ISO 14001:2015 Environmental Management System # 3

Annex A

(informative)

Guidance on the use of this International Standard

A.I General

The explanatory information given in this annex is intended to prevent misinterpretation of the requirements contained in this International Standard. While this information addresses and is consistent with these requirements, it is not intended to add to, subtract from, or in any way modify them.

The requirements in this International Standard need to be viewed from a systems or holistic perspective. The user should not read a particular sentence or clause of this International Standard in isolation from other clauses. There is an interrelationship between the requirements in some clauses and the requirements in other clauses. For example, the organization needs to understand the relationship between the commitments in its environmental policy and the requirements that are specified in other clauses.

Management of change is an important part of maintaining the environmental management system that ensures the organization can achieve the intended outcomes of its environmental management system on an ongoing basis. Management of change is addressed in various requirements of this International Standard, including

o   maintaining the environmental management system (see 4.4).

o   environmental aspects (see 6.1.2).

o   internal communication (see 7.4.2).

o   operational control (see 8.1).

o   internal audit programme (see 9.2.2). and

o   management review (see 9.3).

As part of managing change, the organization should address planned and unplanned changes to ensure that the unintended consequences of these changes do not have a negative effect on the intended outcomes of the environmental management system. Examples of change include:

o   planned changes to products, processes, operations, equipment or facilities;

o   changes in staff or external providers, including contractors;

o   new information related to environmental aspects, environmental impacts and related technologies;

o   changes in compliance obligations.

A.2 Clarification of structure and terminology

The clause structure and some of the terminology of this International Standard have been changed to improve alignment with other management systems standards. There is, however, no requirement in this International Standard for its clause structure or terminology to be applied to an organization's environmental management system documentation. There is no requirement to replace the terms used by an organization with the terms used in this International Standard. Organizations can choose to use terms that suit their business, e.g. "records", "documentation", or "protocols", rather than "documented information".

A.3 Clarification of concepts

In addition to the terms and definitions given in Clause 3. clarification of selected concepts is provided below to prevent misunderstanding.

o   In this International Standard, the use of the word "any" implies selection or choice.

o   The words "appropriate" and "applicable" are not interchangeable. "Appropriate" means suitable [for, to) and implies some degree of freedom, while "applicable" means relevant or possible to apply and implies that if it can be done, it needs to be done.

o   The word "consider" means it is necessary to think about the topic but it can be excluded; whereas "take into account" means it is necessary to think about the topic but it cannot be excluded.

o   "Continual" indicates duration that occurs over a period of time, but with intervals of interruption [unlike "continuous" which indicates duration without interruption). "Continual" is therefore the appropriate word to use when referring to improvement.

o   In this International Standard, the word "effect" is used to describe the result of a change to the organization. The phrase "environmental impact" refers specifically to the result of a change to the environment.

o   The word "ensure" means the responsibility can be delegated, but not the accountability.

o   This International Standard uses the term "interested party"; the term "stakeholder" is a synonym as it represents the same concept

o   This International Standard uses some new terminology. A brief explanation is given below to aid both new users and those who have used previous editions of this International Standard.

o   The phrase "compliance obligations" replaces the phrase "legal requirements and other requirements to which the organization subscribes" used in the previous edition of this International Standard. The intent of this new phrase does not differ from that of the previous edition.

o   "Documented information" replaces the nouns "documentation", "documents" and "records" used in previous editions of this International Standard. To distinguish the intent of the generic term "documented information", this International Standard now uses the phrase "retain documented information as evidence of..." to mean records, and "maintain documented information" to mean documentation other than records. The phrase "as evidence of...." is not a requirement to meet legal evidentiary requirements; its intent is only to indicate objective evidence needs to be retained.

o   The phrase "external provider" means an external supplier organization (including a contractor) that provides a product or a service.

o   The change from "identify" to "determine" is intended to harmonize with the standardized management system terminology. The word "determine" implies a discovery process that results in knowledge. The intent does not differ from that of previous editions.

o   The phrase "intended outcome" is what the organization intends to achieve by implementing its environmental management system. The minimal intended outcomes include enhancement of environmental performance, fulfilment of compliance obligations and achievement of environmental objectives. Organizations can setadditional intended outcomes for their environmental management system. For example, consistent with their commitment to protection of the environment, an organization may establish an intended outcome to work towards sustainable development.

o   The phrase "person(s) doing work under its control" includes persons working for the organization and those working on its behalf for which the organization has responsibility (e.g. contractors). It replaces the phrase "persons working for it or on its behalf" and "persons working for or on behalf of the organization" used in the previous edition of this International Standard. The intent of this new phrase does not differ from that of the previous edition.

o   The concept of "target" used in previous editions of this International Standard is captured within the term "environmental objective".

A.4 Context of the organization

A.4.1 Understanding the organization and its context

The intent of 4/L is to provide a high-level, conceptual understanding of the important issues that can affect, either positively or negatively, the way the organization manages its environmental responsibilities. Issues are important topics for the organization, problems for debate and discussion or changing circumstances that affect the organization's ability to achieve the intended outcomes it sets for its environmental management system.

Examples of internal and external issues which can be relevant to the context of the organization include:

a)                 environmental conditions related to climate, air quality, water quality, land use, existing contamination, natural resource availability and biodiversity, that can either affect the organization's purpose, or be affected by its environmental aspects;

b)                the external cultural, social, political, legal, regulatory, financial, technological, economic, natural and competitive circumstances, whether international, national, regional or local;

c)                 the internal characteristics or conditions of the organization, such as its activities, products and services, strategic direction, culture and capabilities (i.e. people, knowledge, processes, systems).

An understanding of the context of an organization is used to establish, implement, maintain and continually improve its environmental management system (see 4v4). The internal and external issues that are determined in 4A. can result in risks and opportunities to the organization or to the environmental management system (see 6.1.1 to 6.1.3). The organization determines those that need to be addressed and managed (see 6.1.4. 6.2. Clause 7. Clause 8 and 9.1).

A.4.2 Understanding the needs and expectations of interested parties

An organization is expected to gain a general (i.e. high-level, not detailed) understanding of the expressed needs and expectations of those internal and external interested parties that have been determined by the organization to be relevant. The organization considers the knowledge gained when determining which of these needs and expectations it has to or it chooses to comply with, i.e. its compliance obligations (see 6.1.1).

In the case of an interested party perceiving itself to be affected by the organization's decisions or activities related to environmental performance, the organization considers the relevant needs and expectations that are made known or have been disclosed by the interested party to the organization.

Interested party requirements are not necessarily requirements of the organization. Some interested party requirements reflect needs and expectations that are mandatory because they have been incorporated into laws, regulations, permits and licences by governmental or even court decision. The organization may decide to voluntarily agree to or adopt other requirements of interested parties (e.g. entering into a contractual relationship, subscribing to a voluntary initiative). Once the organization adopts them, they become organizational requirements (i.e. compliance obligations) and are taken into account when planning the environmental management system (see 4v4). A more detailed-level analysis of its compliance obligations is performed in 6.1.3.

A.4.3 Determining the scope of the environmental management system

The scope of the environmental management system is intended to clarify the physical and organizational boundaries to which the environmental management system applies, especially if the organization is a part of a larger organization. An organization has the freedom and flexibility to define its boundaries. It may choose to implement this International Standard throughout the entire organization, or only in (a) specific part(s) of the organization, as long as the top management for that [those) part(s) has authority to establish an environmental management system.

In setting the scope, the credibility of the environmental management system depends upon the choice of organizational boundaries. The organization considers the extent of control or influence that it can exert over activities, products and services considering a life cycle perspective. Scoping should not be used to exclude activities, products, services, or facilities that have or can have significant environmental aspects, or to evade its compliance obligations. The scope is a factual and representative statement of the organization's operations included within its environmental management system boundaries that should not mislead interested parties.

Once the organization asserts it conforms to this International Standard, the requirement to make the scope statement available to interested parties applies.

A.4.4 Environmental management system

The organization retains authority and accountability to decide how it fulfils the requirements of this International Standard, including the level of detail and extent to which it:

a)                 establishes one or more processes to have confidence that it (they) is (are) controlled, carried out as planned and achieve the desired results;

b)                integrates environmental management system requirements into its various business processes, such as design and development, procurement, human resources, sales and marketing;

c)                 incorporates issues associated with the context of the organization (see 4JJ and interested party requirements (see 4^2) within its environmental management system.

If this International Standard is implemented for (a) specific part(s) of an organization, policies, processes and documented information developed by other parts of the organization can be used to meet the requirements of this International Standard, provided they are applicable to that (those) specific part(s).

For information on maintaining the environmental management system as part of management of change, see Clause A.I.

A.5 Leadership

A.5.1 Leadership and commitment

To demonstrate leadership and commitment, there are specific responsibilities related to the environmental management system in which top management should be personally involved or which top management should direct. Top management may delegate responsibility for these actions to others, but it retains accountability for ensuring the actions are performed.

A.5.2 Environmental policy

An environmental policy is a set of principles stated as commitments in which top management outlines the intentions of the organization to support and enhance its environmental performance. The environmental policy enables the organization to set its environmental objectives (see 6,2), take actions to achieve the intended outcomes of the environmental management system, and achieve continual improvement (see Clause 10).

Three basic commitments for the environmental policy are specified in this International Standard to:

a)                 protect the environment;

b)                fulfil the organization's compliance obligations;

c)                 continually improve the environmental management system to enhance environmental performance.

These commitments are then reflected in the processes an organization establishes to address specific requirements in this International Standard, to ensure a robust, credible and reliable environmental management system.

The commitment to protect the environment is intended to not only prevent adverse environmental impacts through prevention of pollution, but to protect the natural environment from harm and degradation arising from the organization's activities, products and services. The specific commitment(s) an organization pursues should be relevant to the context of the organization, including the local or regional environmental conditions. These commitments can address, for example, water quality, recycling, or air quality, and can also include commitments related to climate change mitigation and adaptation, protection of biodiversity and ecosystems, and restoration.

While all the commitments are important, some interested parties are especially concerned with the organization's commitment to fulfil its compliance obligations, particularly applicable legal requirements. This International Standard specifies a number of interconnected requirements related to this commitment. These include the need to:

o   determine compliance obligations;

o   ensure operations are carried out in accordance with these compliance obligations;

o   evaluate fulfilment of the compliance obligations;

o   correct nonconformities.

A.5.3 Organizational roles, responsibilities and authorities

Those involved in the organization's environmental management system should have a clear understanding of their role, responsibility(ies) and authority(ies) for conforming to the requirements of this International Standard and achieving the intended outcomes.

The specific roles and responsibilities identified in 5J3 may be assigned to an individual, sometimes referred to as the "management representative", shared by several individuals, or assigned to a member of top management.

A.6 Planning

A.6.1 Actions to address risks and opportunities

A.6.1.1 General

The overall intent of the process(es) established in 6.1.1 is to ensure that the organization is able to achieve the intended outcomes of its environmental management system, to prevent or reduce undesired effects, and to achieve continual improvement. The organization can ensure this by determining its risks and opportunities that need to be addressed and planning action to address them. These risks and opportunities can be related to environmental aspects, compliance obligations, other issues or other needs and expectations of interested parties.

Environmental aspects (see 6.1.2) can create risks and opportunities associated with adverse environmental impacts, beneficial environmental impacts, and other effects on the organization. The risks and opportunities related to environmental aspects can be determined as part of the significance evaluation or determined separately.

Compliance obligations (see 6.1.3) can create risks and opportunities, such as failing to comply (which can damage the organization's reputation or result in legal action) or performing beyond its compliance obligations (which can enhance the organization's reputation).

The organization can also have risks and opportunities related to other issues, including environmental conditions or needs and expectations of interested parties, which can affect the organization's ability to achieve the intended outcomes of its environmental management system, e.g.

a)                 environmental spillage due to literacy or language barriers among workers who cannot understand local work procedures;

b)                increased flooding due to climate change that could affect the organizations premises;

c)                 lack of available resources to maintain an effective environmental management system due to economic constraints;

d)                introducing new technology financed by governmental grants, which could improve air quality;

e)                 water scarcity during periods of drought that could affect the organization's ability to operate its emission control equipment.

Emergency situations are unplanned or unexpected events that need the urgent application of specific competencies, resources or processes to prevent or mitigate their actual or potential consequences. Emergency situations can result in adverse environmental impacts or other effects on the organization. When determining potential emergency situations (e.g. fire, chemical spill, severe weather), the organization should consider:

o   the nature of onsite hazards (e.g. flammable liquids, storage tanks, compressed gasses);

o   the most likely type and scale of an emergency situation;

o   the potential for emergency situations at a nearby facility (e.g. plant, road, railway line).

Although risks and opportunities need to be determined and addressed, there is no requirement for formal risk management or a documented risk management process. It is up to the organization to select the method it will use to determine its risks and opportunities. The method may involve a simple qualitative process or a full quantitative assessment depending on the context in which the organization operates.

The risks and opportunities identified (see 6.1.1 to 6.1.3) are inputs for planning actions (see 6.1.4) and for establishing the environmental objectives (see 6.2).

A.6.1.2 Environmental aspects

An organization determines its environmental aspects and associated environmental impacts, and determines those that are significant and, therefore, need to be addressed by its environmental management system.

Changes to the environment, either adverse or beneficial, that result wholly or partially from environmental aspects are called environmental impacts. The environmental impact can occur at local, regional and global scales, and also can be direct, indirect or cumulative by nature. The relationship between environmental aspects and environmental impacts is one of cause and effect.

When determining environmental aspects, the organization considers a life cycle perspective. This does not require a detailed life cycle assessment; thinking carefully about the life cycle stages that can be controlled or influenced by the organization is sufficient. Typical stages of a product (or service) life cycle include raw material acquisition, design, production, transportation/delivery use, end-of-life treatment and final disposal. The life cycle stages that are applicable will vary depending on the activity, product or service.

An organization needs to determine the environmental aspects within the scope of its environmental management system. It takes into account the inputs and outputs (both intended and unintended) that are associated with its current and relevant past activities, products and services; planned or new developments; and new or modified activities, products and services. The method used should consider normal and abnormal operating conditions, shut-down and start-up conditions, as well as the reasonably foreseeable emergency situations identified in 6.1.1. Attention should be paid to prior occurrences of emergency situations. For information on environmental aspects as part of managing change, see Clause A.1.

An organization does not have to consider each product, component or raw material individually to determine and evaluate their environmental aspects; it may group or categorize activities, products and services when they have common characteristics.

When determining its environmental aspects, the organization can consider:

a)                  emissions to air;

b)                 releases to water;

c)                  releases to land;

d)                 use of raw materials and natural resources;

e)                  use of energy;

f)                   energy emitted (e.g. heat, radiation, vibration (noise), light);

g)                  generation of waste and/or by-products;

h)                use of space.

In addition to the environmental aspects that it can control directly, an organization determines whether there are environmental aspects that it can influence. These can be related to products and services used by the organization which are provided by others, as well as products and services that it provides to others, including those associated with (an) outsourced process(es). With respect to those an organization provides to others, it can have limited influence on the use and end-of-life treatment of the products and services. In all circumstances, however, it is the organization that determines the extent of control it is able to exercise, the environmental aspects it can influence, and the extent to which it chooses to exercise such influence.

Consideration should be given to environmental aspects related to the organization's activities, products and services, such as:

o   design and development of its facilities, processes, products and services;

o   acquisition of raw materials, including extraction;

o   operational or manufacturing processes, including warehousing;

o   operation and maintenance of facilities, organizational assets and infrastructure;

o   environmental performance and practices of external providers;

o   product transportation and service delivery, including packaging;

o   storage, use and end-of-life treatment of products;

o   waste management, including reuse, refurbishing, recycling and disposal.

There is no single method for determining significant environmental aspects, however, the method and criteria used should provide consistent results. The organization sets the criteria for determining its significant environmental aspects. Environmental criteria are the primary and minimum criteria for assessing environmental aspects. Criteria can relate to the environmental aspect (e.g. type, size, frequency) or the environmental impact (e.g. scale, severity, duration, exposure). Other criteria may also be used. An environmental aspect might not be significant when only considering environmental criteria. It can, however, reach or exceed the threshold for determining significance when other criteria are considered. These other criteria can include organizational issues, such as legal requirements or interested party concerns. These other criteria are not intended to be used to downgrade an aspect that is significant based on its environmental impact.

A significant environmental aspect can result in one or more significant environmental impacts, and can therefore result in risks and opportunities that need to be addressed to ensure the organization can achieve the intended outcomes of its environmental management system.

A.6.1.3 Compliance obligations

The organization determines, at a sufficiently detailed level, the compliance obligations it identified in 4.2 that are applicable to its environmental aspects, and how they apply to the organization. Compliance obligations include legal requirements that an organization has to comply with and other requirements that the organization has to or chooses to comply with.

Mandatory legal requirements related to an organization's environmental aspects can include, if applicable:

a)                 requirements from governmental entities or other relevant authorities;

b)                international, national and local laws and regulations;

c)                 requirements specified in permits, licenses or other forms of authorization;

d)                orders, rules or guidance from regulatory agencies;

e)                 judgements of courts or administrative tribunals.

Compliance obligations also include other interested party requirements related to its environmental management system which the organization has to or chooses to adopt. These can include, if applicable:

o   agreements with community groups or non-governmental organizations;

o   agreements with public authorities or customers;

o   organizational requirements;

o   voluntary principles or codes of practice;

o   voluntary labelling or environmental commitments;

o   obligations arising under contractual arrangements with the organization;

o   relevant organizational or industry standards.

A.6.1.4 Planning action

The organization plans, at a high level, the actions that have to be taken within the environmental management system to address its significant environmental aspects, its compliance obligations, and the risks and opportunities identified in 6.1.1 that are a priority for the organization to achieve the intended outcomes of its environmental management system.

The actions planned may include establishing environmental objectives (see 6Ji) or may be incorporated into other environmental management system processes, either individually or in combination. Some actions may be addressed through other management systems, such as those related to occupational health and safety or business continuity, or through other business processes related to risk, financial or human resource management.

When considering its technological options, an organization should consider the use of best-available techniques, where economically viable, cost-effective and judged appropriate. This is not intended to imply that organizations are obliged to use environmental cost-accounting methodologies.

A.6.2 Environmental objectives and planning to achieve them

Top management may establish environmental objectives at the strategic level, the tactical level or the operational level. The strategic level includes the highest levels of the organization and the environmental objectives can be applicable to the whole organization. The tactical and operational levels can include environmental objectives for specific units or functions within the organization and should be compatible with its strategic direction.

Environmental objectives should be communicated to persons working under the organization's control who have the ability to influence the achievement of environmental objectives.

The requirement to "take into account significant environmental aspects" does not mean that an environmental objective has to be established for each significant environmental aspect, however, these have a high priority when establishing environmental objectives.

"Consistent with the environmental policy" means that the environmental objectives are broadly aligned and harmonized with the commitments made by top management in the environmental policy, including the commitment to continual improvement.

Indicators are selected to evaluate the achievement of measurable environmental objectives. "Measurable" means it is possible to use either quantitative or qualitative methods in relation to a specified scale to determine if the environmental objective has been achieved. By specifying "if practicable", it is acknowledged that there can be situations when it is not feasible to measure an environmental objective, however, it is important that the organization is able to determine whether or not an environmental objective has been achieved.

For additional information on environmental indicators, see ISO 14031.

A.7 Support

A.7.1 Resources

Resources are needed for the effective functioning and improvement of the environmental management system and to enhance environmental performance. Top management should ensure that those with environmental management system responsibilities are supported with the necessary resources. Internal resources may be supplemented by (an) external provider(s).

Resources can include human resources, natural resources, infrastructure, technology and financial resources. Examples of human resources include specialized skills and knowledge. Examples of infrastructure resources include the organization's buildings, equipment, underground tanks and drainage system.

A.7.2 Competence

The competency requirements of this International Standard apply to persons working under the organization's control who affect its environmental performance, including persons:

a)                 whose work has the potential to cause a significant environmental impact;

b)                who are assigned responsibilities for the environmental management system, including those who:

1)  determine and evaluate environmental impacts or compliance obligations;

2)                contribute to the achievement of an environmental objective;

3)                respond to emergency situations;

4)                perform internal audits;

5)                perform evaluations of compliance.

A.7.3 Awareness

Awareness of the environmental policy should not be taken to mean that the commitments need to be memorized or that persons doing work under the organization's control have a copy of the documented environmental policy. Rather, these persons should be aware of its existence, its purpose and their role in achieving the commitments, including how their work can affect the organization's ability to fulfil its compliance obligations.

A.7.4 Communication

Communication allows the organization to provide and obtain information relevant to its environmental management system, including information related to its significant environmental aspects, environmental performance, compliance obligations and recommendations for continual improvement. Communication is a two-way process, in and out of the organization.

When establishing its communication process(es), the internal organizational structure should be considered to ensure communication with the most appropriate levels and functions. A single approach can be adequate to meet the needs of many different interested parties, or multiple approaches might be necessary to address specific needs of individual interested parties.

The information received by the organization can contain requests from interested parties for specific information related to the management of its environmental aspects, or can contain general impressions or views on the way the organization carries out that management. These impressions or views can be positive or negative. In the latter case (e.g. complaints), it is important that a prompt and clear answer is provided by the organization. A subsequent analysis of these complaints can provide valuable information for detecting improvement opportunities for the environmental management system.

Communication should:

a)                  be transparent, i.e. the organization is open in the way it derives what it has reported on;

b)                 be appropriate, so that information meets the needs of relevant interested parties, enabling them to participate;

c)                  be truthful and not misleading to those who rely on the information reported;

d)                 be factual, accurate and able to be trusted;

e)                  not exclude relevant information;

f)                   be understandable to interested parties.

For information on communication as part of managing change, see Clause A.I. For additional information on communication, see ISO 14063.

A.7.5 Documented information

An organization should create and maintain documented information in a manner sufficient to ensure a suitable, adequate and effective environmental management system. The primary focus should be on the implementation of the environmental management system and on environmental performance, not on a complex documented information control system.

In addition to the documented information required in specific clauses of this International Standard, an organization may choose to create additional documented information for purposes of transparency, accountability, continuity, consistency, training, or ease in auditing.

Documented information originally created for purposes other than the environmental management system may be used. The documented information associated with the environmental management system may be integrated with other information management systems implemented by the organization. It does not have to be in the form of a manual.

A.8 Operation

A.8.1 Operational planning and control

The type and extent of operational control(s) depend on the nature of the operations, the risks and opportunities, significant environmental aspects and compliance obligations. An organization has the flexibility to select the type of operational control methods, individually or in combination, that are necessary to make sure the process(es) is (are) effective and achieve(s) the desired results. Such methods can include:

a)                 designing (a) process(es) in such a way as to prevent error and ensure consistent results;

b)                using technology to control (a) process(es) and prevent adverse results (i.e. engineering controls);

c)                 using competent personnel to ensure the desired results;

d)       performing (a) process(es) in a specified way;

e)                 monitoring or measuring (a) process(es) to check the results;

f)        determining the use and amount of documented information necessary.

The organization decides the extent of control needed within its own business processes (e.g. procurement process) to control or influence (an) outsourced process(es) or (a) provider (s) of products and services. Its decision should be based upon factors such as:

o   knowledge, competence and resources, including:

o   the competence of the external provider to meetthe organization's environmental management system requirements;

o   the technical competence of the organization to define appropriate controls or assess the adequacy of controls;

o   the importance and potential effect the product and service will have on the organization's ability to achieve the intended outcome of its environmental management system;

o   the extent to which control of the process is shared;

o   the capability of achieving the necessary control through the application of its general procurement process;

o   improvement opportunities available.

When a process is outsourced, or when products and services are supplied by (an) external provider(s), the organization's ability to exert control or influence can vary from direct control to limited or no influence. In some cases, an outsourced process performed onsite might be under the direct control of an organization; in other cases, an organization's ability to influence an outsourced process or external supplier might be limited.

When determining the type and extent of operational controls related to external providers, including contractors, the organization may consider one or more factors such as:

o   environmental aspects and associated environmental impacts;

o   risks and opportunities associated with the manufacturing of its products or the provision of its services;

o   the organization's compliance obligations.

For information on operational control as part of managing change, see Clause A.I. For information on life cycle perspective, see A.6.1.2.

An outsourced process is one that fulfils all of the following:

o   it is within the scope of the environmental management system;

o   it is integral to the organization's functioning;

o   it is needed for the environmental management system to achieve its intended outcome;

o   liability for conforming to requirements is retained by the organization;

o   the organization and the external provider have a relationship where the process is perceived by
interested parties as being carried out by the organization.

Environmental requirements are the organization's environmentally-related needs and expectations that it establishes for, and communicates to, its interested parties (e.g. an internal function, such as procurement; a customer; an external provider).

Some of the organization's significant environmental impacts can occur during the transportation, delivery, use, end-of-life treatment or final disposal of its product or service. By providing information, an organization can potentially prevent or mitigate adverse environmental impacts during these life cycle stages.

A.8.2 Emergency preparedness and response

It is the responsibility of each organization to be prepared and to respond to emergency situations in a manner appropriate to its particular needs. For information on determining emergency situations, see A.6.1.1.

When planning its emergency preparedness and response processes), the organization should consider:

a)                  the most appropriate method(s) for responding to an emergency situation;

b)                 internal and external communication process(es);

c)                  the action(s) required to prevent or mitigate environmental impacts;

d)                 mitigation and response action(s) to be taken for different types of emergency situations;

e)                  the need for post-emergency evaluation to determine and implement corrective actions;

f)                   periodic testing of planned emergency response actions;

g)                  training of emergency response personnel;

h)                 a list of key personnel and aid agencies, including contact details (e.g. fire department, spillage clean-up services);

i)                     evacuation routes and assembly points;

j)                     the possibility of mutual assistance from neighbouring organizations.

A.9 Performance evaluation

A.9.1 Monitoring, measurement, analysis and evaluation

A.9.1.1 General

When determining what should be monitored and measured, in addition to progress on environmental objectives, the organization should take into account its significant environmental aspects, compliance obligations and operational controls.

The methods used by the organization to monitor and measure, analyse and evaluate should be defined in the environmental management system, in order to ensure that:

a)                  the timing of monitoring and measurement is coordinated with the need for analysis and evaluation results;

b)                 the results of monitoring and measurement are reliable, reproducible and traceable;

c)                  the analysis and evaluation are reliable and reproducible, and enable the organization to report trends.

The environmental performance analysis and evaluation results should be reported to those with responsibility and authority to initiate appropriate action.

For additional information on environmental performance evaluation, see ISO 14031.

A.9.1.2 Evaluation of compliance

The frequency and timing of compliance evaluations can vary depending on the importance of the requirement, variations in operating conditions, changes in compliance obligations and the organization's past performance. An organization can use a variety of methods to maintain its knowledge and understanding of its compliance status, however, all compliance obligations need to be evaluated periodically.

If compliance evaluation results indicate a failure to fulfil a legal requirement, the organization needs to determine and implement the actions necessary to achieve compliance. This might require communication with a regulatory agency and agreement on a course of action to fulfil its legal requirements. Where such an agreement is in place, it becomes a compliance obligation.

A non-compliance is not necessarily elevated to a nonconformity if, for example, it is identified and corrected by the environmental management system processes. Compliance-related nonconformities need to be corrected, even if those nonconformities have not resulted in actual non-compliance with legal requirements.

A.9.2 Internal audit

Auditors should be independent of the activity being audited, wherever practicable, and should in all cases act in a manner that is free from bias and conflict of interest.

Nonconformities identified during internal audits are subject to appropriate corrective action. When considering the results of previous audits, the organization should include:

a)                 previously identified nonconformities and the effectiveness of the actions taken;

b)                results of internal and external audits.

For additional information on establishing an internal audit programme, performing environmental management system audits and evaluating the competence of audit personnel, see ISO 19011. For information on internal audit programme as part of managing change, see Clause A.I.

A.9.3 Management review

The management review should be high-level; it does not need to be an exhaustive review of detailed information. The management review topics need not be addressed all at once. The review may take place over a period of time and can be part of regularly scheduled management activities, such as board or operational meetings; it does not need to be a separate activity.

Relevant complaints received from interested parties are reviewed by top management to determine opportunities for improvement.

For information on management review as part of managing change, see Clause A.1.

"Suitability" refers to how the environmental management system fits the organization, its operations, culture and business systems. "Adequacy" refers to whether it meets the requirements of this International Standard and is implemented appropriately. "Effectiveness" refers to whether it is achieving the desired results.

A.10 Improvement

A.10.1 General

The organization should consider the results from analysis and evaluation of environmental performance, evaluation of compliance, internal audits and management review when taking action to improve.

Examples of improvement include corrective action, continual improvement, breakthrough change, innovation and re-organization.

A.10.2 Nonconformity and corrective action

One of the key purposes of an environmental management system is to act as a preventive tool. The concept of preventive action is now captured in 4A. (i.e. understanding the organization and its context] and 6A. (i.e. actions to address risks and opportunities).

A.10.3 Continual improvement

The rate, extent and timescale of actions that support continual improvement are determined by the organization. Environmental performance can be enhanced by applying the environmental management system as a whole or improving one or more of its elements.