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 the first case, when a site-specific Environmental Manual is a copy of the corporate Manual with modifications specific to a given site, mechanisms to keep these documents coordinated are rarely defined. Difficulties of keeping these documents in sync are due to the fact that corporate Environmental Manuals are controlled by the home office, while local EMS Manuals are responsibility of site’s documentation control departments.
In the case of companies choosing their facilities to develop their own ISO 14001 Manuals, discrepancies in numerous Environmental Manuals result in visible differences between the home office and facilities’ Environmental Manuals and therefore commitments to environmental issues.
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.
One of Quality Works’ EMS clients illustrated this deficiency. The home office Manual documented majority of the applicable requirements. At the same time, their facility in Canada did not document Environmental policy, another missed a commitment to prevention of pollution, yet the third one forgot to document their EMS communication procedure at all!
Summarizing my EMS auditing and consulting experiences, I am convinced that these approaches to design of the corporate Environmental Manual and sites’ Manuals do not provide a solid consistent way to document organization’s Environmental Management System and Manuals.
If a business wishes to establish an Environmental Manual that will serve all its facilities, we need to consider a different route. Let’s start from an example of the clause 4.4.1 Resources, roles, responsibility and authority. The manual may state: Hazmat Handling Company ensures the availability of resources essential to establish, implement, maintain and improve the EMS per the Resource Procedure and the Organizational Chart
This model proved to be effective for a single-location company. It also will work for a multi-site business, but only for common EMS documents that are used at all locations. For example, such procedures as Documentation Management, Environmental Audit, CAPA and others may be the same for your all facilities and therefore be referenced in the Environmental Manual as shown above.
However, what if our locations need to use different environmental aspects, programs and other site-specific Environmental Management System processes? If we use the model above and want to keep a common ISO 14001 Environmental Manual, we have to reference in the Manual corresponding documents for all locations which may not be practical. Below we will explore how a corporate Environmental Manual can practically reference location-specific documents to support commitments of the company’s common ISO 14001 Environmental Manual.
A method identical to a single-site organization can be used when the number of facilities is relatively small, let’s say 2 – 3. For example, element 4.5.2, Evaluation of compliance, may read: Consistent with Green Products’ commitment to compliance, we have established, implemented and maintain a Compliance Evaluation Procedure for periodically evaluating compliance with applicable legal requirements per the Legal Requirements Matrix HO and the Legal Requirements Matrix Canada. This example references to the common Compliance Evaluation Procedure and facility-specific Legal Requirements Matrix HO (Home Office) and Legal Requirements Matrix Canada. This approach works well for a company with limited number of locations, but it becomes bulky and unworkable when the number of facilities grows.
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 element
Manual Reference Matrix Table of Contents (ToC)
Facility 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)
Springfield, IL (USA)
Aspen, Colorado (USA)
Port Williams (Chile)
To illustrate this model, let’s document element 4.3.1 Environmental aspects of our corporate ISO 14001 Environmental Manual with references to site-specific significant environmental aspect matrixes: Environmental Consultants, Inc. has established, implemented and maintains Environmental Aspect Procedure to identify the environmental aspects of its activities, products and services and site-specific significant environmental aspect matrixes per the Manual Reference Matrix ToC. This example shows references to the common Environmental Aspect Procedure and site-specific Significant Environmental Aspect Matrixes. To locate a site-specific Matrix, we need to refer to the Manual Reference Matrix Table of Contents (ToC).
Let’s say we need to locate a Communication Procedure for our Singapore plant. When we find this clause in our Manual Reference Matrix table of contents, we actually will connect to the location’s Manual Reference Matrix. Finding the corresponding clause number in the site’s Manual Reference Matrix, we will find a site-specific procedure title that addresses our clause of the Environmental Manual.
Our experience shows that a Manual Reference Matrix works well as a 3-column form with the 1st column titled Corp. Manual Section, the 2nd column Corp. References, and the 3rd column called Site References. For the element 4.5.1, for example, the St. Petersburg’s Matrix indicates that Manual references Key Characteristics Matrix HO for the home office and Key Characteristics Matrix SP for the St. Petersburg site.
Looking for samples of Manual Reference Matrix for ISO 14001 Ems and other manuals? Check links below.
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