Integrate ISO 14001 with Existing procedures

Much of what an organization must do in an ISO 14001 EMS is probably already being done. No organization can operate without some environmental programs in place. These programs may need modification to comply with the ISO 14001 standard, but they serve as a good starting point to begin construction of an ISO compliant EMS. In fact, a good way to look at your EMS Manual is to view it as a road map. It will tell people where to find programs the organization uses to handle environmental concerns such as: wastewater systems operational manuals, air permit operating requirements, hazardous wastes handling procedures, materials purchasing requirements, and so forth.

A well-conceived ISO 14001 EMS will use existing environmental programs and procedures as a foundation. It will also include the business management practices of the company wherever possible. An example of this would be tying environmental impacts of raw materials purchases into an existing procedure to review raw materials specifications for engineering requirements and consistency. Many firms already have such procedures in place.

Other types of program integration may include integrating cost accounting practices with environmental operational practices. Many organizations cannot actually determine where their environmental dollars go. As a result, they cannot identify opportunities for financial improvement in environmental practices. Without such information, the environmental management of an organization is difficult. If management cannot see any cost benefit in environmental decision making, the managers usually take the least costly option. Activitybased costing allows a more comprehensive understanding of how environmental expenses are accrued by process and product rather than by facility or region. Then process control and product design can be reviewed to see if costs associated with their environmental impacts can be minimized. This is a good example of what ISO 14001 hopes to accomplish–good financial management leading to better environmental control.

Initial Review Of Gap Analysis In ISO 14001

A fundamental concept of the ISO 14001 EMS Standard is continual improvement of environmental performance. Before you can plan for improvement, you must first determine the current state of the organization’s environmental programs.

The initial review or gap analysis is, in itself, a microcosm of a well-organized approach to the entire ISO 14001 EMS development process. Each specification of the standard must be reviewed, including policy, legal requirements, training, objectives and targets, operational control systems, document control, auditing, management review, and corrective action.

The review should take into account the culture, products, marketing strategies, and other specifics of the organization. In all cases, consideration should be given to the full range of operating conditions, including possible incidents and emergency situations that may be encountered.

The ability of suppliers and subcontractors to comply with the Organization’s EMS program and applicable regulatory requirements should also be evaluated. It is strongly recommended that the initial review consider energy use, financial accounting, and information systems so that these issues may be integrated into the EMS program.

To effectively begin the Initial Review, several things must happen. First, Management should issue a company-wide announcement of intent and endorsement. This should include estimates of the time required to complete the Initial Review, and time required to complete the entire project. Second, the project leader should be identified and vested with ample authority for completion of the project.

The Initial Review is a review of all pertinent documents, from which an accurate plan is designed for the EMS Gap Analysis.

All information from the review, including deviation from regulatory requirements and adverse impacts on the environment, should be identified along with policies, programs, procedures, training and work instructions, and operational controls.

A portion of the project team should begin to assemble a registry of appropriate regulations identified during the Initial Review. All pertinent national, state, local and self-subscribed requirements should be assembled. They should be compared with identified environmental impacts.

An Initial Review is also important in ensuring that EMS design is compatible with all current organizational management structures and operations wherever possible. This is especially important where the EMS interfaces with the site’s existing health and safety, accounting, computer systems, purchasing, energy utilization and other management programs. The focus will be to achieve operational efficiencies that ensure environmental improvements and maximize cost reductions.

Initial Review outputs will be:

· An EMS Gap Analysis Design that details where existing environmental management procedures must be further investigated to determine conformance with the Standard.

· A review of the site’s overall environmental management strengths/weaknesses.

· A schedule of events for the Gap Analysis.

The gap analysis allows for a quick but comprehensive assessment of the facility’s existing environmental management practices and procedures, and compares them

with the requirements of the Standard. To perform the Gap Analysis, a standard template tailored for that specific purpose is used. The template is a questionnaire with a three way scoring system, which develops a final rating of the current programs of the site as they compare with the sections of the Standard. The score from this questionnaire and investigative template identifies which areas of the EMS might be enhanced to improve environmental performance and comply with the Standard.

Based on the results of the Gap Analysis, the project schedule and design may require modifications. Modification should precede further systems development. Using the results of the Gap Analysis, the EMS developmental process can now begin.

This may involve modifying existing procedures, adapting other business procedures such as those designed for health and safety, accounting, or risk management to environmental utilization. At certain points, new procedures will be required.

Prior to embarking on EMS development, always remember that the more flexible your EMS is, the easier it will be to implement and the more flexible it will be in the future.