Environment Management System in Steel Plant


p style=”text-align: center;”>Environment Management System in Steel Plant

Management is connected with the economy and running of the organization. However, it is not at all limited to that. It can in principle apply to any activity or unit, from the individual to the entire organization, and in fact any process which can be steered in some way.  For running a management system it is necessary to get organized. In economy, the idea of a management system is basic. This can be due to the fact that chaos, the opposite of being organized, can be quite costly. If the organization does not know what its costs are, and when to pay them, then it has its consequences. For the organization and its economy the costs can be large since operations are huge involving high costs. The organization cannot afford to have an improper economical management. Today, the organizational management need to recognize that the same is true for the environment. The organization cannot afford to have a defective environmental management. Resources are too scarce and expensive. Emissions are already, or on their way to be, very tightly controlled by statutory regulations.

Environmental management system (EMS) is a systematic approach for incorporating energy and environmental goals and priorities (such as energy use and regulatory compliance) into the routine operations. While some sort of de-facto system is inherent to the organization which is to meet the requirements of energy and environment as part of its daily operations, it is normally accepted as a valuable step to formalize the approach by documenting it. Not only does documentation of the system ensure consistency over time and across employees, there is a growing body of evidence indicating that there is considerable value in defining a systematic approach to managing energy and environmental goals. EMS is also a systematic approach of meeting the business goal and objectives of the organization. The focus of the EMS is on the quality principles for improving the environment.

Environmental management is different from economic management in the sense that it can have several additional items to keep track of. In fact there can be hundreds of them. The most important ones include resources, such as energy and water, emissions and wastes, and the various pollutants, which can be emitted during the running of the processes of the organization. Management system refers to the organizational structure for managing its processes or activities which transform inputs of the resources into its products and / or services.

The introduction of a management system always includes an important component of education and training. In several cases, all the employees of the organization get basic information and training, and several those who are responsible get very considerable education, which also is regularly updated. The introduction of environmental management systems in fact has the potential to be a main mechanism for environmental education. The understanding received in the workplace leads to the environmental improvement.

The EMS is a structured framework for managing the significant environmental impacts of the organization. The environmental impacts vary between the organizations, but typically include waste, emissions, energy use, transport, and consumption of materials. Climate change factors have become increasingly prominent these days because of the statutory issues such as contaminated land etc. Wider factors can also be included, such as impacts on wildlife (biodiversity) and use of materials (such as embodied water). In implementing the EMS, the organization is to identify the significant effects relevant to its operations. For maximum effectiveness, the EMS is not to be set up as a stand-alone system, but built into the exiting management structure.

Historical aspects

ISO is the International Organization for Standardization. It was established in 1946 in Geneva, Switzerland for the promotion of international trade. This was done by developing and issuing harmonized standards with inputs from various national standards. ISO has developed international voluntary consensus standards for manufacturing, communication, trade, and management systems. The standard for management systems were introduced by ISO in 1987. This was a new type of standard. The previous standards were used for physical objects or processes. The management standards have become a global success. From a slow beginning the introduction of the systems has picked up and became very fast. The ISO 9001 for quality management systems and the ISO 14001 standards for environmental management systems are by far the best known management system standards.

The need for international environmental management standards was assessed by the Strategic Advisory Group on the Environment (SAGE), a committee established by ISO in 1991. SAGE recommended development of a standard and in January 1993. ISO created Technical committee 207 (TC 207) to develop the ISO 14000 series of 20 standards. TC 207 is composed of various subcommittees and working groups. Representatives from the ISO member countries contribute their input to TC 207 through national delegates. TC 207 developed the ISO 14001 standard which specifies requirements for an environmental management system. An organization can actually become registered to the ISO 14001 standard for its EMS. Several guidance documents are also developed and environmental auditing guidelines have been published. Published ISO standards are being reviewed every five years.

The standards are designed to (i) help manufacturing and service organizations of any size, or in any industrial sector, and (ii) develop a uniform set of environmental management elements which help them to achieve their own environmental goals. If an organization adopts the standard, it makes a clear management commitment to an environmental policy, form a plan to implement the policy, identify activities which significantly impact the environment, and train employees in environmental practices. The organization also creates a review system to assure that the programmes are implemented and maintained. In a nutshell, an effective EMS needs (i) identification of clear goals, supported by management, with respect to the environment, (ii) development and implementation of ways to measure and progress toward the goals, and (iii) periodic review and improvement. Fig 1 shows development of approach to the environment management.

Fig 1 Development of approach to the environment management

As seen in the Fig 1, national and international EMS certification schemes emerged in the early 1990s and have since evolved to become standardized and structured so that they are compatible and complementary with other mainstream standards (e.g. ISO 9001 quality management standard). Both the ISO 14001 standard and the European Union ‘Eco-Management and Audit Scheme’ (EMAS) are well known for environmental management.

EMAS is a management tool for organizations to ‘evaluate, report, and improve their environmental performance’. It is a voluntary scheme which aims at promoting on-going improvements in environmental performance of organizations and the provision of environmental information to the public. Private and public organizations operating in the European Union and the European Economic Sphere (such as Iceland, Liechtenstein and Norway) can participate in EMAS.

For getting EMAS certification, an organization has to (i) develop an environmental policy, (ii) make an initial environmental review, (iii) develop an environmental programme, (iv) establish an EMS, (v) carry out an internal environmental audit, (vi) review once more, (vii) develop an environmental statement, and (viii) get validation and register. A qualified third party checks the system and statement to see if EMAS requirements are met. If so, the system and statement are validated and the site can be registered. When it has been registered, the site receives a declaration of participation which can be used to promote its participation in the scheme. EMAS became operative in April 1995. It was restricted to industrial sites only until March 2001, when it became open to all private and public organizations of all sectors. The version of EMAS after the March 2001 revision is called EMAS II. However, current common use of the term EMAS (i.e. without the ‘II’) refers to the revised version.

ISO 14000 series of standards

ISO 14000 series is a series of international standards on environmental management which provide a framework for the development of an environmental management system and the supporting audit programme. The ISO 14001 standard is a specification for an environmental management system under this series, which can be assessed by external bodies. The standard also provides an umbrella for the rest of the ISO 14000 series which covers a wide range of environmental management issues including auditing, labelling, and life-cycle assessment etc. The use of ISO 14001 is voluntary, but is frequently cited as a requirement of commercial tendering processes.

These include (i) ISO 14004 which provides guidance on the development and implementation of the environmental management systems, (ii) ISO 14013/5 which provides audit programme review and assessment material, (iii) ISO 14020+ standards are for labelling issues, (iv) ISO 14030+ standards provide guidance on performance targets and monitoring within an ‘Environmental Management System’, (v) ISO 14040+ standards cover life cycle issues, (vi) ISO 14063 standard is for ‘Environmental Communication’, and (vi) ISO 14064,14065 and 14067 standards are for greenhouse gas emissions measurement, monitoring, reporting, verifying etc. Out of these standards, ISO 14001 is the only ISO standard against which it is currently possible for an organization to be certified by an external certification authority.

ISO 14001 specifies a blueprint for an environmental management system against which an organization can be certified by a third party. Other standards in the series are actually guidelines, many to help achieve certification to ISO 14001, although they can be used as ‘stand-alone standards’. The standards in the ISO 14000 series fall into two major groups namely (i) organization-based standards, and (ii) product-based standards.

The standards linked to the organization evaluation are (i) Environmental Management Systems (ISO 14001 and ISO 14004), (ii) Environmental Performance Evaluation (ISO 14031 and ISO/TR 14032), and (iii) Environmental Auditing (ISO 19011 and ISO 14015). The standards linked to the products, services and processes are (i) Life Cycle Assessment (ISO 14040, ISO 14041, ISO 14042, ISO 14043, ISO/TR 14047, ISO/TS 14048 and ISO/TR 14049), (ii) Environmental Labelling (ISO 14020, ISO 14021, ISO 14024 and ISO/TR 14025), and (iii) Environmental Aspects in Product Standards (ISO 14062).

The organization based standards provide comprehensive guidance for establishing, maintaining, and evaluating an EMS. They are also concerned with other organization wide environmental systems and functions. The product-based standards are concerned with determining the environmental impacts of products and services over their life cycles, and with environmental labels and declarations. These standards help the organization gather information needed to support its planning and decisions, and to communicate specific environmental information to consumers and other interested parties.

It is important to note that ISO 14001 is an environmental management standard and not an environmental performance standard. The standard is general and no precise requirements concerning environmental objectives are set. This means that improved environmental performance is not guaranteed. The ISO 14001 standard is voluntary and is meant to be applicable anywhere in the world. Though ISO 14001 is not regulated by statutory regulation, there are strict rules on legal compliance. Improving efficiency of resource consumption and control of environmental impacts are about equally important issues in this standard.

Environment management system

EMS is a set of processes and practices which enables the organization to manage the impacts of its organizational activities on the environment and also to increase its operating efficiency. It is a framework which helps the organization to achieve its environmental goals through consistent control of its operations. The framework includes environmental programmes of the organization in a comprehensive, systematic, planned, and documented manner and includes the organizational structure, planning, and resources for developing, implementing, and maintaining organizational policy for the protection of the environment. It provides a structured approach to planning and implementation of the environment protection measures. However the EMS itself does not dictate a level of environmental performance which is required to be achieved since EMS of every organization is tailored to meet the business objectives and goals of the organization.

EMS encourages the organization to continuously improve its environmental performance. It is a continuous cycle of planning, implementing, reviewing, and improving the processes and actions which the organization undertakes to meet its environmental targets and requirements. The definition of an EMS used by ISO 14001 is ‘the part of the overall management system which includes organizational structures, planning activities, responsibilities, practices, procedures, processes and resources for developing, implementing achieving, reviewing and maintaining the environmental policy’. The EMS thus manages the environmental impacts of the organization. The expected outcome is continuous improvement in the environmental management.

The elements of ISO 14001 standard can be divided into five major sections which forms a cycle and results into continual improvement. Fig 2 shows the continual improvement in environmental management by implementing EMS in the organization.

Fig 2 Continual improvement in environmental management

The EMS standard needs the organization to (i) develop an environmental policy with a commitment to regulatory compliance, (ii) have a procedure for identifying and having access to environmental statutory regulations, (iii) set objectives and targets which are in line with its environmental policy, (iv) establish operational control procedures, (v) establish procedures for emergency preparedness and response, and (vi) establish a procedure for periodically evaluating compliance.

The basic features of the EMS are (i) the organization commits initially to an environmental policy, (ii) it includes review of the present status and future environmental goals of the organization, (iii) it carries out the analysis of the environmental impacts and the legal requirements, (iv) by keeping environmental policy as the basis, the organization sets the environmental objectives and targets for reducing environmental impacts and for complying with the statutory regulation requirements, (v) the organization establishes plans for improving the environment performance and also for meeting the objectives and targets of the organization, (vi) the organization measures, monitors, and evaluates the progress for achievement of the objectives, (vii) the organization ensures environmental awareness and competence of the employees of the organization, (viii) it takes corrective actions if the objectives and targets are not being met, and (ix) the organizational management has regular review of the progress of the EMS and to make improvements on continuous basis.

The ISO 14001 EMS standard has seventeen elements. These seventeen elements are shown in Fig 3 and described below.

Fig 3 Elements of environment management system 

Environmental policy – The environment policy is to be simple and understandable. It is the declaration of the commitment to the environment by the organization. It serves as the foundation for the organizational EMS and provides a unifying vision of the environmental concerns by the entire organization. It serves as the framework for setting environmental objectives and targets and for planning and action. It drives the commitment of the organization to maintain and potentially improve its environmental performance. The environmental policy is to be supported by the senior management and understood by all the employees. By documenting and publicizing the policy, the organization demonstrates a commitment to the management of environmental issues from the highest management levels.

The environmental policy can be a stand-alone document or it can be integrated with the quality, occupational health and safety, or other organizational policies. The policy is required to contain three key commitments known as the pillars of environmental policy (Fig 4) namely (i) continual improvement, (ii) pollution prevention, and (iii) compliance with the relevant statutory regulations.

Fig 4 Pillars of environmental policy and determination of objectives and targets

Environmental aspects – Environmental aspects are the organizational activities which have the potential to interact with the environment in some way and potentially posing a risk if they are not managed appropriately. The environmental aspect is the element of the organizational activities, products, or services which can interact with the environment. The environmental Impact is any change to the environment, whether adverse or beneficial, wholly or partially resulting from the organizational activities, products, or services. To plan for and control its significant environmental impacts, the organization is to know first what these impacts are. But knowing what the impacts are is only part of the challenge’ The organization is also required to know from where these impacts have come.

The identification and management of environmental aspects can (i) have positive impacts on the bottom line, and (ii) provide significant environmental improvements. The EMS is required to include a procedure to identify the environmental aspects which the organization (i) can control, and (ii) over which it can have an influence. The relationship between aspects and impacts is one of cause and effect. The term ‘aspects’ is neutral, hence it is to be kept in mind that the environmental aspects can be either positive (such as making a product out of recycled materials) or negative (such as discharge of toxic materials to a stream). The organization is not expected to manage issues outside its sphere of influence.

Once the organization has identified the environmental aspects of its products, activities, and services, it is required to determine which aspects can have significant impacts on the environment. These environmental aspects are to be considered when the organization sets its environmental objectives and define its operational controls

Statutory and other requirements – The statutory and other requirements are those requirements which the organization is expected to comply with on a continual basis. Besides statutory requirements, there can be the expectations of the local community. To be in compliance with the statutory regulations which apply to the organization, it is necessary first to know what these regulations are and how they affect the organizational operations. The compliance with the statutory regulations is also one of the ‘three pillars’ upon which the environmental policy is to be based. Costs of non-compliance (in terms of monetary value, public image, and possible damage to the environment) can be very high.

Statutory regulations requirements include government (central, state, and local) requirements, and licence requirements. Other requirements can include (for example), (i) organizational specific standards and codes, (ii) standards in locations where the products are marketed, and (iii) other norms related to the industry. The key steps are (i) identify, (ii) analysis of impacts, (iii) communication, and (iv) act.

An effective EMS is to include a process for (i) identifying applicable statutory and other requirements, and (ii) ensuring that these requirements are factored into the efforts of the organization. In case of changes in the statutory requirements, the organization is required to modify the environmental objectives or other elements of the EMS. By anticipating new requirements and making changes to the operations, one can avoid some future compliance obligations and their associated costs.

The process of identifying applicable regulations, interpreting them, and determining their impacts on the operations of the organization can be a time-consuming task. Fortunately, there are several ways in which the organization can get information about applicable statutory regulations. These include (i) commercial services (offered on-line, on computer disk, and on paper), (ii) regulatory agencies central, state, or local), (iii) trade groups / associations, (iv) public libraries, (v) seminars and courses, (vi) newsletters / magazines, (vii) consultants and lawyers, (viii) the Internet, and (ix) customers, vendors and other organizations.

Once the applicable statutory and other requirements have been identified and analyzed for their impacts, the organization is required to communicate these requirements (and plans for complying with them) to the appropriate people within the organization. Communicating the ‘other requirements’ which apply to the organization (as well as their impacts) is an important step which is frequently being overlooked.

Objectives and targets – Objectives and targets form the goals of the organizational EMS. Drawing on the information gained in the ‘aspects’ study, the organization is to develop goals for improving its performance in regard to specific activities. Environmental objective consists of overall environmental goal, arising from the environmental policy, which the organization sets itself to achieve, and which is quantified where practicable. Environmental target consists of detailed performance requirement, quantified where practicable, applicable to the organization or its parts, which arises from the environmental objectives and which needs to be set and met in order to achieve those objectives.

Objectives and targets help the organization to translate purpose into action. They are to be factored into the organizational strategic plan and can facilitate the integration of the environmental management with other management systems of the organization. The determined objectives and targets are to be appropriate for the organization. The goals can be organization-wide or applied to individual units or activities. In setting objectives, the environmental policy, including its three ‘pillars’ is to be kept in mind. Other things to be considered are (i) significant environmental aspects, (ii) applicable statutory and other requirements, (iii) the views of interested parties,(iv)  technological options available, and (v) operational, financial, and other business requirements. Fig 4 shows determination of the objectives and targets.

Factors to consider in setting objectives and targets are (i) ability to control, (ii) ability to track / measure, (iii) cost to track / measure, (iv) progress reporting, and (v) links to policy commitments. There are no ‘standard’ environmental objectives which fit all the organizations. The objectives and targets are to reflect what the organization does and what it wants to achieve.

For the setting of objective and targets the guidelines are (i) objectives and targets are to be set by the people in the functional area involved and who are best positioned to establish, plan for, and achieve the goals, (ii) involving of people in the area helps in building of commitment, (iii) objectives are to be consistent with the overall business mission and plan and the key commitments established in the policy (pollution prevention, continual improvement, and compliance), (iv) the objectives are to be flexible and are to define a desired result with the people responsible to determine how to achieve the result, (v) the objectives are to be simple initially, and after gaining some early successes, they are to be build further, (vi) The objectives and targets (as well as the progress in achieving them) are to be communicated regularly across the organization, (vii)  for obtaining the views of interested parties, holding of an open house or establishing a focus group with people in the community is to be considered, (vii) the objectives and targets are to be realistic, (ix) the measuring of the progress towards achieving the objectives is to be determined, and (x) It is to be kept in mind that the suppliers (service or materials) can help in meeting of the objectives and targets (e.g. by providing more environmentally friendly products).

Environmental management programme – The programme defines the methods which the organization uses to achieve its objectives and targets. The environmental management programme is to be linked directly to the objectives and targets (Fig 4), that is, the programme is to describe how the organization translates its goals into concrete actions so that the environmental objectives and targets are achieved. For ensuring its effectiveness, the environmental management programme is to (i) designate responsibilities for achieving goals, and (ii) define the means and time frame for achieving the goals.

It is to be kept in mind that the programme is to be a dynamic one. The modifying of the programme is to be considered when (i) objectives and targets are revised or added, (ii) progress in achieving the objectives and targets is made (or not made), or (iii) products, processes, or facilities change or other factors arise. The action plan need not be compiled into a single document. A ‘road map’ to several plans is an acceptable alternative, as long as the key responsibilities, tactical steps, and schedules are adequately defined in these other documents.

It is further to be kept in mind that the programme is not to be developed in a vacuum. It is to be coordinated or integrated with other business plans, strategies, and budgets. For example, if changes to a manufacturing process are planned, then it makes sense to look at the possible environmental issues associated with this process change at the same time. The guidelines for the environmental management programme are to (i) involve the employees early in establishing and carrying out the programme, (ii) clearly communicate the expectations and responsibilities laid out in the programme to those who need to know, (iii) build on the plans and programmes for environmental compliance, health and safety, and / or quality management purposes, (iv) re-evaluate the action plan when there are considerable changes to the products, processes, facilities or materials and making this re-evaluation part of the change management process, and (v) keep the programme simple, and to focus on the continual improvement of the programme over time.

Structure and responsibility – It is the establishment of defined roles, responsibilities and authorities for environmental management and provision of appropriate resources. For the EMS to be effective, roles and responsibilities are to must be clearly defined and communicated. Top management plays a key role by providing the resources needed to ensure that the EMS is implemented effectively. Ensuring this capability is one of the most important jobs of top management.

Top management is required to appoint a management representative. This representative (i) ensures that the EMS is established and implemented, (ii) reports on its performance over time, and (iii) works with others to modify the EMS when necessary. The management representative can be the same person who serves as the project in-charge, but this is not mandatory. Management can use information on EMS performance to improve the system over time.

The important aspects regarding structure and responsibility are (i) to build flexibility into the EMS, (ii) recognize that environmental (and other) management needs are going to change over time, and (iii) to be sure to communicate to the people what their roles are (as well as the roles of others). One tool for communicating these responsibilities is a responsibility matrix.

Training, awareness and competence – This element of the EMS defines what training and minimum competence levels are needed to ensure that environmental risks are managed appropriately, who receives the training, and how frequently. Training is needed for building internal capabilities. Training brings in the employees motivation, awareness, commitment, skills / capability, compliance, and performance. The two good reasons for training employees about environmental management and EMS are that (i) every employee can have an impact on the environment, and (ii) any employee can have good ideas about how to improve environmental management efforts. Hence, all the personnel are to receive appropriate training. All training is to be documented properly.

Each person and function within the organization can play a role in environmental management. For this reason, the training programme is to cast a wide net. Everyone in the organization is to be trained on the environmental policy, significant environmental impacts of their work activities, key EMS roles and responsibilities, procedures which apply to their activities, and the importance of conformance with the EMS requirements.

The training is just one element of establishing competence, which is typically based on a combination of education, training, and experience. For certain key roles (including tasks which can cause considerable environmental impacts), it is necessary to establish criteria for the measuring the competence of individuals performing those tasks. Since there is high level of effort involved in a training programme, this is one EMS area where one do not want to start from scratch. Several employees can already be qualified on the basis of their experience and previous training. Since employees can need training on how to run a process safely, on the job training certainly plays a role.

The important aspects regarding training, awareness, and competence are (i) to plan and schedule training opportunities carefully, (ii) new employees can pose a significant training challenge, (iii) in reviewing training needs, not to forget to consider the qualifications and training needs of the environmental manager and the trainers, (iv) to factor the EMS skills requirements into the recruiting, selection, and new employee orientation efforts, (v) establishing competency for various tasks can be a challenge, and (vi) to consider ‘job aids, to supplement training or help establish competence.

Competency criteria for jobs which can cause considerable environmental impacts are to be as objective as possible. One informal method for assessing competency is to question employees in critical functions as to how they perform various aspects of their jobs. The responses are to be used to determine whether they have the requisite skills and understanding to do the job safely. This helps in gauging whether additional training is needed.

Communications – The communications element of the EMS is critical to the success of the EMS. It defines how internal and external communications with respect to environmental issues are handled. This can be quite useful in regards to requests for information from the local community. An effective EMS is to include procedures for (i) communicating internally (between levels and functions), and (ii) soliciting, receiving, documenting and responding to external communications.

Effective environmental management needs effective communications. Communications help in (i) motivating the employees, (ii) explain the environmental policy (both internally and externally) and how it relates to the overall vision / strategy of the organization, (iii) ensure understanding of roles and expectations, (iv) demonstrate management commitment, (v) monitor performance, and (vi) identify potential system improvements.

Effective internal communications need mechanisms for information to flow top-down and bottom-up. Since employees are on the ‘front lines’, they are frequently an excellent source of information, issues and ideas.

Communicating with external parties is also important for effective environmental management. Obtaining the views of neighbours, community groups, and customers, (among others), help to understand how the organization is perceived by others. Information from external sources can be critical in setting environmental and other business goals.

The important aspects of communications are (i) to determine the extent of proactive the external communications strategy is needed since a proactive external communications programme needs more resources, (ii) in communicating with employees, it is helpful to explain not only what they need to do but why they need to do it, (iii) to keep the message simple  with all communications, the messages are to be clear, concise, and accurate, and (iv) managing responses to external inquiries does not have to be a burdensome task.

EMS documentation – The documentation element defines the structure of the EMS itself. For ensuring that the EMS is well understood and operating as designed, the need is to get information to the people doing the work. In addition, there are external parties who can need to understand how the EMS operates, such as customers, certifying agency, regulating agencies, lending institutions, and the public. A ‘road map’ of the EMS explaining how the pieces fit together can be a very useful tool.

EMS documentation can be viewed as a series of explanations or statements of how EMS criteria (such as ISO 14001) apply to the organization. While it is not needed to maintain a single ‘manual’, it is necessary to maintain EMS information in a form which (i) describes the core elements of the EMS (and how these elements relate to each other), and (ii) provides direction to related documentation. The documentation can be maintained either on paper or electronically. There are some advantages to maintain documents electronically, such as easier updating, access control, and ensuring that the most upto-date version of a document is used by all readers.

EMS documents include policy, manual, procedures, work instructions, and forms, drawings etc. EMS documentation is related to (but not the same as) EMS records. EMS documentation describes what the system consists of, while EMS records demonstrate that it is being done what is said to be done.

The guidelines for the EMS documents are (i) to keep the EMS documentation simple and choose a format which works best for the organization, (ii) the documentation does not need to describe every detail of the EMS or how the organization conforms to the ISO 14001 standard (or other EMS criteria), instead, providing references to other documents or procedures is to be considered, (iii) to use the results of the preliminary assessment for preparing the EMS documentation, (iv) the usefulness of the EMS documentation can be improved by including the mission statement, vision, guiding principles, and annual objectives of the organization, (v) the EMS manual can be a useful tool for explaining the EMS to new employees, customers, or others, and (vi) EMS documentation is to be updated as needed, based on any system improvements which has been put in place.

Document control – This element focuses on the maintenance and control of EMS documents required to maintain the EMS. Documents which are to be controlled are (i) policy, (ii) manual, (iii) procedures, (iv) work instructions, and (v) forms and drawings.

People in the organization probably use various documents (drawings, work instructions and the like) as they perform their duties. To ensure that the personnel are consistently doing the job right, the organization is required to provide them with the right tools. In this case, the tools needed are the correct and up-to-date procedures, drawings and other documents. Without a mechanism to control EMS documents, the organization has no way of knowing (or verifying) that people are working with the right tools.

To ensure that everyone is working with the proper EMS documents, the organization needs to have a procedure which describes how documents are controlled. Implementation of this procedure is to ensure that (i) EMS documents can be located, (ii) the documents are periodically reviewed, (iii) current versions are available where needed, and (iv) obsolete documents are removed. The document control procedure is to designate responsibility and authority for preparing documents, making changes to them and keeping them up-to-date. In other words, it is needed to make it clear who can actually change documents and what the change process is.

The important aspects of document control are (i) do not make the procedure more complicated than it needs to be, (ii) limiting the distribution makes the job easier, (iii) determine how many copies are really needed and where they are to be located for ease of access, (iv) if the people who need access to documents are connected to a local area network, then a paperless system can be used, (v) prepare a document control index which shows all of the EMS documents and the history of their revision, and (vi) as the procedures or other documents are revised, to highlight the changes.

Operational control – Certain operations and activities are required to be controlled. The operational control element focuses on the level of operation control which is applied to the environmental risks within the organization. Operational control is necessary to ensure that the environmental policy is followed and that the objectives are achieved. Where an operation or activity is complex and / or the potential environmental impacts are significant, these controls are to take the form of documented procedures. Procedures can help the organization to ensure regulatory compliance and consistent environmental performance. Procedures can also play a key role in employee training.

Documented procedures are to cover those situations where the absence of procedures can lead to deviations from the environmental policy or the objectives and targets. Determination of which operations are to be covered by documented procedures and how those operations are to be controlled is a critical aspect of developing an effective EMS.

In deciding which activities need to be controlled, the organization is to look beyond routine production on the shop floor. Activities such as maintenance, management of on-site contractors, and relationships with suppliers or vendors can affect the organizational environmental performance considerably.

The rule of thumb is that the more highly skilled and trained the employees are, the procedures are to be less critical. The more complex the work or the greater the potential impact on the environment, the more important these procedures are to be. Once the operations have been identified which need control, then it is to be considered what kinds of maintenance and calibration are appropriate. However, the need for maintenance on equipment which can have considerable environmental impacts is obvious, and the need to plan and control such maintenance is not to be overlooked. This does not mean that an elaborate preventive or predictive maintenance programme is needed in all cases. The existing maintenance programme and its effectiveness are to be assessed before making considerable changes.

The important aspect of the operational control is to look at procedures which are already in place to comply with environmental and health and safety regulations. Some of these can be adequate to control significant impacts (or can be modified to do so). A chart is to be developed to keep track of what is needed.

Emergency preparedness and response – This EMS element outlines the procedures by which the organization responds to the environmental emergencies, and the maintenance of a minimum level of preparedness. Despite best efforts by the organization, there is the possibility of accidents and the existence of other emergency situations. Effective planning and preparation can reduce injuries, protect employees and neighbours, reduce asset losses and minimize production downtime.

An effective emergency preparedness and response programme is to include provisions for (i) assessing the potential for accidents and emergencies, (ii) preventing incidents and their associated environmental impacts, (iii) plans / procedures for responding to the incidents, (iv) periodic testing of emergency plans / procedures, and (v) mitigating impacts associated with these incidents. Consistent with the organizational focus on continual improvement, it is also a good idea to review emergency response performance after an incident has occurred. This review can help determine if more training is needed or if emergency plans / procedures are to be revised.

Emergency preparedness means that everyone (including new employees) knows what to do in an emergency. It means that the contractors or site visitors know what to do in an emergency situation. Communications with local officials (fire department, hospital, etc.) are important about potential emergencies at the work site and how they can support the organizational response efforts.

Mock drills can be an excellent way to reinforce training and get feedback on the effectiveness of the emergency plans / procedures. Copies of the plan (or at least critical contact names and phone numbers) are to be posted around the site and especially in areas where high hazards exist. The phone numbers for the on-site emergency coordinator, local fire department, local police, hospital, rescue squad, and others as appropriate are to be included.

Monitoring and Measurement –Monitoring involves measurement. Only those parameters can be monitored which can be measured. The element of monitoring and measurement describes how the organization monitors its environmental performance, the procedures used to measure the appropriate data sources, and the frequency of the measurement. Monitoring and measuring can be resource-intensive.

Monitoring and measurement enables the organization to (i) gauge the environmental performance and analyze root causes of the problem, (iii) identify areas where corrective action is needed, and (iv) improve performance / increase efficiency. In short, monitoring helps the organization to manage its operations better. Pollution prevention and other strategic business opportunities are identified more readily when current and reliable data is available.

The organization is required to develop procedures for (i) monitoring of key characteristics of its operations and activities which can have considerable environmental impacts, (ii) tracking the performance (including how well it meets its objectives and targets), (iii) calibrating and maintaining measurement equipment, (iv) through internal audits, periodically evaluate the compliance with applicable statutory regulations.

The key aspects of monitoring are (i) monitoring of key process characteristics, (ii) most effective environmental measurement systems use a combination of process and outcome measures, (iii) calibration of equipment and process instruments used for measurement, (iv) monitoring of regulatory compliance, (v) evaluation of environmental performance, and (vi) provision of the necessary resources for monitoring and measurement. The performance indicators being measured for the monitoring are to be (i) simple and understandable, (ii) objective, (iii) verifiable, and (iv) relevant to the organization (i.e., its activities, products, and services)

People respond best to information which is meaningful to them. Putting environmental information in a form which is relevant to their function increases the likelihood of their acting on the information. The measurements made are to be communicated to all those people who are concerned with the measurements.

Nonconformities and corrective and preventative action – No EMS is perfect. This EMS element outlines how the organization investigates and corrects non-conformities.  The organization probably finds problems with the system, especially in the beginning (through audits, measurement, or other activities). The EMS is also required to change as the organization changes and grows. When the system deficiencies are encountered, the organization need a process to ensure that (i) problems (including nonconformities) are investigated, (ii) root causes are identified, (iii) corrective actions are identified and implemented, and (iv) corrective actions are tracked and documented.

EMS nonconformities and other system deficiencies are to be analyzed to detect patterns or trends. Identifying these trends allow the organization to anticipate and prevent future problems. The organization is to focus on correcting and preventing problems. Preventing problems is normally less costly than fixing them after they occur (or after they reoccur). This approach is consistent with the continual improvement philosophy.

The amount of planning and documentation needed for the corrective / preventive actions can vary with the severity of the problem (and its potential environmental impacts). In this, bureaucratic approach is to be avoided since simple methods frequently work best. Once a problem is documented, then the organization is to be committed to resolving it. Corrective actions are to be implemented as quickly as possible. It is to be made sure that the corrective / preventive action process specifies responsibilities and schedules. The progress is to be reviewed regularly and follow up is to be done on any deficiencies. It is to make sure that the right data / information are collected to make good decisions. While many corrective actions can be ‘common sense’, it is necessary to look below the surface to determine why a problem has occurred.

Initially, the majority of the EMS problems are identified during the audits. However, over the long run, most problems and good ideas can come from the people in the shop doing the work. This is to be encouraged. Ways are to be found to get employees involved in the system improvement process.

Records – Records are the evidence to show that the EMS is being implemented as designed and is working properly. While records have value internally, over time they are needed to provide evidence of EMS implementation to external parties (such as customers, certifying agency, regulatory agencies, or the public). Records management is frequently being viewed as bureaucratic, but it is hard to imagine a process or system operating consistently without keeping accurate records.

Basic records management is straightforward consisting of (i) types of the records to be kept, (ii) methods of keeping record, and (iii) time period for keeping the records. Further, the organization is also to think about how to dispose the records which are no longer needed.

The important guidelines for the records are (i) to focus on records which add value and to avoid bureaucracy, (ii) the records are to be accurate and complete, (iii) records are to be kept in simple and understandable forms, (iii) process of keeping records is to be integrated with the records management processes for other management systems such as quality and occupational health and safety management systems, and (iv) to establish a records retention policy taking into account regulatory requirements and sticking to it.

In the designing of the records management system, the points to be considered are (i) who needs access, (ii) to what records, and (iii) in what circumstances. If the organization uses computers extensively, then using an electronic EMS records management system is to be considered. Maintaining records electronically can provide an excellent means for rapid retrieval of records as well as controlling access to sensitive records. It is also necessary to decide the records (i) which need additional security, (ii) which need to have restricted access, and (iii) which need to have a back-up copy maintained at another location.

Types of records to be maintained include (i) statutory, regulatory and other standards and code requirements, (ii) results of environmental aspects identification, (iii) reports of progress towards meeting objectives and targets, (iv) permits, licenses and other approvals, (v) training records, (vi) EMS audit and regulatory compliance audit reports, (vii) reports of identified nonconformities, corrective action plans and corrective action tracking data, (viii) hazardous material spill / other incident reports, (ix) communications with customers, suppliers, contractors and other external parties, (ix) results of management reviews, (x) sampling and monitoring data, (xi) maintenance records, and (xii) equipment calibration records.  ISO 14001 requires that organizations have procedures for training records and the results of audits and reviews.

EMS internal audit – EMS audit is a systematic and documented verification process of objectively obtaining and evaluating evidence to determine whether the environmental management system of the organization conforms to the environmental management system audit criteria set by the organization, and for communication of the results of this process to the management. Audits are vital for the continual improvement. Audits are the objective evidence of conformance with the EMS requirements.

Once the organization has established its EMS, verifying the implementation of the system is critical and necessary for the identification and resolving of the EMS deficiencies. EMS audit brings out these deficiencies. Periodic EMS audits establish whether or not all of the requirements of the EMS are being carried out in the specified manner. For the EMS audit programme to be effective, the organization is required to (i) develop audit procedures and protocols, (ii) establish an appropriate audit frequency, (iii) train the auditors, and (iv) maintain audit records. The results of the EMS audits are to be linked to the corrective action system. While the audits can be time-consuming, they are critical to the effectiveness of the EMS. Systematic identification and reporting of EMS deficiencies to management provides a good opportunity to (i) maintain management focus on the environment, (ii) improve the EMS, and (iii) ensure its cost-effectiveness.

For the determination of the audit frequency, some issues which are to be considered are (i) the nature of the operations, (ii) the significant environmental aspects / impacts, (iii) the results of the monitoring programme, and (iv) the results of previous audits. As a rule of thumb, all parts of the EMS are to be audited at least annually. The audit can be done for the entire EMS at one time or it is broken down into discrete elements for more frequent audits. There are advantages if the audit is done more frequently.

The audits are to be performed by the trained EMS auditors. EMS auditors are to be trained in auditing techniques and management system concepts. Familiarity with environmental regulations, facility operations, and environmental science is a big plus, and in some cases can be essential to adequately assess the EMS. Management can use EMS audit results to identify trends or patterns in EMS deficiencies. The organization is also to make sure that any identified system gaps / deficiencies are corrected in a timely fashion and that the corrective actions are documented.

The important aspects of EMS audits are (i) it is to focus on the objective evidence of conformance, (ii) during the course of the audit, auditors are to discuss the identified deficiencies with the people who work in the area, (iii) if possible, to train a number of internal auditors so that the auditors work as a team and allows audits to take place when some auditors have a schedule conflict.

Management review – Management review can be used to demonstrate top management’s ongoing support for the environment. It ensures that the EMS remains viable by closing of the continual improvement loop. The EMS is to be reviewed by management from time to time for EMS to stay ‘healthy’. Management review is the key to continual improvement and to ensure that the EMS continues to meet the needs of the organization over time. Management reviews also offer a great opportunity to keep the EMS efficient and cost-effective. The key issues which a management review deals are that the EMS is working effectively and efficiently and meets the needs of the organization.

The people who are to be involved in the management review process are (i) who have the right information / knowledge, and (ii) who can make decisions. The frequency for management reviews is to be such which works best for the organization. Regardless of the approach the organization takes, it is to be made sure that the issues discussed, decisions taken, and the action items identified during the management reviews are recorded in the minutes. Management review minutes are important documents of the system.

The management review is required to assess the changing circumstances which can influence the suitability, effectiveness or adequacy of the EMS. Changing circumstances can be internal to the organization (i.e., new facilities, new materials, changes in products or services, new customers, etc.) or can be external factors (such as changes in new regulatory requirements, new scientific information, or changes in adjacent land use etc.). The documented action items of the management review are to be followed-up and the progress of these items are to be tracked.  Environmental decision-making is to be integrated into the overall management strategy.

Information sources to be considered in the manage reviews include (i) audit results, (ii) internal suggestions, (iii) external communications, (iv) progress on objectives and targets and other environmental performance measures, (v) reports of emergencies, spills, and other incidents, (vi) new or modified statutory regulatory requirements, and (vii) new scientific/ technical data on materials and processes used by the organization

The ISO 14001 follows the Deming cycle which is a continuous quality improvement model and which consists of a logical sequence of four key stages: Plan, Do, Study, and Act. Fig 5 shows the division of the seventeen elements of the EMS in the four stages of the PDCA cycle.

Fig 5 Environment management system and PDCA cycle

Benefits of an EMS

Adopting of an EMS can help the organization to (i) manage and improve its environmental performance (managing negative impacts) and helping to increase resource efficiency (e.g. cutting waste and energy use), (ii) identify environmental risks and manages these risks accordingly by developing the EMS, (iii) comply with environmental statutory regulations, (iv) achieves environmental commitments and environmental policy requirements (v) generate financial savings through well-managed use of resources and efficient practices, (vi) improve its standing and reputation with the employees, public, regulating agencies, customers, partner organizations, lenders, investors, and wider stakeholders, and (vii) adapt to a changing environment (either its operations or its products / services). Some other benefits of EMS are (i) prevention of pollution, (ii) resource conservation, (iii) new customers / markets, (iv) increased organizational efficiency / reduced production costs, (v) enhances employee morale, (vi) employee awareness of environmental issues and responsibilities, (vii) reduced liabilities, (viii) competitive advantages, (viii) fewer environment related accidents, and (ix) meeting of social responsibility

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