Since introduction of ISO 14001 Standard for Environmental Management Systems the market has developed numerous practical models of Environmental Manuals for organizations with single sites. At the same time, formats for management system structures for multi-facility businesses are limited at best in technical publications. This paper discusses a model for structuring a top-level documentation that allows an organization with multiple sites to use common ISO 14001 Environmental Management System Manual. Discussed approach noticeably improves consistency of the organization’s Environmental policies.
Working as an Environmental Lead Auditor for numerous international ISO registrars, I assessed dozens of big multi-facility, multi-national organizations that had difficulties with synchronizing their home office ISO 14001 Environmental Manuals with the corresponding documents controlled by their sites. Designing Environmental Manuals for companies with multiple sites, some organizations develop their sites’ Environmental Manuals as copies of the corporate Environmental Manual; other enterprises create facility-specific Manuals that are totally autonomous and do not correlate with corporate ISO 14001 Manuals.
In practice, neither one of these approaches produce a consistent result. In the 1st instance when a modified Environmental Manual is used for a location, methods for updating local Environmental Manuals are not defined. This disconnect arises from the fact that the corporate office manuals are controlled by the home office, while local Environmental Manuals are facilities’ responsibility.
The 2nd approach, when companies permit their sites to establish their own Environmental Manuals, differences in all those Environmental Manuals lead to noticeable disconnect between the corporate and site-specific Environmental Manuals.
If an organization wishes to deliver a consistent message regarding its Environmental policies and their position on prevention of pollution, the deficiencies of discussed methods become obvious.
As an example, we can examine one of our international clients with facilities in the United States, Thailand and Europe. This organization established pretty complete Environmental Manual for their corporate office in the US. When we visited their plant in Thailand, we found that their Environmental Manual did not include reference to local regulations; the facility in Italy did not address contol of EMS records, etc.
As one can see, both approaches above to development of sites’ Environmental Manuals as copies of the corporate Manuals or independent Environmental Manuals do not appear to be practical or economical.
Fortunately, there is a solution. Let’s review an example of ISO 14001 2008 Environmental Manual model that references supporting documents within the text of the Manual. For example, element 4.3.2, Legal and other requirements, may read: EMS Associates, LLP has established, implemented and maintains Legal Requirements Procedure to identify and have access to the applicable legal requirements related to the organization’s environmental aspects per the Environmental Aspects Procedure,
This method of referencing supporting procedures is very common for Environmental Manuals for companies with single location. Interestingly, it also works for a multi-site business for those documents that are common for all sites. For instance, Audit Procedure, Data Analysis procedure, and others may be common for all your sites and be referenced in your Environmental Manual as shown.
But, what if your sites use their own environmental aspects procedures, country or state specific legal requirements and other unique EMS documents different form corporate procedures? Let’s examine how an organization’s ISO 14001 Environmental Manual can reference corporate and site-specific procedures.
The same document reference structure as for a single-location company that we discussed above, can be used if the number of locations is small, let’s say two or three. In this case, clause 4.3.1, Environmental aspects may read: Environmental Consultants Inc. has established, implemented and maintains Environmental Aspect Procedure to identify the environmental aspects of its activities, products and services and Significant Environmental Aspect Matrix HO and Significant Environmental Aspect Matrix WA to determine and document those aspects that have or can have significant impacts on the environment. This example shows references to the common Environmental Aspect Procedure and site-specific Significant Environmental Aspect Matrixes for the Home Office (HO) and the Washington (WA) locations. While this model works well for a limited number of facilities, it becomes impractical when the number of locations is significant.
For companies with a large number of locations, where we need to reference numerous documents in the Manual, including those controlled by satellite locations, we have another option. We can establish a document to connect corporate Environmental Manual commitments with the site-specific supporting documents. Let’s name this document a Manual Reference Matrix and consider the following document reference structure.
Corporate ISO 14001 Environmental Manual section
Manual Reference Matrix Table of Contents (ToC)
Location Manual Reference Matrix
The Manual Reference Matrix is simply a list of all facilities and their Manual Reference Matrixes, as shown in the example below:
Manual Reference Matrix Table of Contents
Main Office (Washington, DC USA)
St. Petersburg (Russia)
Buenos Aires, (Argentina)
Let’s see how this model works. We will document section 4.4.1 Resources, roles, responsibility and authority: Hazmat Experts Company ensures the availability of resources essential to establish, implement, maintain and improve the EMS per the Resource Procedure and the organizational charts per the Manual Reference Matrix To locate a site-specific organizational chart, we simply need to consult the Manual Reference Matrix ToC.
Following the specific location hyperlink for example our Washington facility, we will find a site-specific Manual Reference Matrix. Locating a specific element in the location’s Manual Reference Matrix, we will find a particular, location-specific document that corresponds with a given clause of our ISO 14001 Environmental Manual.
A Manual Reference Matrix may be formatted as a three-column form. The first two columns are titled Corporate EMS Section No. and Corporate EMS References; the third column is called Location procedures. For the element 4.3.1, for example, the Matrix indicates that our Manual Reference Matrix references Significant Environmental Aspect Matrix HO for the corporate office and the Significant Environmental Aspect Matrix WA for the Washington facility.
For examples of the Manual Reference Matrix, follow the links below.
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* Video on Environmental Problems and Challenges put together for the MSc in Environmental Technology at Imperial College London
Also see: https://www.youtube.com/watch?v=V6u3e59tVnA
Environmental Problems and Challenges