

January 26, 2012
Recent EH&S Trends Based on 2011 Data
February 2, 2012
The EH&S Compliance Cycle: Audits, Development, Implementation, and Maintenance
February 9, 2012
Supplemental Environmental Project (SEP) & August Mack’s eCAP Programe
February 16, 2012
Background Contaminants
February 21, 2012
IDEM Rule 6 Storm Water Permits
February 23, 2012
Environmental Due Diligence for Commercial Property Transaction
March 2, 2012
How Do You Manage Your Safety Risk in Environmental Remediation Projects?
March 8, 2012
Changes to Indiana Closure Guidance
March 15, 2012
Environmental Considerations with Land Use Redevelopment
March 22, 2012
Updated Toxic Substances Control Act (TSCA) Chemical Data Reporting (CDR) Standards
Since the International Organization for Standardization initially issued the environmental management systems (EMSs) series of standards (ISO 14001) in 1996, numerous companies have developed EMSs and attained third-party registration to ISO 14001. However, there are still many companies who have not achieved ISO 14001 certification but are considering it for a variety of reasons. If your company is considering ISO 14001 certification there are a number of items that are needed to become ISO certified. This article will focus on four of the most important:
A company that is considering pursuing ISO 14001 certification should initially determine what is driving their decision. Who cares if there’s a reason to obtain certification? The people paying the bills and keeping an eye on the facility’s bottom line. As many of you know, ISO 14001 is not a regulatory driven standard. Adherence and certification to the standard is entirely voluntary. (Well almost. I did work with one facility that was required to obtain ISO 14001 certification as part of a consent agreement with the state regulatory agency.) As with most voluntary programs, companies will most likely choose to participate or not participate with ISO 1400 certification based on some internal or external driving force. With ISO 14001, since there is no regulatory driver pushing companies to achieve certification, then some other reason for obtaining ISO 14001 certification should exist. Some of the drivers for a facility to become ISO 14001 certified may include:
Having a reason to obtain ISO14001 certification directly relates to the second item that is needed to become ISO certified. There is no getting around the fact that certifying to ISO 14001 will require a commitment of financial and personnel resources. Financial resources will be required for items such as external training classes, consulting support, retaining a registrar to perform the registration audit, and periodic surveillance audits to maintain the certification, and miscellaneous support items including signage, communication devices, office supplies, etc. With regard to personnel resources, a team of individuals at the facility will be needed to develop the program which will take time away from their other responsibilities. In addition, an internal audit team will need to be established and trained which will require a commitment of man-hours in addition to the time required for members of the audit team to conduct internal audits of all of the elements of the facility’s ISO 14001 EMS initially and on an ongoing basis.
Okay, so you have a reason and have secured the required resources now what? Well, it’s hard to get where you’re going if you do not know where you are. Since many facilities already have some type of environmental program in place, these existing environmental programs can be used as the basis for the facility’s ISO 14001 EMS. In order to do this effectively these existing programs should be reviewed and compared to the elements of the ISO 14001 standard to ascertain what existing programs can be modified to comply with the ISO 14001 standard and what new programs will need to be developed. This review is sometimes referred to as a gap analysis.
Once the review of your current EMS is complete you will know what procedures and policies will need to be developed and implemented before scheduling your certification audit. There is one more item that you will want to have before you make the arrangements with your registrar, an EMS document. It’s kind of strange listing an EMS document as one of the musts to successfully obtain ISO 14001 certification when the ISO14001 standard doesn’t actually require an EMS document to be developed. Sure there is the requirement to develop documentation as part of your ISO 14001 program (quite a lot of documentation in fact), but there is actually no requirement to develop an EMS document. So why develop one? The same reason we document all sorts of things for regulatory agencies, financial auditors, and others. How are you going to demonstrate to a certification auditor that your ISO 14001 program meets the standard during a five day certification audit? Is he going to be able to interview every one of your employees and observe the implementation of all of your environmental practices and procedures? No. He is going to rely on the documentation that has been prepared outlining your EMS and listing all of the elements of your EMS. This is the EMS document. He is going to use it as a road map to understand how your organization handles environmental concerns and compare it to the ISO 14001 standard to see if it includes all of the required elements. Then as part of the audit he will observe how you are implementing your EMS and conduct employee interviews as appropriate.
Now you know the four most important items that will be needed for your facility to obtain ISO 14001 certification. Next month we will look at maintaining ISO 14001 certification in Part 2 of this three part series of articles - What It Takes to Maintain ISO 14001 Certification.
Other Articles In This Issue: