While numerous successful models of ISO 14001 Environmental management systems have been developed and are being used in various industries, approaches to documenting top level environmental management systems for multi-location enterprises are limited at best. This article discusses a method for establishing an ISO 14001 top-level documentation structure that allows a business with multiple facilities to use common Environmental Management System Manual. This model significantly improves consistency of the corporate message regarding Environmental policies, while reducing the number of EMS documents within the organization's Environmental Management System.
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 reality, these solutions do not provide for a consistent representation of the organization's position on Environmental issues. The first approach, when a copy of the home office Environmental Manual is used, techniques for controlling local Environmental Manuals as a rule are not determined. Differences in the corporate Manual and the site's Environmental Manual often occur because the corporate office Manuals are managed by the home office, while site?s Manuals is controlled by individual sites.
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.
From the corporate identity and simply business consistency points of view, an organization should not find itself in a position of having different or conflicting commitments of its facilities to environmental policies, pollution prevention, compliance with regulations and other requirements of ISO 14001 standard.
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
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 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.
As with a single-location company, a business can still use discussed reference structure if the number of locations or sites is small; let's say not to exceed three. For example, clause 4.4.1 Resources, roles, responsibility and authority may read: Hazmat Experts Company ensures the availability of resources essential to establish, implement, maintain and improve the EMS per the Resource Procedure and the Organizational Chart HO and the Organizational Chart Singapore This example references the common Resource Procedure and site-specific organizational charts for Home Office (HO) and Singapore facility. This format works well for limited number of facilities, but it becomes ineffective when the number of company's locations increases.
If we need to work with a company that has significant number or offices and wishes to reference in the Environmental Manual procedures controlled by its sites, we may take a different approach. For example, we can prepare a matrix to associate the corporate Environmental Manual clauses with the site-specific procedures. We can name this tool Manual Reference Matrix and consider the following reference model:
Corporate ISO 14001 Environmental Manual section
Manual Reference Matrix Table of Contents (ToC)
Site-specific Manual Reference Matrix
Corresponding site-specific document
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)
Cleveland, OH (USA)
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.
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.
Looking for samples of Manual Reference Matrix for ISO 14001 Ems and other manuals? Check links below.
by: Mark Kaganov
About the Author:
If you are struggling with aligning your corporate EMS Manual with location-specific procedures, you need to use our ISO 14001 Manual Reference Matrix. Visit our site to see how our tested tools can help you develop or improve your 14001 Environmental Management System.