Becoming Who You Want To Be

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 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.

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 control 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.

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 Procedure 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.

While references to common procedures in an ISO 14001 Environmental Manual are clear, we still have to address those documents that are specific to particular locations such as site-specific aspect, programs, Hazmat handling and others. When we wish to maintain just one Environmental Manual, we need to reference in it supporting procedures for all sites which may easily clutter the Manual. To solve this problem we will examine how a common Environmental Manual can efficiently reference facility-specific procedures to address statements of the organization’s ISO 14001 Environmental Manual.

A method identical to a single-site organization can be used when the number of facilities is relatively small, let’s say 2 – 3. For example, element 4.5.2, Evaluation of compliance, may read: Consistent with Green Products’ commitment to compliance, we have established, implemented and maintain a Compliance Evaluation Procedure for periodically evaluating compliance with applicable legal requirements per the Legal Requirements Matrix HO and the Legal Requirements Matrix Canada. This example references to the common Compliance Evaluation Procedure and facility-specific Legal Requirements Matrix HO (Home Office) and Legal Requirements Matrix Canada. This approach works well for a company with limited number of locations, but it becomes bulky and unworkable when the number of facilities grows.

When an enterprise has significant number of facilities and needs to reference in its corporate Manual numerous procedures including those controlled by its sites, we have another choice. We can develop a matrix to connect our Environmental Manual elements with the location-specific supporting documents. We will title this document Manual Reference Matrix and establish the following documentation reference structure.

Corporate ISO 14001 Environmental Manual element

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

Corporate Office (Dubai, UAE)

Miami, Florida (USA)

Cleveland, OH (USA)

Buenos Aires, (Argentina)

Port Williams (Chile)

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.

For examples of the Manual Reference Matrix, follow the links below.