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ISO 14001 Environmental Management - Corporate Manual

By Mark Kaganov

Small and medium size businesses with a single location that employ ISO 14001 Environmental Management System have developed solid models for the top level documentation. At the same time, information on Environmental Manuals for multi-facility companies has not been addressed in professional publications. This publication proposes a model of an Environmental Manual for establishing the top-level documentation structure that allows a business with more than one site to use a common ISO 14001 Environmental Management System Manual.

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 are because the corporate office Manuals are managed by the home office, while site's Manuals are controlled by individual sites.

The 2nd approach, when companies permit their sites to establish their own Environmental Manuals, differences in all those Environmental Manuals lead to noticeable disconnect between the corporate and site-specific Environmental Manuals.

Those companies that adhere to the policy of maintaining a consistent corporate message regarding their position on Environmental issues will definitely experience a gap if they use methods that we discussed above.

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!

As one can see, both approaches above to development of sites' Environmental Manuals as copies of the corporate Manuals or independent Environmental Manuals do not appear to be practical or economical.

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.

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.

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.

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)

Location Manual Reference Matrix

Facility 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

Home Office (San Francisco, California, USA)

Toronto (Canada)

Springfield, IL (USA)

Buenos Aires, (Argentina)

Tokyo (Japan)

etc,

To illustrate this model, let's document element 4.3.1 Environmental aspects of our corporate ISO 14001 Environmental Manual with references to site-specific significant environmental aspect matrixes: Environmental Consultants, Inc. has established, implemented and maintains Environmental Aspect Procedure to identify the environmental aspects of its activities, products and services and site-specific significant environmental aspect matrixes per the Manual Reference Matrix ToC. This example shows references to the common Environmental Aspect Procedure and site-specific Significant Environmental Aspect Matrixes. To locate a site-specific Matrix, we need to refer to the Manual Reference Matrix Table of Contents (ToC).

Finding the location of interest in the Matrix ToC and locating, we will find, let's say, St. Petersburg's Matrix. In the matrix, in the given element, we will identify a site-specific Key Characteristics Matrix SP.

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.

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