Environmental Systems ISO 14000, R2 AND RIOS AN EXECUTIVE OVERVIEW C P J PERRY JOHNSON C O N S U L T I N G, I N C.

Transcription

1 Environmental Systems ISO 14000, R2 AND RIOS AN EXECUTIVE OVERVIEW C P J PERRY JOHNSON C O N S U L T I N G, I N C

2 ENVIRONMENTAL MANAGEMENT SYSTEMS The Groundwork For Environmental Management ISO 14001:2004 R2-RIOS (With Additional Guidance on REACH and RoHS) An Executive Overview Revised 03/13 PERRY JOHNSON CONSULTING, INC. Detroit 5000 Town Center, Suite 2002, Southfield, MI or (248) Website: Copyright 2013 by PERRY JOHNSON CONSULTING, INC. All rights reserved. No part of this book may be reproduced in any form or by any means without permission, in writing, from Perry Johnson Consulting, Inc.

3 ENVIRONMENTAL MANAGEMENT SYSTEMS The Groundwork For Environmental Management AN EXECUTIVE OVERVIEW CONTENTS FOREWORD...2 MANAGEMENT SYSTEMS...3 THE USERS OF THIS GUIDE...3 MANAGEMENT SYSTEM REGISTRATION...4 Key Steps to Completing Registration...5 What to Look For in a Registrar...6 What to Look For in an Auditor...6 PART I ISO 14001:2004 WHAT IS ISO 14000?...7 The Origin of ISO ISO Series Standards...9 ISO Components...11 Implementing an Environmental Management System...15 Meeting Environmental Auditing Requirements...16 THE BENEFITS OF ISO ISO ENVIRONMENTAL MANAGEMENT SYSTEM REQUIREMENTS...20 PART II RESPONSIBLE RECYCLING (R2)...28 The History of R Integration & Comparison with ISO 9001 and ISO Additional Rules and Requirements...34 The R2 Practices...36 PART III - RIOS...47 RIOS Certification...49 The RIOS Standard...51 PART IV RoHS AND REACH...59 RoHS...59 REACH...62 EMS Executive Overview Page 1 3/13

4 FOREWARD Management System standards define generic and/or industry specific requirements necessary to ensure the consistency of management requirements for various organizations all over the world. The ISO series and other standards covered in this executive overview have positive impacts on companies in industrialized nations spanning our global community. These standards ensure environmental, quality, health and safety management responsibilities are addressed by top management. The people with the greatest influence over company policies and procedures also have the flexibility and freedom to define methods for implementing management system requirements. Once a company decides to control the processes related to the scope of activities performed, it can establish targets and objectives for achieving identified management system goals. Management system standards have made a tremendous impact in the global community, as they outline methods for companies to manage their various activities. While management system requirements are intended to be voluntary, some government agencies may require registration to various standards or other related requirements commensurate with those defined within applicable standards. As a result, organizations that do not implement effective management systems may diminish their ability to compete in various markets, such as the European Union (EU), where registration to some standards is required by governing states or other entities. Marketing advantages, government mandates, benefits derived from strategic planning and the growing interest of other public entities represent a basis for justifying the implementation and maintenance of an effective management system(s). The adoption of management system requirements provides enumerative benefits to various interested parties. Interested parties can be represented by customers, stake holders, employees, suppliers and members of communities affected by the scope of activities performed as well as products and services delivered by organizations. This booklet was created to promote awareness necessary for organizations to provide superior products and services to customers while embracing a philosophy of environmental responsibility and the provision of a safe and healthy work environment for employees. This manual provides an overview of the intent and content of management system and other standards addressed, including detailed descriptions of the standards, related requirements, objectives and the implementation process that assists organizations in accomplishing their goals and objectives. Because management system registration is a lengthy and detailed process, it is strongly suggested that organizations seeking registration retain the services of a reputable consulting firm. PERRY JOHNSON CONSULTING, INC. March 2013 EMS Executive Overview Page 2 3/13

5 MANAGEMENT SYSTEMS This executive overview manual was originally created to provide general information and guidance to accommodate requirements for ISO 14001:2004 Environmental Management Systems. Since the initial release of this manual, industry specific environmental and other management system standards have been released to address a broader range of environmental, occupational health and safety, quality and other requirements applicable to subscribing industries. This version of The Groundwork For Environmental Management Manual has been expanded to include additional industry specific requirements included in the Recycling Industry Operating (RIOS) Standard adopted by the recycling industry (ISRI) and the Responsible Recycling (R2) Standard sponsored by the United States Environmental Protection Agency (EPA). THE USERS OF THIS GUIDE Because management system requirements are adopted to support universal applications, this guide can be used by various organizations, and tailored to meet business or industry specific requirements appropriate for the scope of work performed. The use of this guide and the information contained herein is unlimited. Information contained within this guide is not limited to environmental management, but also places additional emphasis on health, safety, legal compliance and quality management requirements. Environmental Management Systems (EMS) and other standards affect almost everyone, from companies that manufacture products or provide services to individuals who are concerned about the environment. The principles of these standards extend well beyond business and industry, and are applicable to the readers and producers of this guide. Various challenges are associated with an organization s activities, the processes it engages in, and the products and services it produces. Each activity can have an impact on the environment, health and safety and quality in varying degrees. An organization seeking to control environmental aspects and impacts through its EMS must identify them and implement procedures to deal with these situations. Business suppliers should also take note of this guide. Some companies have mandated that their suppliers become registered to applicable management system requirements is addition to complying with other related requirements. The Environmental Protection Agency (EPA) has contributed extensively to the development of ISO 14000, and its representatives have suggested that ISO registration is likely to reduce the need for multiple environmental audits in the future. The Recycling Industry Operating Standard (RIOS) and the Responsible Recycling (R2) Standard have extended requirements EMS Executive Overview Page 3 3/13

6 beyond those of ISO 14001:2004 in order to integrate quality, health and safety and environmental requirements into common standards intended to maximize the benefits for the scrap metal and electronics recycling industries. This manual also provides additional guidance on the Restriction of Hazardous Substance Directive (RoHS) and Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) Standards for organizations that are required to comply with regulatory requirements defined within and complimentary to these standards. MANAGEMENT SYSTEM REGISTRATION Management system registration is a tangible expression of an organization s commitment to satisfying the needs of customers and other interested parties applicable to the management system requirements defined. ISO defines environmental requirements that are suitable for industries of any type and size. RIOS applies to the scrap metal recycling industry while R2 is tailored to meet the needs of organizations involved in processing and recycling used electronics. RoHS and REACH are compliance standards adopted by the European Union (EU) to control and manage chemicals in different states to better manage the environment and ensure the health and safety of persons or communities in which such chemicals are used or transported. The process necessary to achieve registration is described below as applicable to ISO and is outlined briefly for different management system requirements throughout the text of this manual. Management Systems provide formal requirements to help organizations manage environmental aspects and impacts applicable to the scope of activities performed. ISO is understood and accepted globally. There are a variety of reasons for seeking ISO registration. These include customer mandates, a competitive advantage through reduced energy costs and improved efficiency, cutting liability and regulatory compliance costs, and increased community goodwill from preventing pollution and reducing waste. ISO registration is carried out by registrars, accredited organizations that review the facility s environmental policy and other documentation during the Stage 1 (desktop) audit to ensure that they meet the standard, and examine the firm s processes during the Stage 2 (registration) audit to ensure that the EMS described in the documentation is in place and is effective. Once registration is obtained, the registrar conducts regular surveillance audits of the facility to determine if its EMS continues to meet the standard s requirements. As it typically takes 6 to 18 months to complete the ISO registration process, organizations are advised not to put off registration for too long. EMS Executive Overview Page 4 3/13

7 Key Steps to Completing Registration Before an organization can be considered for registration, several preliminary steps must be taken: 1) The first step is to implement an EMS that meets ISO requirements. 2) To qualify for registration, it s not enough to just conform to the standard. An environmental policy must be created which stipulates a facility s environmental commitments, procedures and practices. This document plays a vital role in the registration process. Because the policy is the principal document used during an audit, it must be a true reflection of the facility s EMS. The policy must also address, point by point, all ISO requirements. 3) The facility s EMS must be in operation for a minimum of three to six months so that employees are familiar with it and an evidentiary trail of documents has been created for auditors to review. After successfully completing the preliminary steps, a relationship must be established with a registrar. The registrar s job is to verify whether an organization s EMS has been properly implemented and conforms to ISO and any other applicable requirements. Once the services of an accredited registrar have been obtained, a formal application must be filed. When all of the paperwork has been submitted, the registrar examines the facility s environmental policy and other documentation during the Stage 1 (desktop) audit. After the registrar has verified that the policy and other documentation satisfactorily reflect the organization s EMS and meet all ISO requirements, and any nonconformities have been corrected, the on-site Stage 2 (registration) audit of the organization s facility is scheduled. During the Stage 2 audit, the registrar s auditor interviews employees, reviews records, and performs a detailed inspection of the facility s EMS and procedures. The purpose of the audit is to ensure that the facility s EMS is functioning adequately and conforms to all ISO requirements. Afterward, the registrar reports its findings in an audit report. If any nonconformities were found, the organization (or auditee) must take corrective action to remedy them within a set time frame, determined by the registrar. Once the registrar has closed out all outstanding nonconformities, a registration certificate is issued. The standard validity of a registration certificate is three years, after which a full re-audit is done for renewal. To ensure that organizations are following ISO requirements after registration is obtained, the registrar conducts on-site surveillance audits two times a year. Remember: In order to achieve registration to ISO 14001, the organization must completely embrace the standard, which focuses on performance, documentation and objective evidence. EMS Executive Overview Page 5 3/13

8 What to Look For in a Registrar In selecting a registrar, it is extremely important for every organization to be aware of the relevant qualifications. A registrar must: Be accredited by a national accreditation body, such as the ANSI-ASQ Accreditation Board (ANAB), the Raad voor Accreditatie (RvA) of the Netherlands, the United Kingdom Accreditation Service (UKAS), or the Japan Accreditation Board for Conformity Assessment (JAB) among others. Maintain a listing of its ISO qualified auditors; Have personnel on its executive (registration) committee or governing board with environmental experience and expertise; and, Conform to ISO/IEC 17021:2011, Conformity assessment Requirements for bodies providing audit and certification of management systems. What to Look For in an Auditor Requirements have been established for the auditors working for accredited ISO registrars. Before an auditor can evaluate an organization s facility to verify whether its EMS conforms to ISO requirements, the auditor must satisfy the following conditions: 1) Auditors working for or on behalf of registrars must have satisfactorily completed ISO training courses and demonstrated their knowledge of ISO by passing an exam. A certificate is awarded to those auditors who have successfully completed this training; 2) Auditors must comply with ISO/IEC 17021:2011, Conformity Assessment Requirements for Bodies Providing Audit and Certification of Management Systems; and, 3) They must be recognized and qualified as ISO auditors under the registrar s criteria. Before hiring the services of a registrar, it s a good idea to make sure the registrar and its auditors have met the above qualifications. EMS Executive Overview Page 6 3/13

9 PART 1 ISO 14001:2004 WHAT IS ISO 14000? ISO is a series of generic environmental management systems (EMS) standards created by the International Organization for Standardization (ISO), a federation of 132 national standards bodies based in Geneva, Switzerland. The American National Standards Institute (ANSI) is the member body representing the United States. The goal of these standards is to give top management of any organization a framework for managing its environmental aspects and impacts. An environmental aspect is defined by ISO Section 3.6 as an element of an organization s activities, products or services that can interact with the environment. ISO Section 3.7 defines an environmental impact as any change in the environment, whether adverse or beneficial, wholly or partially resulting from an organization s environmental aspects. The ISO series of standards attempts to harmonize environmental management activities for industries all over the world. The series promotes a common approach to environmental management that can be used by any organization, of any size, anywhere in the world. These standards are divided into two classifications: Organization Evaluation Product and Service Evaluation Organization Evaluation, in turn, consists of three components: Environmental Management Systems (EMS) Environmental Auditing Environmental Performance Evaluations (EPE) Product and Service Evaluation also consists of three components: Environmental Labeling Life-Cycle Assessment (LCA) Environmental Aspects in Product Standards (EAPS) The most important ISO standard, and the key member of the EMS component, is ISO 14001:2004, Environmental Management Systems Requirements with Guidance for Use. This standard sets EMS requirements to which an organization must conform, and is the single standard within the ISO series to which an organization may become registered. EMS Executive Overview Page 7 3/13

10 All other ISO standards are guidance documents and technical reports, assisting an organization in developing its EMS. These standards contain recommendations that organizations may use to clarify or go beyond ISO requirements. Additional requirements for R2/RIOS, RoHS and REACH are specified within applicable sections of this Executive Overview document. The Origin of ISO The international environmental movement that developed in the 1960s spurred environmental legislation around the globe during the 1970s, with the strongest regulations in industrialized nations. Regulatory compliance proved costly for many companies, with environmental improvements sometimes falling short of expectations. Attempts by some industries to police themselves failed to establish a viable and credible worldwide consensus. ISO, which had released the ISO 9000 quality management systems standards in 1987, stepped into the breach to create a voluntary global approach to environmental management. In 1991, ISO established the Strategic Advisory Group on the Environment (SAGE) to research the need for international environmental standardization. In addition to its ISO responsibilities, SAGE was a major contributor to the 1992 United Nations Earth Summit in Rio de Janeiro, Brazil, particularly in adopting a commitment to sustainable development. At the same time, the British Standards Institution (BSI) released BS 7750, Environmental Management Systems, the first EMS standard. BS 7750 stressed overall environmental systems performance, with mandatory audits to confirm and maintain a company s conformity and registration to the standard. The European Union (EU) followed with its Eco-Management Audit Scheme (EMAS), which contained similar requirements. In light of these developments, SAGE recommended developing an international series of EMS standards, and ISO established Technical Committee (TC) 207, Environmental Management, to carry out this work. Both BS 7750 and EMAS were influential in developing the ISO standards. In 1996, the first five ISO standards were released. They were ISO 14001; the guidance document ISO 14004:1996, Environmental Management Systems General Guidelines on Principles, Systems and Supporting Techniques; and three auditing standards: ISO 14010:1996, Guidelines for Environmental Auditing General Principles, ISO 14011:1996, Guidelines for Environmental Auditing Audit Procedures Auditing of Environmental Management Systems, and ISO 14012:1996, Guidelines for Environmental Auditing Qualification Criteria for Environmental Auditors. ISO/TC 207 has continued its work, releasing and revising ISO standards, guidance documents and technical reports, some of which are still in draft status as of this writing. The revised second edition of ISO was released in 2004, (ISO 14001:2004) and clarifies various requirements specified within the first edition. Additional consideration has been given to the requirements of ISO 9001:2000 (now ISO 9001:2008) to ensure consistency between the standards to support a more uniform approach. EMS Executive Overview Page 8 3/13

11 The sub-clause numbers in Clause 4 and in Annex A now correspond to support ease of use. Annex B now identifies broad technical relationships between ISO 14001:2004 and ISO 9001:2000(8). ISO 14001:2004 describes the requirements for an organization's environmental management system that can be used to support certification/registration and/or self-declaration of the organization s environmental management system. ISO was also revised to ISO 14001:2004 and is intended to serve as a non-certifiable guideline intended to provide strategic assistance organizations wishing to establish, implement or improve an existing environmental management system. ISO Series Standards Organization Evaluation Standards ISO 14001:2004 Environmental Management Systems Specification with Guidance for Use ISO 14004:2004 Environmental Management Systems General Guidelines on Principles, Systems and Supporting Techniques ISO 14015:2001 Environmental Management Environmental Assessment of Sites and Organizations (EASO) ISO 14031:1999 Environmental Management Environmental Performance Evaluation Guidelines ISO/TR 14033:2012 Environmental management Quantitative environmental information Guidelines and examples ISO 14050:2009, Environmental Management Vocabulary ISO 19011:2011 Guidelines for Auditing Management Systems ISO/IEC Guide 66:1999 General Requirements for Bodies Operating Assessment and Certification/Registration of Environmental Management Systems (EMS) Product and Service Evaluation Standards ISO 14020:2000 Environmental Labels and Declarations General Principles ISO 14021:1999, Amd 2011, Environmental Labels and Declarations Self-Declared Environmental Claims (Type II Environmental Labeling) ISO 14024:1999 Environmental Labels and Declarations Type I Environmental Labeling Principles and Procedures ISO/TR 14025:2006 Environmental Labels and Declarations Type III Environmental Declarations ISO 14040:2006 Environmental Management Life Cycle Assessment Principles and Framework ISO 14044:2006 Environmental management Life cycle assessment Requirements and guidelines ISO 14045:2012, Environmental management Eco-efficiency assessment of product systems Principles, requirements and guidelines EMS Executive Overview Page 9 3/13

12 ISO/TR 14047:2012 Environmental management Life cycle assessment Illustrative examples on how to apply ISO to impact assessment situations ISO/TS 14048:2002 Environmental Management Life Cycle Assessment Data Documentation Format ISO/TR 14049:2012 Environmental management Life cycle assessment Illustrative examples on how to apply ISO to goal and scope definition and inventory analysis ISO/TR 14062:2002 Environmental Management Integrating Environmental Aspects Into Product Design and Development ISO 14063:2006 Environmental management Environmental communication Guidelines and examples ISO :2006 Greenhouse gases Part 1: Specification with guidance at the organization level for quantification and reporting of greenhouse gas emissions and removals ISO :2006 Greenhouse gases Part 2: Specification with guidance at the project level for quantification, monitoring and reporting of greenhouse gas emission reductions or removal enhancements ISO :2006 Greenhouse gases Part 3: Specification with guidance for the validation and verification of greenhouse gas assertions ISO 14063:2006 Environmental management Environmental communication Guidelines and examples ISO Guide 64:2008 Guide for addressing environmental issues in product standards EMS Executive Overview Page 10 3/13

13 ISO Components The ISO series of standards, organized into two classifications and six components. Organization Evaluation Standards Environmental Management Systems (EMS) Environmental Management Systems (EMS) is the entire environmental program planned by an organization. ISO Section 3.8 defines an EMS as the part of an organization s management system used to develop and implement its environmental policy (3.11) and manage environmental aspects (3.6). The overall intentions of an organization related to its environmental performance must be documented in an environmental policy, along with other necessary documents, such as an environmental manual. These documents must define the EMS in detail and clearly state the organization s environmental objectives and targets. The environmental policy is defined by ISO Section 3.11 as an overall intentions and direction of an organization (3.16) related to its environmental performance (3.10) as formally expressed by top management. ISO Section 3.9 defines an environmental objective as an overall environmental goal, consistent with the environmental policy (3.11), that an organization sets itself to achieve. An environmental target is defined by ISO Section 3.12 as a detailed performance requirement, applicable to the organization or parts thereof, that arises from the environmental objectives and that needs to be set and met in order to achieve those objectives. EMS standards are: ISO 14001:2004, Environmental Management Systems Requirements with Guidance for Use, which specifies EMS requirements that seek confirmation for self-declaration or registration purposes. ISO 14004:2004, Environmental Management Systems General Guidelines on Principles, Systems and Support Techniques, which provides guidance to help an organization establish, implement, maintain and improve an EMS, including guidance that goes beyond ISO requirements. ISO 14050:2009, Environmental Management Vocabulary, which helps an organization understand the terms and definitions used in the ISO series standards. EMS Executive Overview Page 11 3/13

14 Environmental Auditing The ISO series relies heavily on auditing to ensure that ISO requirements are being met. ISO mandates audits, with Element stating, The organization shall establish and maintain (a) program(s) and procedures for periodic environmental management system audits to be carried out. Both internal and external audits are used to ensure conformity to ISO 14001, and can be of great benefit to a facility. Environmental Auditing standards are: ISO 19011:2011, Guidelines for Auditing Management Systems, which provides guidance on auditing principles, audit program management, the conduct of management system audits and auditor competence. More detail on this support document appears in the section on Meeting Environmental Auditing Requirements. ISO 14015:2001, Environmental Management Environmental Assessment of Sites and Organizations (EASO), which helps an organization to identify and assess the environmental aspects and associated business consequences of sites and organizations to support the transfer of properties, responsibilities and obligations from one party to another. ISO/IEC Guide 66:1999, General Requirements for Bodies Operating Assessment and Certification/Registration of Environmental Management Systems (EMS), which sets operational requirements for ISO registrars. Environmental Performance Evaluation (EPE) Once an EMS is implemented, its performance must be evaluated for effectiveness. The Environmental Performance Evaluation (EPE) should be conducted by front-line employees who continually monitor the production process to ensure that environmental requirements are being met. EPE standards are: ISO 14031:1999, Environmental Management Environmental Performance Evaluation Guidelines, which provides guidance on selecting and using indicators to evaluate an organization s environmental performance. ISO/TR 14033:2012, Environmental Management Quantitative Environmental Information - Guidelines and Examples, which provides guidelines on how to acquire quantitative environmental information and data and implement methodology. ISO 14063:2006, Environmental Management Environmental Communications Guidelines and Examples, provides guidance on communication of an organization s environmental aspects and performance. EMS Executive Overview Page 12 3/13

15 Product and Service Evaluation Standards Environmental Labeling Many companies use environmental claims as a marketing tool for their products and services. With ISO registration providing a similar labeling opportunity, these support documents seek to prevent unwarranted claims, ensure that environmental claims are accurate and verifiable, and set standards for the three types of environmental labels. These labeling categories are: Type I Third-party certified labels Type II Self-declared labels Type III Product information claims based on life cycle inventory data Environmental Labeling standards are: ISO 14020:2000, Environmental Labels and Declarations General Principles, which provides general principles for developing ISO guidelines and standards on environmental claims and declarations. ISO 14021:1999, Amd 2011, Environmental Labels and Declarations Self-Declared Environmental Claims (Type II Environmental Labeling), which provides guidance on the terminology, symbols, and testing and verification methodologies an organization should use for self-declaring the environmental aspects of its products and services. ISO 14024:1999, Environmental Labels and Declarations Type I Environmental Labeling Principles and Procedures, which provides the guiding principles and procedures for thirdparty environmental labeling certification programs. ISO/TR 14025:2006, Environmental Labels and Declarations Type III Environmental Declarations, which identifies and describes elements and issues to be considered when making quantified product information declarations based on life cycle inventory data. Life Cycle Assessment (LCA) Several support documents provide life cycle assessment study guidance. These standards describe how to conduct a study of the environmental performance of a company s products, including inventory analysis, impact assessment and interpretation. LCA standards are: ISO 14040:2006, Environmental Management Life Cycle Assessment Principles and Framework, which provides the general principles, framework and methodological requirements for the LCA of products and services. ISO 14044:2006, Environmental Management Life cycle Assessment Requirements and Guidelines, specifies requirements and provides guidelines for LCA. EMS Executive Overview Page 13 3/13

16 ISO 14045:2012, Environmental management Eco-efficiency assessment of product systems Principles, requirements and guidelines. ISO/TR 14047:2012, Environmental Management Life Cycle Assessment Examples of Application of ISO 14044, provides examples that illustrate current practice of life cycle impact assessment according to ISO 14044:2006. ISO/TS 14048:2002, Environmental Management Life Cycle Assessment Data Documentation Format, which provides information regarding the formatting of data to support an LCA. ISO/TR 14049:2012, Environmental Management Life Cycle Assessment Illustrative examples on how to apply ISO to impact assessment situations, which provides examples to illustrate how to apply the guidance in ISO Environmental Aspects in Product Standards (EAPS) Guidelines for environmental aspects in product standards recognize the potential effects of products on the environment, and recommend consideration of environmental aspects in developing future products and product standards. EAPS standards are: ISO/TR 14062:2002, Environmental Management Integrating Environmental Aspects Into Product Design and Development, which provides concepts and current practices for integrating environmental aspects into product design and development. ISO Guide 64:1997, Guide for the Inclusion of Environmental Aspects in Product Standards, which helps product standard writers address environmental aspects. ISO :2006, Greenhouse Gases Part 1: Specification with Guidance at the Organization Level for Quantification and Reporting of Greenhouse Gas Emissions and Removals, provides guidelines principles and requirements at the organization level for quantification and reporting of greenhouse gas (GHG) emissions and removals. ISO :2006, Greenhouse Gases Part 2: Specification with Guidance at the Project Level for Quantification, Monitoring and Reporting of Greenhouse Gas Emission Reductions or Removal Enhancements, provides guidance at the project level for quantification, monitoring and reporting of activities intended to cause greenhouse gas (GHG) emission reductions or removal enhancements. ISO :2006, Greenhouse Gases Part 3: Specification with Guidance for the Validation and Verification of Greenhouse Gas Assertions, provides guidance for those conducting or managing the validation and/or verification of greenhouse gas (GHG) assertions. EMS Executive Overview Page 14 3/13

17 Implementing an Environmental Management System Implementing an EMS affects an entire organization and requires commitment across the board. The implementation process begins with top management identifying the appropriate resources, and then creating a personnel structure to plan and oversee the process. IS places this initial task in the hands of top management to provide direction for the program and convey the importance of the EMS to employees. It also requires top managers to draft policies, allocate resources, establish support systems, mandate training, formulate appraisal systems and provide necessary communication. Executive management must also select the management representative (MR), who is responsible for the EMS throughout implementation, maintains the day-to-day EMS operations, and reports on EMS performance to top management. ISO Element requires top management to appoint a management representative with ensuring that an environmental management system is established, implemented and maintained. The MR must identify available resources and personnel, develop procedures, track costs and benefits, and gather information from each department manager for EMS review and improvement. Every employee must play a role in EMS implementation. Department managers are involved to the degree that their operations produce environmental aspects and impacts. Floor employees are the backbone of the whole system, since they carry out most of the organization s activities that can affect the environment. Environmental training plays a big role in ISO EMS implementation. Element requires all employees whose job duties may significantly affect the environment to be competent on the basis of appropriate education, training and/or experience. To ensure that employees have the resources they need to meet EMS requirements, the organization must identify training needs. Element recommends that the organization inform interested parties, such as subcontractors, regulators and customers, of its significant environmental aspects. Auditors who evaluate an organization s EMS must also be trained, with these requirements set forth in ISO ISO requires documentation, which the MR is responsible for establishing and maintaining. Element 4.2 mandates an environmental policy that provides the framework for setting environmental objectives and targets. Other documents include a description of the scope of the environmental management system, procedures, work instructions and records. While ISO does not define explicit requirements for an Environmental Manual, it is good practice to maintain EMS documentation in some structured format such as a manual. Documents are controlled under procedures required by Element Documentation presents a clear picture of a facility s EMS as it compares to ISO requirements, providing objective evidence of EMS status. It also establishes an archive of EMS information that aids in both operations and audits. EMS Executive Overview Page 15 3/13

18 Meeting Environmental Auditing Requirements ISO requires organizations to continually monitor their performance through a systematic auditing approach that compares a company s environmental achievements to its objectives and targets. Auditing requirements are found in ISO 19011:2011, Guidelines for Auditing Management Systems, which contains definitions of auditing terms, sets forth auditing principles, describes audit program management requirements, provides guidance for conducting management system audits, and presents auditor competence and evaluation requirements. Understanding the Audit Process An audit is a systematic, independent and documented process for obtaining audit evidence and evaluating it objectively to determine the extent to which the audit criteria are fulfilled. During an audit, an auditor measures the adequacy of the EMS, its effectiveness, and its conformity to ISO ISO Element requires periodic audits of an organization s EMS, with the scope, frequency and methodologies of these audits covered by procedures. In registering an organization to ISO 14001, the environmental policy and other documentation are reviewed first during the Stage 1 (desktop) audit. Following this process, the auditor then examines the company s on-site operations during the Stage 2 (registration) audit, to ensure that the EMS requirements are met. Both stages are incorporated into an internal audit. Upon completing the Stage 2 audit, it is the auditor s job to identify areas of operation where the EMS does not meet ISO requirements. The auditor will require the organization to take corrective action to close out any nonconformities before a registration certificate can be issued. In an internal audit, implementation of these actions must be verified during either a follow-up audit or the next surveillance audit. If corrective actions are required for the organization s environmental policy, procedures or other EMS components as a result of nonconformities, the ISO management representative, together with the department manager of the affected area, should guide these activities. The management representative is also responsible for updating documentation to reflect changes that result from corrective and preventive actions. Documentation Review A thorough review of an organization s EMS documentation is conducted during the Stage 1 audits. Documentation includes the environmental policy, procedures, work instructions and records, which are reviewed for conformity to ISO requirements, along with other applicable requirements, such as regulatory mandates. Documentation is an invaluable reference source because it serves as the foundation of the EMS and provides objective evidence on its status. EMS Executive Overview Page 16 3/13

19 In most organizations, documentation is structured in the following four-tier hierarchy: Tier 1 Environmental Policy with optional EMS Manual Tier 2 Procedures Tier 3 Work Instructions Tier 4 Records The environmental policy defines the criteria against which the EMS measured. If this review shows that the organization s documentation fails to meet ISO requirements, the Stage 2 audit cannot be scheduled until the situation is corrected. Performing Internal Audits An internal audit is performed by an organization s personnel, and may be carried out by the management representative or any employee who has demonstrated competence based on education, training, skills and experience as referenced in ISO Section The goal of an internal audit is to assess the adequacy and effectiveness of the management system and to determine where improvements can be made. In order to maintain impartiality, internal auditors are not allowed to audit their own work. Auditor competence is a critical component for ISO registration. It is important for auditors, especially internal auditors, to receive training that is relevant and comprehensive with regard to the entire ISO series, and is conducted according to ISO requirements. Taking Corrective Action There are several reasons why an EMS might not meet ISO requirements. The program may have failed to keep up with environmental regulations during a period of rapid change. Perhaps employees have not been trained to new procedures or no provisions have been made to ensure that all employees have the resources needed to implement these procedures. In any case, it is the responsibility of the management representative and top management to review the plan and correct it when necessary. The goal is to detect and then correct the root causes of deficiencies. This is another area in which an external auditor or consultant may prove invaluable. If an audit reveals that your company needs to take corrective action for nonconformities, it is not a cause for alarm. If the nonconformity was identified as a minor, it is a problem that can be easily rectified and will not usually block the registration process The corrective action process is more involved for a major nonconformity, a deficiency or break down in the EMS that is preventing the organization from achieving its environmental objectives and targets. When a major nonconformity is identified, it usually means that a significant change must be made to the EMS by adding a procedure or changing a practice to eliminate its root cause and prevent it from recurring. Once the nonconformities are corrected, a follow-up audit specific to the areas of concern is usually required. This is done to confirm that the problem has been resolved. In the case of a Stage 2 audit, registration cannot be achieved until it is verified that all nonconformities have been corrected. EMS Executive Overview Page 17 3/13

20 THE BENEFITS OF ISO ISO registration creates innumerable advantages and unlimited benefits for organizations within both the public and private sectors. Reasons for seeking registration include fulfilling legal requirements, satisfying contractual requirements, achieving internal improvements, reducing multiple audits, regulatory and legal concerns, and marketplace benefits. In some countries, ISO registration may become a legal requirement to enter the marketplace. This may occur in the European Union (EU) and Japan. ISO registration enhances a company s public image while offering safeguards against lawsuits through reduced exposure to liabilities. Companies can face stiff fines and timeconsuming lawsuits for not adhering to environmental regulations. Furthermore, registration can greatly improve a company s competitive stance, especially when it comes to overseas trade. In the business sector, ISO registration has become a contractual requirement of some major companies in purchasing products and services. Additional mandates are expected in the future. To consumers, a company s registration to ISO provides assurance that it is committed to protecting the environment through proactive activities that can be objectively demonstrated. Even if ISO registration is not a customer-mandated requirement, businesses may opt to pursue it for such benefits as cost reduction, prestige, an assumed perception of environmental responsibility, and a positive public response. Most companies realize that self-improvement is imperative for business prosperity and growth. Internal improvement is yet another reason for ISO registration. When environmental management is a high priority of a company s management team, this positive message is reinforced throughout the workplace. Organizations that have implemented ISO often see improvements in productivity, waste reduction, energy efficiency and regulatory compliance costs. We are all becoming increasingly aware of the costs of environmental damage: contaminated ground water, polluted air, doubts and uncertainties about a sustainable future, and the expense of remediation. ISO 14000, by requiring organizations to plan, implement and maintain an EMS, can be used to prevent and minimize environmental impacts through a common sense approach, allowing companies to take charge of their environmental affairs while improving regulatory compliance. EMS Executive Overview Page 18 3/13

21 There are monetary benefits as well. Through the continual improvement process, an organization can save money by preventing pollution, avoiding cleanup and liability costs, using energy more efficiently and reducing waste. ISO registration, besides easing regulatory compliance, can improve a company s competitiveness, as a growing number of major firms have set supplier registration mandates. Registration can also aid companies seeking to enter the EU and Japanese markets. There are many benefits to be derived from implementing a well-structured ISO EMS, and the registration process is rigorous and timely. For this reason, not to mention the high rate of failure that afflicts organizations seeking registration for the first time, it is a good idea to seek the services of an outside professional consulting firm. A competent environmental consultant can walk your organization through the ISO requirements, interpret and implement the standard to your specific situation, and identify any problems that may halt the implementation and registration process. EMS Executive Overview Page 19 3/13

22 ISO ENVIRONMENTAL MANAGEMENT SYSTEM REQUIREMENTS NOTE: Requirements are paraphrased to avoid issues associated with potential copyright infringements. 4.1 General Requirements The organization shall establish, document, implement, maintain and continually improve an environmental management system in accordance with the requirements of ISO 14001:2004 and determine these requirements will be fulfilled. The organization shall define and document its environmental management system scope. 4.2 Environmental Policy Top management shall define the organization's environmental policy and ensure that the scope of its environmental management system: a) Is appropriate to the nature, scale and environmental impacts of its activities, products or services provided. b) Includes a commitment to continual improvement and pollution prevention. c) Includes a commitment to comply with applicable environmental legislation and regulations, and with other requirements to which the organization subscribes that relate to its environmental aspects. d) Provides the framework for establishing and reviewing environmental objectives and targets. e) Is documented, implemented and maintained. f) Is communicated to employees and other persons working for or on behalf of the organization. g) Is available to the public. 4.3 Planning Environmental Aspects. The organization must establish and maintain (a) procedure(s): a) To identify environmental aspects related to its activities, products and services within the defined scope of the environmental management system that it can control and those that it can influence giving consideration to planned or new developments, or new or modified activities, products and services. b) To determine aspects that have or can have significant impact(s) on the environment. EMS Executive Overview Page 20 3/13

23 The organization must keep this information up to date. The organization shall ensure that the significant environmental aspects given consideration when establishing, implementing and maintaining its environmental management system Legal and Other Requirements The organization shall establish, implement and maintain a procedure: a) To identify and have access to relevant legal and other requirements to which the organization subscribes, that are applicable to its environmental aspects. b) To determine how these requirements relate to its environmental aspects. The organization shall ensure that these relevant legal and other requirements to which the organization subscribes are given consideration when establishing, implementing and maintaining its environmental management system Objectives and Targets The organization shall establish, implement and maintain documented environmental objectives and targets, at relevant functions and levels within the organization. The objectives and targets shall be measurable and consistent with the environmental policy, including the commitments to prevention of pollution, to compliance with applicable legal and other requirements to which the organization subscribes, and to continual improvement. When establishing and reviewing its objectives and targets, an organization shall give consideration to the legal and other requirements to which the organization subscribes, and its significant environmental aspects. It shall also consider its technological options, its financial, operational and business requirements, and the views of interested parties. The organization shall establish, implement and maintain a program(s) for achieving its objectives and targets. Program(s) shall include: a) Designation of responsibility for achieving objectives and targets at relevant functions and levels throughout the organization. b) The means and time-frame for achieving the objectives. EMS Executive Overview Page 21 3/13

24 4.4 Implementation and Operation Resources, Roles, Responsibility and Authority Management shall ensure the availability of resources necessary to establish, implement, maintain and improve the environmental management system. Resources include human resources and specialized skills, organizational infrastructure, technology and financial resources. Roles, responsibilities and authorities shall be determined, documented and communicated in order to facilitate effective environmental management. The organization's top management shall appoint a management representative(s) who, irrespective of other responsibilities, shall have defined roles, responsibilities and authority for: a) Ensuring that an environmental management system is established, implemented and maintained in accordance with the requirements of ISO 14001:2004. b) Reporting to top management on the performance of the environmental management system, including recommendations for improvement, for review Competence, Training and Awareness The organization shall ensure that any person(s) working under its control that have the potential to cause a significant environmental impact(s) identified by the organization is (are) competent on the basis of appropriate education, training or experience, and shall retain associated records. The organization shall determine training requirements associated with its environmental aspects and its environmental management system. It shall provide training or take other action to meet these needs, and shall retain associated records. The organization shall establish, implement and maintain a procedure(s) to make persons working under its control aware of: a) The importance of conforming to the environmental policy and procedures and with the requirements of the environmental management system. b) The significant environmental aspects and related impacts associated with their work, and the environmental benefits of improved personal performance. c) Their roles and responsibilities in conforming with the requirements of the environmental management system. d) The potential consequences of departing from specified procedures. EMS Executive Overview Page 22 3/13