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.
As a professional EMS assessor with leading certification bodies, I audited many large multi-site enterprises that had problems with aligning their corporate ISO 14001 Environmental Manuals with the corresponding procedures issued by their locations. To fill this gap, some companies create Environmental Manuals for their locations as copies of the main Environmental Manual; other businesses develop location-specific Environmental Manuals that are completely independent form the home office Environmental Manual.
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.
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.
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.
As an example, we can examine one of our international clients with facilities in the United States, Thailand and Europe. This organization established pretty complete Environmental Manual for their corporate office in the US. When we visited their plant in Thailand, we found that their Environmental Manual did not include reference to local regulations; the facility in Italy did not address contol of EMS records, etc.
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.
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.
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.
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.
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)
Facility Manual Reference Matrix
Location procedure
We will structure our Manual Reference Matrix as a list of all facilities and their corresponding Manual Reference Matrixes, as shown below:
Manual Reference Matrix Table of Contents
Home Office (San Francisco, California, USA)
Miami, Florida (USA)
Cleveland, OH (USA)
Singapore
Los Angeles, CA, USA
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.
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.
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. - 20765
As a professional EMS assessor with leading certification bodies, I audited many large multi-site enterprises that had problems with aligning their corporate ISO 14001 Environmental Manuals with the corresponding procedures issued by their locations. To fill this gap, some companies create Environmental Manuals for their locations as copies of the main Environmental Manual; other businesses develop location-specific Environmental Manuals that are completely independent form the home office Environmental Manual.
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.
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.
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.
As an example, we can examine one of our international clients with facilities in the United States, Thailand and Europe. This organization established pretty complete Environmental Manual for their corporate office in the US. When we visited their plant in Thailand, we found that their Environmental Manual did not include reference to local regulations; the facility in Italy did not address contol of EMS records, etc.
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.
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.
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.
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.
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)
Facility Manual Reference Matrix
Location procedure
We will structure our Manual Reference Matrix as a list of all facilities and their corresponding Manual Reference Matrixes, as shown below:
Manual Reference Matrix Table of Contents
Home Office (San Francisco, California, USA)
Miami, Florida (USA)
Cleveland, OH (USA)
Singapore
Los Angeles, CA, USA
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.
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.
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. - 20765
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