Make Money OnlineStart generating your online income now!

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.

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 practice, neither one of these approaches produce a consistent result. In the 1st instance when a modified Environmental Manual is used for a location, methods for updating local Environmental Manuals are not defined. This disconnect arises from the fact that the corporate office manuals are controlled by the home office, while local Environmental Manuals are facilities’ responsibility.

In the case of companies choosing their facilities to develop their own ISO 14001 Manuals, discrepancies in numerous Environmental Manuals result in visible differences between the home office and facilities’ Environmental Manuals and therefore commitments to environmental issues.

If an organization wishes to deliver a consistent message regarding its Environmental policies and their position on prevention of pollution, the deficiencies of discussed methods become obvious.

One of Quality Works’ EMS clients illustrated this deficiency. The home office Manual documented majority of the applicable requirements. At the same time, their facility in Canada did not document Environmental policy, another missed a commitment to prevention of pollution, yet the third one forgot to document their EMS communication procedure at all!

As we can see, both approaches to creation of location’s ISO 14001 Environmental Manuals as copies of the corporate Manuals or independent Manuals do not appear to be practical. Besides, if a company has already spent time on developing an Environmental Manual, why should another employee in the same organization spent more time to create a similar or duplicate document?

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

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.

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.

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 clause

Manual Reference Matrix Table of Contents (ToC)

Site-specific Manual Reference Matrix

Facility document

The Manual Reference Matrix is simply a list of all facilities and their Manual Reference Matrixes, as shown in the example below:

Manual Reference Matrix Table of Contents

Corporate Office (Dubai, UAE)

Miami, Florida (USA)

Springfield, IL (USA)

Aspen, Colorado (USA)

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).

Let’s say we need to locate a Communication Procedure for our Singapore plant. When we find this clause in our Manual Reference Matrix table of contents, we actually will connect to the location’s Manual Reference Matrix. Finding the corresponding clause number in the site’s Manual Reference Matrix, we will find a site-specific procedure title that addresses our clause of the Environmental Manual.

Our experience shows that a Manual Reference Matrix works well as a 3-column form with the 1st column titled Corp. Manual Section, the 2nd column Corp. References, and the 3rd column called Site References. For the element 4.5.1, for example, the St. Petersburg’s Matrix indicates that Manual references Key Characteristics Matrix HO for the home office and Key Characteristics Matrix SP for the St. Petersburg site.

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.