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by Russell V. Thornton

Customers' and suppliers' increased awareness of environmental issu

es is spurring process industries and other manufacturers throughout the world to look for the best ways to integrate environmental management systems into their day-to-day operations.

Bringing an EMS into the mainstream right alongside other management systems helps businesses meet their customers' needs, which, in turn, helps them achieve their own financial goals. Integrating the EMS into daily operations also helps to elevate the level of consciousness within a business's workforce relative to environmental costs and impacts, often overlooked because they're difficult to quantify.

Perhaps most important, as the EMS becomes an integral part of an organization's daily operating environment, everyone within the organization, including decision makers, manufacturing associates, marketing representatives and finance personnel, takes ownership in a process that guides the organization toward achieving much greater productivity.

ISO 14001 Implementation Guideline

Following is an example of a practical implementation guideline, from which each organization’s practical checklist can be developed. The checklist helps focus activities.

Have the implementation team review the current ISO 14001 standard to determine requirements.

Identify an ISO 14000 process owner at the site.

Identify all site processes and functions that carry special requirements applicable to the EMS.

Define and document a matrix of existing policies and procedures.

Develop additional procedures to meet requirements, if needed.

Develop internal training material and methods for instruction.

Train internal auditors and relevant personnel in ISO 14000.

Develop communication methods, such as a newsletter, to promote ISO 14000 to the facility.

Implement all new or changed procedures and collect documented evidence of implementation during an internal audit.

Rectify all nonconformities.

Plan the registration audit by writing a scope statement and a strategy for registration.


Why is ISO 14001 needed?

The ISO 14001 standard, often referred to as the "green" standard, sets forth specific requirements for a comprehensive EMS. Formally published by the International Organization for Standardization on Sept. 1, 1996, the standard was developed to allow organizations to formulate policies and objectives within a structured management system framework. Simultaneously, legislative requirements, relevant public issues and plant-specific environmental concerns could all be considered.

As the introduction to ISO 14001 states, "International standards concerning environmental management are intended to provide organizations with the elements of an effective environmental management system, which can be integrated with other management requirements (or other management systems) to assist organizations in achieving environmental and economic goals."

ISO 14001 specifies the following components of an EMS:

Definition of an environmental policy

Environmental planning, encompassing identifying environmental aspects and legal obligations, developing objectives and targets, establishing an environmental management program, and specifying the means of achieving objectives

Implementation of the EMS and operational control

Assessment of conformity with the standard's requirements and/or company requirements, and corrective action in the case of nonconformity

Management review of the EMS

Each of these components must be fulfilled to completely integrate the EMS into a company's operating environment and/or achieve ISO 14001 registration.

Those wondering about the need for an EMS should note that, at this time, the United States is not the main driver for ISO 14001. Nevertheless, one would be naive to think the standard will go away.

Many see ISO 14001 certification as the ticket to trade in Europe and Asia. Already, sufficient evidence exists from a variety of international initiatives indicating that ISO 14001 will be widely adopted. Certification is well under way in the United Kingdom, Japan, East Asia, Brazil, India, Korea, Argentina, Hong Kong and Taiwan.

The Japanese Ministry of International Trade and Industry has advocated mandatory third-party registration to ISO 14001. The Japanese electronics industry has responded by developing the necessary infrastructure, and U.S. companies are reviewing their existing environmental programs in concert with the ISO 14001 criteria in order to better develop implementation strategies.

Steps along the guideline

A company that seeks to integrate ISO 14001 with other management systems in its business must be willing to begin that effort with a strong commitment to environmental responsibility. Perhaps Bin Prasad, manager of quality engineering at Rockwell Automation, best expressed the current "trend philosophy" being adopted by more and more companies when he said, "We really believed at that point [i.e., beginning the ISO 14001 pursuit] that our employees and our customers would prefer to do business with a company that espouses an environmental awareness."

Once the commitment to that philosophy is made and communicated to all employees, the next step is to put in place clearly defined environmental policies, programs, objectives and targets. Success at this phase allows an organization to both mainstream and fully integrate the EMS into its business.

As companies entering the process begin to get their feet wet, they should first turn to a variety of often-overlooked aids that may already be available. On-hand information might prove useful, and a business should consider viewing the following items--available in almost all organizations' existing databases--at the initial stage of development:

Documentation of the list of chemicals in the Occupational Safety and Health Act

Reports prepared for hazard and operability studies

Chemicals listed in the Environmental Protection Act and the Toxic Substances Control Act's chemical substances inventory

Process safety management rules often implemented in manufacturing facilities

Form R's and Tier I and Tier II reports submitted under the Emergency Planning and Community Right to Know Act

Contingency or vulnerability studies completed relative to critical systems and equipment

Data from risk management studies

Data from corrective action reports, especially data from preventive maintenance programs and inspections

Maintenance records

When assembled, the information from these resources establishes the existing environmental baseline, which can be used to help identify and evaluate environmental aspects and impacts.

Examine the local environment

Examining the local environment represents a prudent next step, with the understanding that companies should start with the major and obvious. Consider the following:

Air/climate factors, including local weather conditions, air quality data, etc.

Historical and cultural resources

Topography and landscape (from U.S. Geological Survey maps)

Any recreational uses

Proximity to residential areas

Watersheds, wildlife sanctuaries, lakes and streams

Past practices

Be sure to consider existing data from current operating permits, including:

Wastewater treatment parameters

Air quality emission data

Form R's

SARA Tier I and Tier II reports

Air emissions inventory

Waste characterization studies

Listed hazardous waste

After taking all these considerations into account, an organization is ready for a review of all key areas. The review should include a re-examination of all legislative and regulatory requirements. Take a look at existing environmental management procedures, feedback obtained from corrective action response systems, results available from completed internal audits and industry codes of practice. Use technical models, when appropriate, to further review potential environmental aspects and effects.

Once the baseline relative to the environment has been established, it's time to begin formulating a plan to develop and deploy the EMS. This could include preparing an ISO 14001 general requirements guideline and framework to identify environmental aspects and effects. Program support needs an up-to-date document reference list to help prepare a step-by-step implementation guideline. Training and development should be considered part of the general requirements.

Organizations will also find it helpful to refer to Annex A of ISO 14001:1996 (E), and ISO 14004:1996 (E) Environmental Management Systems, which contain general guidelines on principles, systems and supporting techniques to build an EMS that conforms to ISO 14001 requirements.

Set objectives and targets

Objectives are the overall goals for environmental performance based on an organization's environmental policy and evaluation of environmental aspects. Goals should be set after taking into account the identified environmental aspects as well as the associated environmental effects. Obviously, special consideration should be given to those identified as significant to the organization and the environment. Targets should be specific, have an established time frame and be measurable. As companies set objectives and targets, it's acceptable to consider technological options, financial options, operational options, and both business and customer requirements. Remember to include the views of interested parties, such as regulators, the community, stockholders and nongovernment organizations.

A company should be wary of the temptation to set "appealing" objectives and targets, which can adversely affect the process if they're not linked directly to policy and environmental aspects and effects. When placed correctly, targets should be linked with environmental aspects, performance indicators, relevant levels and functions of the organization, relevant operational controls, and most important, measuring and monitoring activities.

To maintain conformance with the ISO 14001 standard, an organization, as it sets objectives and targets, should discover that the process is continual. Each step must take into account the previous steps when developing the EMS.

Most companies generate an objectives and targets matrix or checklist to remain organized and stay on track. An organization should strive for aggressive but attainable targets and make available the necessary resources, expertise and time to reach each of them. Because this involves practical and effective training of the workforce, both time and cost for training should be a factor when establishing the time frame for reaching a target.

Implement and get registered

At this point, companies should be ready to begin implementing and completing the integration of ISO 14001 into their existing management systems. During implementation, companies should remember to use procedures and programs from existing management systems whenever possible, continuing to build on what they have.

Using a guideline and developing a checklist tied to the ISO 14001 standard is a wise approach and a key ingredient when planning and integrating an EMS and pursuing ISO 14001 registration. The registrar will be using a checklist, and a company should too. Objectives and targets of the EMS don't need to be totally implemented at the time of a registration audit, but a company must have assembled sufficient evidence to show progress in the pursuit of its goals.

A company can gather this evidence through an internal EMS audit that provides objective evidence of implementation, signs that objectives and targets are being monitored and measured, and confirmation that progress is being tracked according to an established time frame.

In summary, as a company successfully integrates an EMS into its business, its ability to meet its customers' needs and expectations will improve.

Create and use a checklist linked to the ISO 14001 standard. Remember that when seeking registration, a company must be able to identify environmental aspects and effects in a manner clear to the registrar.

Finally, be practical: Avoid issues over which the organization has no real control, and refrain from writing elaborate procedures.

About the author

Russell V. Thornton is a manager of environmental certification for Det Norske Veritas, a leading supplier of accredited management systems registration services worldwide. He is a frequent author and lecturer regarding EMS development and implementation. DNV (www.dnvcert.com) is based in Houston. Letters to the editor regarding this article can be e-mailed to letters@qualitydigest.com.

This article originally appeared in the July 1998 issue of InTech magazine.