by Mark Kaganov
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.
In the case of the second approach, when organizations allow their satellite locations to have their own Environmental Manuals independent from the corporate EMS Manual, differences in Environmental Manuals may create major disconnect of the corporate and local ISO 14001 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.
One of our large EMS customers demonstrated this point well. The corporate ISO 14001 Environmental Manual addressed majority of the requirements of the standard and referenced appropriate regulations. At the same time, one of their US locations did not define their Environmental policy, Mexico facility did not reference local legal requirements, yet their European site failed to document their Environmental programs all together!
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.
To solve this problem, let’s review an ISO 14001 Environmental Manual model, specifically supporting document reference structure. As a common practice, an Environmental Manual references supporting documents within the text of the Manual. For example, 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 to determine and document those aspects that have or can have significant impacts on the environment.
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.
When an enterprise has significant number of facilities and needs to reference in its corporate Manual numerous procedures including those controlled by its sites, we have another choice. We can develop a matrix to connect our Environmental Manual elements with the location-specific supporting documents. We will title this document Manual Reference Matrix and establish the following documentation reference structure.
Corporate ISO 14001 Environmental Manual element
Manual Reference Matrix Table of Contents (ToC)
Facility Manual Reference Matrix
Location procedure
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
Home Office (San Francisco, California, USA)
Toronto (Canada)
Cleveland, OH (USA)
Aspen, Colorado (USA)
Tokyo (Japan)
etc,
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.
Environmental Manual Reference Matrix may be formatted as a three-column table with the Manual Clause in the first column, HO References in the second and Location References in the third column. For example, for the element 4.4.6, Operational Control, the Los Angeles plant’s Matrix indicates that the Manual references Operational Controls Procedure HO for the corporate office and the Operational Control Procedure LA for the Los Angeles plant.
If you are developing an ISO 14001 Environmental Manual for a large corporation with multiple sites, check the links below for samples of Reference Matrix.
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