standard while others will be specific to your organisation’s EMS, or implied. Once you identified what needs doing, identify who will be ultimately responsible for ensuring this is carried out – this need not be the person who eventually carries out the task but needs to be the person who has ultimate say. For e.g. implementing procedures will be carried out by operatives, but the ultimate responsibility lies with the Operations Manager. In this case it would be right to document both levels of responsibility albeit that the Ops mgr hold overall responsibility. It is possible that this process creates a requirement for a new role in the organisation – e.g. Management Rep – but more often existing roles adopt new tasks. Defining authorities describes how far each individual is expected to take responsibilities –e.g. an operator might only be expected to report a fault, whereas the manager would be required to arrange for rectification.

Roles, Responsibilities & Authorities
Ways of Documenting Procedures Schedules Responsibilities Document Organisation Chart Communication To those affected Skills/Knowledge building There are many different approaches to documenting RRAs. What needs to be done is often documented in procedures – responsibilities and authorities can be stated in these procedures. This links the procedure directly with responsibilities and can be easier to put into context. Procedures might be supported by schedules or plans identifying responsibilities. In some cases schedules and plans can be procedures themselves – e.g. review of legal register, scheduled every 6 months on a wall planner (competence of the management rep could preclude the need for detailed description of how to review legal register) Another common approach is to establish a management responsibilities document. This can be organised by role/level of the structure and defines responsibilities across the whole EMS for each. This approach, whilst not so obvious when reading procedures, but can reduce admin work when changes need to be made (to RRAs and structure). In addition it also provides a good reference document for inducting new starters, conducting TNA, or to help define job descriptions in more detail. Organisation charts (organogram) – this is recommended in order to show the ‘management’ structure (need not be restricted to management posts), roles, and to an extent, authorities. It can also be extended to detail authorities. None of these approached is mutually exclusive, and indeed a combination of some/all would be useful – NOTE: Cross referencing can be helpful but care needs to be taken when updating. Documenting RRAs and the structure can help in communicating this information, not only to those directly involved/named, but also to those who might have an indirect involvement with a task or process. Ensure that individuals or groups assigned RRA’s are suitably skilled and knowledgeable to discharge their responsibilities.

Communications What Constitutes Communication ?
Why Define Procedures for Communications in the EMS? Do you need Procedures for all Communications ? Where would you Define Procedures for Communication in the EMS ? Reveal each question and open them up for the delegates to respond. 1) Look for various methods of communication - e.g. newsletters, briefings, notices, letters, one to one sessions, , fax, intranet. Make the difference between internal and external communication. Identify that communications can go up and down through an organisation’s structure. 2) Look for reasons why you should have procedures for communications - NOTE that the standard does not insist on documented procedures. E.g. consistency of approach, style, content, and timing - particularly important if reporting performance information to report information in a timely manner and in a consistent format. Communication is often overlooked but is key to success of an EMS. 3) Not all communication needs to be proceduralised as long as sufficient and important communications are clearly identified. You might write in a catch all clause for ad hoc communications. 4) As with responsibilities, communications can be identified in: Procedures - Schedules - Responsibilities Document - Organisation Chart - or a separate communications document which lists all the formal communications under the EMS.

ISO14001 Requirements Communications Procedures for: Internal
Receiving Communications Consideration of External ISO14001 Text: With regard to its environmental aspects and EMS, the organisation shall establish and maintain procedures for: a) Internal communications between the various levels and functions of the organisation (think about regular planned comms and ad hoc comms. B) receiving, documenting and responding to relevant communication from external interested parties - think about systems for referring external communications to the relevant people in the organisation so that an appropriate response can be actioned - also track these communications through your system. MPIs might be developed around this e.g. number of comms, average response time. The organisation shall consider processes for external communication on it’s significant environmental aspects and record it’s decision. NOTE: If the org’n decides not to communicate externally on it’s sig A&Is then it only needs to record this decision - a good place for this is the management review meeting, this way it can be reviewed periodically, bearing in mind views might change on this. EMAS requires organisations to produce an environmental statement which includes verified performance data relating to significant aspects, for public access

Training What is training ? What sort of activities do you use ?
Does training ensure competence ? Do you have to have received training to be competent ? Start session asking people what they think training is: Awareness raising Skills building Knowledge Building Then ask what sort of training approaches do they use. Class based, workplace briefs, written instructions, tests, one to one, news letters, memos, internet/distance learning. Finally pose questions: Does trained = competent? And Can you only become competent if trained? Note that these are important distinctions to make at audit - demonstrating competence can be more important than demonstrating training provision, if possible.

Training, Awareness, & Competence
What types to do: Awareness Raising Activity Specific Issue Related Training Task / Procedure Related Training Level 1 requires awareness raising activity to be planned and initiated. Level 2 requires further awareness training relating to legislation and also some specific procedural training to support compliance controls Also, possible need for training relating to indicator data collection and and analysis. Level 3 awareness raising of policy, aspects, impacts, objectives and targets. Specific training relating to tasks in the EMPs or additional procedures developed. Ask delegates - How formal has your identification of training needs been so far? How well has training and awareness activity been planned and recorded? As highlighted at level one - training and awareness raising is ongoing at every level and through the operation of the EMS

Meeting ISO14001 Training Needs Identification Understanding
Importance of compliance Significant Impacts Roles & Responsibilities Consequences Competence Training Records ISO14001 requirements need to be met. - Training / skills / knowledge: needs identification process is required, while not a requirement to document this, it is usual to have some recording method. Training Needs Assessment (TNA) is common term used for this. - Understanding, at all levels, of the importance of compliance with procedures, policy and other requirement s of the EMS - Understanding of significant aspects and impacts of their work activities and how they can influence these - Understanding of their roles and responsibilities - this was looked at before lunch - important to communicate RRAs but may also need some training / awareness raising. - Understanding consequences of not adhering to EMS. - Competence might need to be demonstrated in areas where activities can lead to significant impacts. Competence can be demonstrated through appropriate education, training, or experience. Ongoing assessments might be required to demonstrate competence in critical areas. - Training records are required to demonstrate training activities conducted. Training registers, and information on individuals files are usually recommended. Also any assessment or review information, feedback forms, trainer comments, TNA results, training plans will be useful supporting documentation.

Training Needs Identification
Identify tasks, roles, or responsibilities Identify specific skills or knowledge requirements Identify individuals or groups Assess what skills or knowledge exists Determine the ‘gaps’ Decide on approach to fill ‘gap’ Plan training activity Assessing training needs: Follow sequence as per slide. This TNA process will show that you are proactively identifying training needs in relation to specific tasks, roles, or responsibilities. Personal reviews can greatly enhance the TNA process, by involving each individual in assessing skills gaps - however this can be very time consuming (note Investors in people requires this review approach and it has shown to be of great value) You might have to prioritise training depending on how much needs to be carried out. In this case focus firstly on the areas which can have the greatest environmental impacts - which should correspond to your most significant aspects/impacts. In addition to a formal training needs assessment, you can also identify training needs through corrective action procedures, incident investigation, communications/complaints from interested parties. The training plan should be flexible enough to accommodate requirements identified through such routes.

Some Key Areas of Training
Induction General Awareness Specific Skill Theory Practical Refresher Assessments Training will be required at different stages of an employee / sub contractors term of employment. In addition the level of detail required will vary according to the tasks and circumstances of their work. Training is very rarely a one off task - and while repeating the same training over and over is likely to have limited impact, you should search for different methods of getting the same basic information across effectively. Induction training / awareness raising is vital for any new or temporary workers. General awareness might well be needed before more involved training takes place, and this indeed might be all that is required for some groups of employees. In many instances specific skill based training will be required. Often the training will most effective if split between theory and practical, but this will depend on the complexity of the knowledge being transferred and trainee competence. Refresher training will be important in critical areas where a high degree of competence is required, but don’t ignore refresher training for more straight forward issues. Assessments or tests can help you monitor and demonstrate competence, and/or identify refresher training needs

Training Records Needs Assessment Evidence of Existing Competences
Plans & Schedules Who When Where What Feedback Assessments & Reviews Certificates & Awards Requests The standard requires you to keep training records as evidence that you are undertaking training to provide employees and sub contractors with the correct level of knowledge and skills. In addition this will help you identify and plan training needs, as well as identifying skills held which have previously not been utilised. All of the above should be held on record. Check other management systems for current practices - especially Quality Systems and Health and Safety. Commonly individual files are kept for each employee - this is good practice - and these should be updated each time that employee undertakes some training activity or if competence issues arise. In addition to the personal file though, it is often useful to hold a training session specific log or file, which holds details about a specific training session. Of course if both are held, then they must correlate. Data base systems can help in the handling and analysis of training information - though you might need to check data protection requirements.

Documentation Good Practice
Design a Documentation System that Works Centralised or Decentralised systems Electronic or Paper systems Write Policies and Procedures that Work Language, Style and Readability Avoid information overload The Document Life Cycle Information and data gathering Documentation generation, review and approval Validation Implementation (including training) Archiving and Destruction

EMS Documents & Records
EMS Documentation Input [Documents] Output [Records] Related [Documents or Records] There can a large amount of documentation related to the EMS implementation and operation. The session before the break will have drawn some of these out. A simple break down of different types of documents is: INPUT: These are documents which are created for the control and operation of the EMS - some key docs in this category would be: Policy, Responsibilities Doc, Programmes (EMPs), Procedures, Schedules, Registers (e.g. Legal) & Lists (e.g. Sig Aspects),Templates & Pro Formas, Reference Docs (e.g. guidance notes), Signage. OUTPUT: These are documents which are generated by the operation of the EMS - sometimes as a defined output, some will be ad hoc in response to situations - some key examples would be: Completed check lists, audit reports, CARs, meeting minutes, news letters, communications, and information reports, training records, legal submissions, data collection records. RELATED: These are docs which are relevant to the EMS but may have more relevance to another management area (e.g. Quality, Contract management). As such the documents will be controlled as part of another system, and it would be overly bureaucratic to control them again. However reference will need to be made to them. Examples might be Calibration certificates, client contractual requirements, waste transfer notes, discharge consents, COSHH records.

Options for Document Management
Input - Documents EMS Manual Multiple Manuals Electronic Media Other Management Systems Index of Documentation Classical approach to managing all the input documents for a management system is to create a manual. This keeps everything together and can assist greatly in document control, and in helping others to understand your EMS. However, if only one manual exists, then it can become very cumbersome when making the EMS operational. Access to different documents will be required by different people, but it is unlikely that everyone will want access to every EMS document. Multiple manuals can assist here, and are generally favoured. They allow for sub division of documents so that manuals issued out are more relevant to the recipients. Excessive sub division, or tailoring of manuals (e.g. thro loose leaf systems) though, can create a lot of administrative work at doc control stage). A common approach is to have different levels of document - e.g. Level 1 = Policy document with structures and responsibilities outlined, Level 2 = Operationally Related documents, Level 3 = Basic work instructions or signs etc. Electronic Media - recently the capability to hold all docs in electronic format, especially on networks or intranets, has opened up new possibilities. These can be very flexible, allowing tailored document access without the headaches of hard copy doc control, linking docs can help cross referencing and usefulness. Also updating is quicker and easier, especially for re-issuing. Some key points though - access for everyone who needs it might be difficult (do people have IT skills), ensure docs are backed up, ensure that changes can only be made by approved personnel. Other Management Systems - You don’t need to have an ‘EMS manual’. It may be that you can integrate environmental documents into existing management system’s document control - e.g Quality, Health and Safety, Company Resource Centres. This can save creating additional control processes and might be accepted more readily. Be sure to clearly identify where EMS docs are held though and how they relate to one and other. Also if current systems are very cumbersome you might want to avoid this. Requires that information is documented (paper or elctronic) which describes the core elements of the EMS and their interaction, and provides direction to related documentation. A manual basically serves this purpose, so where your approach might deviate from the classic single manual, be sure to cover this requirement of the standard in some other way.

Document Control What is Document Control ? Why do you need it ?
Ask delegates what they think doc control is, and why is it necessary. Document control provides a mechanism by which all documents under the EMS have been approved and can be clearly identified, and located. In addition document control enables identification of a document as being the most recent, and provides controls to ensure that documents are only issued to appropriate people. Ultimately document control must allow relevant people access to documents. Without document control people might not have access to all the information, or the most up to date information, they need in order to uphold EMS practices. It also protects against tampering or misuse of documentation.

Document Control – ISO14001 ISO14001 Requirements Procedure(s)
Can be Located Reviewed & Revised Available Removed when Obsolete Clearly Identified Legible & Dated Responsibilities 14001 Requirements: The organisation shall establish and maintain procedures [not necessarily documented] for controlling all documents required by this international standard to ensure that: a) They can be located b) They are periodically reviewed, revised as necessary, and approved for adequacy by authorised personnel c) The current versions of relevant documents are available at all locations where operations essential to the effective functioning of the EMS are performed. d) Obsolete documents are promptly removed from all points of issue and points of use, or otherwise assured against unintended use. e) Any obsolete documents retained for legal and or knowledge preservation purposes are suitably identified. Documentation shall be legible, dated (with dates of any revision) and readily identifiable, maintained in an orderly manner, and retained for a specified period. Procedures and responsibilities shall be established and maintained concerning the creation and modification of the various types of document.

Approaches to Document Control
Check Existing Practices Document Identification and Status Issuing Documents Access to Documents Amending and Withdrawing Documents Authorised Approval Firstly review any existing document control processes / procedures in your organisation. If you ISO9000 you will already have procedures for this - possibly also with H&S or IiP. Document identification - clearly name documents Date the documents with the issue date. Further control info can be used - such as a unique document number (useful for cross referencing, or maintaining in an orderly manner), status or version number, signature of authorised approver (this is not commonly required as the fact the document has all other doc control info suggests that this has been approved - the policy is an exception), unique issue number (to help identify who documents belong to), name of document controller. Issuing documents - Record who documents have been issued to. Use of a register is most common, this will show date issued, by who, to who, and possibly also a unique issue number for that document. If documents are issued to large numbers of people or through general release you can mark them ‘uncontrolled’ to show that they are for information and will not be reissued automatically. Alternatively your procedure might identify that the document is updated and reissued on a specified periodic basis. Access to docs - ensure that all people who need access to docs have this. Note: access does not mean they have their own copy, though this might be the most practical approach - ultimately, issue documents as you feel necessary to help people work to the EMS. Amending - Docs will need amending at some stage, you must review docs periodically. On amending, keep a record of the amendments (e.g. annotated version of old doc) and alter the issue status, and date of issue accordingly. Withdrawing - If docs are replaced by amended versions or they are to be withdrawn completely then you should make sure they are removed from circulation. This might be made a responsibility of document holders - I.e. not all need to come back to the owner. Authorised Approval- to ensure that docs are not amended by anyone, the standard requires you to nominate authorised people who can approve amendments to certain docs. Commonly this will be a limited number of people to help with co-ordination and control, but consider the needs of the organisation (I.e. don’t restrict yourself too much)

Records Management Output - Records Related
Hard Copy or Electronic Media Retention Period Storage Responsibilities Related Clear Referencing Records: A large number of records will be in hard copy format and therefore good filing/storage approaches will be required. It might be possible to transfer documents into electronic format to reduce filing and storage issues, however this can be time consuming if specialist equipment is not available. Also you need to check the legal validity of some documents if they have been scanned. Check data protection requirements if records are to be held electronically. ISO14001 requires that: Documents and records can be located. Procedures exist for the identification, maintenance, and disposition of environmental records Records should be legible, identifiable, and traceable Records should be stored so that they are retrievable, protected against deterioration, damage, or loss. Retention times are established and recorded Records should be retained as appropriate for demonstrating conformance to the standard The above requirements will also apply to any related documents held in other management systems - even if those systems do not subscribe to such standards. If this is the case then you might want to review the situation. Any such documents should be clearly referenced within EMS documentation or records.

Operational Control Procedures
Why have procedures? Where would you consider that you would need to apply procedures? What makes procedures effective and efficient? What should procedures look like? Who needs access to procedures? Why have procedures: To try and ensure consistent way of doing things for all people involved. Clearly communicate how things should be done, supports training, reference document, reminder, to avoid loss of knowledge and expertise from organisation. Where needed: Highly sensitive activities or processes where the penalty of getting it wrong would be high - legal, financial, lost business, damaged reputation, damage to employee moral and relations. Significant Aspects would class as this, Issues that would effect the achievement of Objectives, Targets or undermine Policy commitments. Complex activities, irregular, abnormal, or emergency activities. What makes procedures effective and efficient? Clear, understandable by the user, only deals with essentials (not unnecessary requirements), regularly updated, kept in good condition and accessible to people who need to use them. Integrated into normal work practice. What should procedures look like? Do they need to be documented? - Not always, if sufficient evidence of training and competencies can be displayed showing that people know what to do. Particularly if process is simple and repeated regularly. Documented procedures are advisable for complex and/or irregular, abnormal, or emergency activities. Also will depend on competencies and turnover of staff. Documented - doesn’t just mean plain text, flow charts, pictures or diagrams with bulleted text, proformas and check lists which guide people through a process through completion, signs, notices, floor markings, labels etc can all help, posters. Electronic documents might be good in some situations - internet or intranet access. Document control - advisable to get into the habit as this will be required by ISO issue number, status, date etc. Who needs access? Managers, operators, temporary or seasonal staff, sub contractors, suppliers, customers (possibly as part of tenders e.g. construction), assessors, enforcement agencies, insurers, planning authorities.

ISO 14001 Requirements Operational Control: 4.4.6
Associated with significant aspects and impacts Plan these activities Documented procedures Operational criteria Communicate to suppliers & contractors Emergency: 4.4.7 Identify potential for Response to Preventing & mitigating impacts Review of procedures Testing Operational control The organisation shall identify those operations and activities that are associated with the identified significant environmental aspects in line with its policy, objectives and targets. The organisation shall plan these activities, including maintenance, in order to ensure that they are carried out under specified conditions by (a) establishing and maintaining documented procedures to cover situations where their absence could lead to deviations from the environmental policy and the objectives and targets; (b) stipulating operating criteria in the procedures; (c) establishing and maintaining procedures related to the identifiable significant environmental aspects of goods and services used by the organisation and communicating relevant procedures and requirements to suppliers and contractors. Emergency preparedness and response The organisation shall establish and maintain procedures to identify potential for and respond to accidents and emergency situations, and for preventing and mitigating the environmental impacts that may be associated with them. The organisation shall review and revise, where necessary, its emergency preparedness and response procedures, in particular, after the occurrence of accidents or emergency situations. The organisation shall also periodically test such procedures where practicable.

Developing & Implementing Procedures
How would you go about developing procedures ? Implementing How would you go about implementing procedures ? Ask questions of delegates and flip up responses: Developing procedures: Identify what it is you are trying to control - and what levels (e.g. management, operators, individuals, teams) Identify what it is you are trying to prevent Understand the activity, other influences, and possible variables in circumstances Involve others - especially those from areas where activity is carried out Identify the format that the procedure will be in - A4, laminated card, sign, pocket guide etc. [Does it need to be documented ???? See ISO14001, think about practicalities] Identify the language / imagery required to get the message across Trial / test the procedure Implementing procedures: Brief relevant staff, suppliers, or sub contractors. Identify and provide training as required Identify and provide equipment or resources as required Make procedure accessible, and understandable. Make procedure suitable for operating conditions (e.g. water proof, hard wearing) Check back early on and regularly to see how well it is working (once established this can become part of the audit process [level 5] - keep records of checks for future audit records. Monitor effectiveness through indicators if possible Request feedback, and provide opportunity to feedback. Revise procedures as necessary in light experiences - CONTROL ISSUES ensure that operators are using most up to date versions.

Homework Final Policy, Aspects & Impacts, Legal and Other Register Final Objectives and Targets / Action Plan / Roles and Responsibilities Final Draft – Training / Communication / Record Keeping First Drafts Document Control Procedures Emergency

Next Time Review – Always…. Monitoring and Measuring Non-Conformances
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Accelerated EMS Session 4 – 28 January 2008.

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Accelerated EMS Session 4 – 28 January 2008.

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