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Environmental management systems

Environmental policy
John Stans & Maarten A. Siebel
UNESCO - IHE, Delft, The Netherlands

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CONTENTS

4. ENVIRONMENTAL MANAGEMENT SYSTEMS 1

4.1. PURPOSE AND BENEFITS OF AN EMS 1

4.1.1 INTRODUCTION 1
4.1.2 INTERNATIONAL DEVELOPMENTS SINCE THE 1970'S 2
4.1.3 ENVIRONMENTAL MANAGEMENT 3
4.1.3.1 Finance 4
4.1.3.2 Stakeholder pressure, awareness, image, reputation 5
4.1.3.3 Competitiveness 6
4.1.3.4 Legislation and enforcement 8
4.1.4 ENVIRONMENTAL MANAGEMENT SYSTEMS 8
4.1.5 THE E-EFFICIENCY TOOL – TO GET A HANDS-ON FEELING 9

4.2. BASIC CONCEPTS OF ISO 14001 11

4.2.1 ISO 14001: STRUCTURE AND BASIC CONCEPTS 11
4.2.1.1 Structure 11
4.2.1.2 The Deming Cycle 12
4.2.1.3 The contents of ISO 14001 13
4.2.1.4 Basic concepts in ISO 14001 15
4.2.1.5 Summary of Procedures, Documents and Records
referred to in ISO 14001 23

4.3. EMS REQUIREMENTS (NO LECTURE NOTES ON THIS CHAPTER)

4.4. ENVIRONMENTAL POLICY 26

4.4.1 INTRODUCTION 26
4.4.2 A LOOK AT ISO 14001 27
4.4.2.1 What ISO 14001 requires you to do 27
4.4.2.2 Interpretation 28
4.4.2.3 Documents and records 29
4.4.3 PRACTICAL GUIDANCE 29
4.4.3.1 Developing the policy 29
4.4.3.2 The content of the policy 30
4.4.3.3 Publicising the Environmental Policy 32
4.4.3.4 Implementing the policy 33
4.4.3.5 Revising and improving the policy 33
4.4.4 ENVIRONMENTAL POLICY: EXERCISE 34
4.4.4.1 Exercise: Environmental Policy 34
4.4.4.2 Exercise: Emergency Preparedness And Response 36
4.4.4.3 Exercise: Environmental Auditing 37

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 4.5. THE INITIAL ENVIRONMENTAL REVIEW 39
4.5.1 THE INITIAL ENVIRONMENTAL REVIEW 39
4.5.1.1 What is the Initial Environmental Review? 39
4.5.1.2 Methodology 40
4.5.1.3 Carrying out the review 44
4.5.1.4 Reporting 46
4.5.1.5 Reference manual 47
4.5.1.6 A basis for the Environmental Policy 48
4.5.2 INITIAL ENVIRONMENTAL REVIEW EXERCISE 49
4.5.2.1 Case Study 49
4.5.2.2 Exercise: Identifying Environmental Aspects and
Impacts 54
4.5.3 INITIAL ENVIRONMENTAL REVIEW PROTOCOL 57

4.6. ENVIRONMENTAL AUDITING EXERCISE 71

4.6.1 EXERCISE: ENVIRONMENTAL AUDITING 71

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4.4. ENVIRONMENTAL POLICY

4.4.1 INTRODUCTION
The Environmental Policy and the Environmental Action Plan of an enterprise
express the first principle for environmental management of the ICC Business Charter for
Sustainable Development: “To recognize environmental management as among the
highest corporate priorities and as a key determinant to sustainable development; to
establish policies, programmes and practices for conducting operations in an
environmentally sound manner”.

Effective environmental management is based on a step-by-step approach, beginning

with a realistic and active Environmental Policy. An Environmental Policy is a statement
by an organisation of its principles and intentions in relation to its overall
environmental performance. It establishes the overall sense of direction, providing a
framework for action and for the development of more specific environmental objectives
and targets.

For this reason, the development of an Environmental Policy should be a carefully

considered process. Its importance is underlined further because the Environmental
Policy:

• is a public statement of the enterprise’s commitment

• provides visible evidence of the support of top management
• may have far-reaching business implications
• is usually a (relatively) long-lived document.

The Environmental Policy acts as the driving force behind all of the enterprise’s activities
in the environmental field, and can have far-reaching business implications for the future
direction of the enterprise. It should be integrated into the enterprise’s overall business
strategy and should also be compatible with other organisational policies such as Quality
or Occupational Health and Safety. It must, therefore, be initiated, developed and actively
supported at the highest levels within the organisation.

The responsibility for developing the Environmental Policy should, therefore, rest with
those at the very top of the enterprise (e.g. the Board of Directors or other governing
body) and it should be signed by the Chairman, Chief Executive or similar top manager
as evidence of commitment. Management will then be responsible for implementing the
policy, but continuing support from the top of the enterprise will be needed during the
further development of the environmental management system and for the organisational
changes which will result from its implementation (see e-efficiency tool, month 2).

As well as being the first public step into the environmental arena, the publishing of the
policy statement can be an effective tool within the enterprise itself. It provides an ideal
opportunity to explain to all of the staff the environmental direction of the enterprise and
the reasons why this is necessary, to motivate them and encourage their involvement
and cooperation.

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By way of introduction to the possible contents of an Environmental Policy it is important
to recognise that the environmental policies of individual enterprises are as varied as the
enterprises themselves, and take a number of different forms. The following elements or
a combination thereof to an Environmental Policy can be found amongst the published
statements available:

• A goal or vision, such as being among the leaders in environmental best practice;
• A statement focusing on environmental protection or sustainable development;
• A set of core values such as care for the environment;
• A number of guiding principles such as reducing waste or replacing hazardous
chemicals;
• Support for a specific international environmental initiative.
The sixteen principles for environmental management contained in the ICC Business
Charter for Sustainable Development may be used as the starting point for the
development of an Environmental Policy which is specific to the needs and character of
an enterprise.

4.4.2 A LOOK AT ISO 14001

4.4.2.1 What ISO 14001 requires you to do

• Have top management define the organisation’s environmental policy;
• Ensure that it contains a commitment to:
• continual improvement,
• prevention of pollution,
• compliance with relevant environmental legislation and
• compliance with other requirements to which the organisation subscribes.
• Ensure that it:
• is appropriate to the nature, scale and environmental impacts of its activities,
products and services and
• provides a framework for setting and reviewing environmental objectives and
targets.
• Ensure that it is:
• documented,
• communicated to all employees and
• available to the public.
• Ensure that it is:
• implemented and
• maintained.

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4.4.2.2 Interpretation
The organisation’s top management must define and document its environmental policy.
This may be within the context of the environmental policy created by any broader
corporate body. However, where a corporate environmental policy statement is not
specifically relevant to site operations or its immediate environmental envelope, a
separate environmental policy statement will be required.

Top management is considered to be the highest level with executive responsibility in the
organisation being certified. It may be the corporate management but, in the case of
certification of a site, top management is the management level responsible for site
operations.

The environmental policy statement needs not be signed if it is included in an officially

distributed document (e.g. the environmental manual). It should be clear when the
environmental policy statement has been established (e.g. by showing a date).

Site management should have taken the necessary steps to define and implement
relevant environmental policies.

Publicly available means available on request, not necessarily through active distribution.
There may also be a reasonable charge involved. The fact that the policy is publicly
available does not need to be stated in the policy itself.

The policy should take advantage of the identification of the significant environmental
aspects and the identification of the relevant legislation and regulations, as well as of the
knowledge of other requirements the organisation has chosen to comply with. Therefore
the policy should not be finalised before these analyses have taken place.

There is no blue print for a good environmental policy. One can use the experience with
environmental policy statements and take into account that ISO 14001 requires to write a
policy which is both appropriate to the nature, scale and impacts of your organisation and
which provides a framework for setting and reviewing objectives.

The following sequence would be helpful:

• A short description of the type of business you are in, using a limited number of
sentences,
• A statement on the organisation’s core values and beliefs linked to its vision on
environmental concerns,
• Expressions on the required commitments, and
• A listing of broad but concrete environmental objectives for the longer term (e.g. for
the next few years or even longer).

The development of a draft text involving several departments and layers in the
organisation would increase commitment and team ownership. The draft text should be
discussed in the organisation and also be tested to see whether the policy is not only
acceptable but also understandable. If it is not, it will not be accepted within the
organisation. Another check should be whether all the statements in the policy can really
be implemented and fully performed in the indicated time span.

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4.4.2.3 Documents and records
The policy itself is a naturally a required document. Moreover, there needs to be
evidence that top management has been involved in setting and approving the policy.
This could be through a signature under the environmental policy document or through
minutes of meetings where the policy has been discussed or equivalent means.

4.4.3 PRACTICAL GUIDANCE

4.4.3.1 Developing the policy

The Environmental Policy is based in part on the findings and conclusions of the Initial
Environmental Review. A number of important factors need to be considered. These are
essential to ensure that the policy relates not only to the enterprise’s individual needs
and ideas, but is also in line with recognised environmental good practice and any
relevant industry-specific guidelines. If the enterprise is interested in working towards
certification of its environmental management system (now or in the future) then it may
also be important to ensure that the policy will conform to the requirements of such a
standard.

Once a policy has been developed and published, the enterprise’s environmental
performance will be judged against it. It is, therefore, worthwhile spending time to ensure
that the policy provides an exact statement of the enterprise’s objectives and can be
used as a basis for the development of targets and the environmental programme.

Other important sources of information for input into the Environmental Policy
development process include the following:

• The results of the Initial Environmental review;

• The enterprise’s values and beliefs, such as its (desired) relationship with its
employees, the local community and the general public;
• The enterprise’s business strategy and strategic plan: elements relating to the
enterprise’s (environmental) direction, opportunities and risks, medium and long term
planning including internal and external limits, and opportunities in capabilities and
resources;
• Any existing statement on environmental aspects: mission statements, old policies,
previous statements of commitment in internal/external reports;
• Other policies in existence: such as occupational health, safety, quality;
• The views of stakeholders (shareholders, staff) and other interested parties;
• Legislation and regulations;
• Written standards: available recognised standards for environmental management
systems which include prescribed elements for Environmental Policy statements;
• General statements of environmental principles: e.g. from government, public bodies,
industry associations, which are relevant to the individual enterprise;
• Other codes to which the enterprise subscribes;
• Examples of Environmental Policy statements: from similar companies or enterprises;

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• Clear definition of the geographical and organisational boundaries of the policy:
which countries/regions and which sites, departments or activities are to covered by
the policy; and
• Any specific local or regional conditions.

4.4.3.2 The content of the policy

An Environmental Policy should clearly delineate the environmental areas to be
addressed by the enterprise or organisation and should be relevant to its activities,
products and/or services. The policy may address very broad aspects of the enterprise’s
activities (such as investments) as well as more specific aspects (such as waste
reduction), depending on the nature of those activities. Many environmental policies also
include aspects of occupational health and safety including statements regarding the
working environment.
Some ideas for the content and wording of statements of commitment in an
Environmental Policy are given below. However, these should not be copied as such and
should always be placed in context. The policy must be appropriate to the individual
enterprise. It may be as brief as one sentence or as long as 10 pages.
General principles:
• Define extent of environmental responsibility (customers, suppliers, staff etc.);
• Ensure minimum of compliance with legislation and strive for best practice;
• Provide for development of corporate standards in the absence of legislation;
• Establish systems to ensure full control of environmental situation (impacts and
risks);
• Make commitment to continual improvement in environmental performance (step by
step)
• Make commitment to cleaner production (and prevention of pollution if compliance
with ISO 14001 is intended)
• Develop environmental performance evaluation procedures and indicators
• Embody life cycle thinking
• Work towards the achievement of sustainable development
• Commit to development and implementation of an environmental management
system
• Provide adequate resources for environmental management
Strategy and Planning:
• Consider environmental issues in investment policy and practice
• Minimise the environmental impacts of new developments through the use of
environmental management procedures and environmental impact assessment in
strategic planning, and project definition and implementation
• Influence suppliers in order to ensure that they contribute to the realisation of the
policy

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Specific policy goals:
• Support for the use of best available technology and management practices
• Promotion of appropriate environmental legislation and requirements
• Cleaner Production
• Reduction in consumption of resources (materials, water, energy)
• Prevention of pollution
• Reduction or elimination of (specific) emissions to the environment
• Commitment to recovery and recycling, as opposed to disposal where feasible
• Reduction in the use of hazardous substances and use of alternatives where possible
• Reduction in packaging
Compliance:
• Cooperation with regulatory authorities
• Compliance with environmental regulations in all areas of operations
• Compliance with local or corporate environmental standards whichever are the most
stringent
• Compliance with the principles set down by the industry association or the ICC
Business Charter for Sustainable Development
Products:
• Consider international restrictions and client requirements
• Design products in such a way as to minimise their environmental aspects and
impacts in production, use and disposal
• Consider environmental aspects in the design and use of packaging materials
Training and Communication:
• Train staff in the environmental aspects of their work
• Share environmental experience
• Advise customers and distributors on environmental aspects of the use,
transportation, storage and disposal of products
• Encourage open dialogue with employees, customers, stakeholders and the public
about environmental performance.
Worker protection:
• Execute operations in such a manner that the health and safety of employees are not
jeopardised.
As it is written for a wide audience, the style of the Environmental Policy statement also
requires consideration. It should be concise. The information should be clearly formatted
and should be written in plain language that is accessible to and can be understood by
all interested parties. The use of jargon, both environmental and technical, should be
avoided. Use of statements such as “environmentally-friendly” may result in a loss of
credibility as all of an enterprise’s activities have some sort of environmental impact.

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Finally, the draft policy will need to be reviewed before publication. As the foundation
stone for the EMS, senior managers will need to ensure that the policy reflects realistic
environmental objectives for the enterprise, balancing the proposed improvements in
environmental performance against technological, financial, operational and business
requirements and constraints. It may also be useful to have the draft version reviewed by
staff from different levels in the organisation, to ensure that the messages are clear and
understood.

4.4.3.3 Publicising the Environmental Policy

It is important to ensure that the Environmental Policy becomes widely known and
understood throughout the enterprise, and a version for external circulation should be
prepared as well. The publishing and distribution of the policy statement can provide an
ideal opportunity for management to outline the underlying reasons for developing an
environmental strategy (for example, in terms of business security, opportunities and risk
reduction) and to explain to the staff how it will be implemented within the enterprise.
This will help to encourage, at all levels, full commitment to achieving the environmental
goals.

Internal presentation of the policy should precede the formal external publication. This
will give staff the chance to familiarise themselves with the policy and to have questions
answered. There are a number of ways of doing this (a combination of these may be
necessary):

• Send a copy of the policy, together with a covering letter from the head of the
organisation, to all members of staff
• Print the policy in the enterprise’s magazine or newspaper, together with an article on
the organisation’s approach to environmental management
• Produce the policy in poster format for all notice boards (including staff canteen etc.)
• Include discussion of the policy and its implications on the agenda for management
and staff meetings (important for receiving feedback)
• Include the Environmental Policy in introduction training courses for all new
employees.
The publication of the policy will inevitably lead to questions from the staff such as “how
will this affect me and my work”. The opportunity to begin an on-going dialogue with staff
concerning environmental aspects should not be missed. Input and suggestions from
staff towards meeting the policy objectives can provide the basis for motivating staff and
encouraging their cooperation during the implementation stage of the environmental
management system.

Externally, there are many ways to publicise the policy, largely depending on the size
and resources of the enterprise. A brochure to give to interested parties, including the
environmental authorities, members of the local community etc., should be the minimum.
Many companies also print their Environmental Policy statement in their annual
(environmental) report. Of course, it is also possible to pay for commercial advertising if
this is seen to be of benefit to the individual enterprise.

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4.4.3.4 Implementing the policy
There is sometimes a danger that the publication of the Environmental Policy statement
is seen as an end in itself, rather than the starting point for the development of the EMS.
Once the policy is in place it can be used, together with the results of the Initial
Environment Review, to develop detailed objectives and targets. This translation of the
policy into action will take the form of an Environmental Programme or Action Plan, which
will define priorities, identify employee responsibilities, allocate resources and set out
measurable targets and goals. However, the Environmental Policy can only be
implemented if:

• Responsibilities are allocated and the necessary organisational measures are in

place to manage the subsequent phases
• Managers accept their environmental responsibilities and in turn ensure that all
employees understand their own obligations
• Managers ensure that all staff have the knowledge and training to meet the
environmental requirements of their position and duties.

4.4.3.5 Revising and improving the policy

In most enterprises, the Environmental Policy statement is a relatively long-lived
document, remaining unchanged for two or three years or longer. However, it is
necessary to ensure the continuing suitability of the policy on a regular basis. Changes
might be necessary as a result of, for example:

• changing market situation;

• changes in processes, products, etc.;
• a merger with or acquisition of another enterprise;
• the need to conform to an EMS standard (for certification);
• the views of the public or stakeholders.
It is important to include evaluation of the policy in the overall management review of
the EMS and to revise and adjust it as necessary, also in view of the commitment to
continual improvement.

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