Ensuring Environmental Compliance & Operational Excellence: A Guide to Documented Information & Operational Planning in ISO 14001

An organization should ensure that its operations and associated processes are conducted in a controlled way in order to fulfil the commitments of its environmental policy, achieve its environmental objectives and manage its significant environmental aspects, compliance obligations and its risks and opportunities that need to be addressed. To plan for effective and efficient operational controls, the organization should determine where such controls are needed and for what purpose. It should establish the types and levels of controls that meet the organization’s needs. The operational controls selected should be maintained and evaluated periodically for their continuing effectiveness.

The organization shall control planned changes and review the consequences of unintended changes, taking action to mitigate any adverse effects, as necessary.

The organization shall ensure that outsourced processes are controlled or influenced. The type and extent of control or influence to be applied to the process(es) shall be defined within the environmental management system.

Consistent with the life cycle perspective, the organization shall:

1. Establish controls, as appropriate, to ensure that its environmental requirement(s) is (are) addressed in the design and development process for the product or service, considering each stage of its life cycle.
2. Determine its environmental requirement(s) for the procurement of products and services. as appropriate.
3. Communicate its relevant environmental requirement(s) to external providers, including contractors.
4. Consider the need to provide information about potential significant environmental impacts associated with the transportation or delivery, use, end-of-life treatment and final disposal of its products and services.

The organization shall maintain documented information to the extent necessary to have confidence that the processes have been carried out as planned.

When determining necessary controls, or considering changes to existing controls, consideration should be given to risks and opportunities that need to be addressed, and to any unintended consequences that can result. The organization should control planned changes and review the consequences of unintended changes, taking action to mitigate any adverse effects, as necessary.

When considering controls for adverse environmental impacts, the organization can refer to the following hierarchy:

• Elimination, such as banning the use of PCBs, CFCs, etc.
• Substitution, such as change of solvent-based paint to water-based paint.
• Engineering controls, such as emission controls, abatement technology, etc.
• Administrative controls, such as procedures, visual controls, work instructions, Safety Data Sheets (SDS/MSDS/CSDS), etc.

To avoid deviations that can occur from the environmental policy, environmental objectives and compliance obligations, documented information can be developed, as appropriate, to explain, for example:

• A specific sequence of activities that should be carried out.
• Necessary qualifications of the personnel involved, including any workmanship required.
• Key variables that should be kept within certain limits, e.g. time, physical, biological.
• Characteristics of the materials to be used.
• Characteristics of the infrastructure to be used.
• Characteristics of the products resulting from the process.