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 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.
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!
As we can see, both approaches to creation of location's ISO 14001 Environmental Manuals as copies of the corporate Manuals or independent Manuals do not appear to be practical. Besides, if a company has already spent time on developing an Environmental Manual, why should another employee in the same organization spent more time to create a similar or duplicate document?
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 Pocedure and the Organizational Chart
The same method will also work for a multi-site organization for those documents that are used at all locations. For example, such processes as Hazard Material Handling, Management Review, Non-Conformity Procedure and others may be the same for all locations and therefore be referenced in the Environmental Manual as shown above.
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)
Site-specific Manual Reference Matrix
Corresponding site-specific document
Our Manual Reference Matrix ToC is simply a list of company's locations or sites' Manual Reference Matrixes, as shown in the illustration below:
Manual Reference Matrix Table of Contents
Corporate Office (Dubai, UAE)
Bangkok (Thailand)
St. Petersburg (Russia)
Aspen, Colorado (USA)
Tokyo (Japan)
etc,
To show how this approach works, we will document element 4.5.1 Monitoring and measurement. Our Environmental manual may state: Recycling Experts, Inc. has established, implemented and maintains a Monitoring Procedure to monitor and measure, on a regular basis, the key characteristics of its operations that can have a significant environmental impact per the site-specific key characteristics matrixes per the Manual Reference Matrix ToC. This clause indicates that the organization uses the corporate Monitoring Procedure and facility-specific Key Characteristics Matrix. To locate a facility-specific Key Characteristics Matrix, one simply needs to go to the Manual Reference Matrix 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.
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. - 15246
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 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.
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!
As we can see, both approaches to creation of location's ISO 14001 Environmental Manuals as copies of the corporate Manuals or independent Manuals do not appear to be practical. Besides, if a company has already spent time on developing an Environmental Manual, why should another employee in the same organization spent more time to create a similar or duplicate document?
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 Pocedure and the Organizational Chart
The same method will also work for a multi-site organization for those documents that are used at all locations. For example, such processes as Hazard Material Handling, Management Review, Non-Conformity Procedure and others may be the same for all locations and therefore be referenced in the Environmental Manual as shown above.
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)
Site-specific Manual Reference Matrix
Corresponding site-specific document
Our Manual Reference Matrix ToC is simply a list of company's locations or sites' Manual Reference Matrixes, as shown in the illustration below:
Manual Reference Matrix Table of Contents
Corporate Office (Dubai, UAE)
Bangkok (Thailand)
St. Petersburg (Russia)
Aspen, Colorado (USA)
Tokyo (Japan)
etc,
To show how this approach works, we will document element 4.5.1 Monitoring and measurement. Our Environmental manual may state: Recycling Experts, Inc. has established, implemented and maintains a Monitoring Procedure to monitor and measure, on a regular basis, the key characteristics of its operations that can have a significant environmental impact per the site-specific key characteristics matrixes per the Manual Reference Matrix ToC. This clause indicates that the organization uses the corporate Monitoring Procedure and facility-specific Key Characteristics Matrix. To locate a facility-specific Key Characteristics Matrix, one simply needs to go to the Manual Reference Matrix 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.
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. - 15246
