ISO 14000 – Common Manuals for large Corporations.

While numerous successful models of ISO 14001 Environmental management systems have been developed and are being used in various industries, approaches to documenting top level environmental management systems for multi-location enterprises are limited at best. This article discusses a method for establishing an ISO 14001 top-level documentation structure that allows a business with multiple facilities to use common Environmental Management System Manual. This model significantly improves consistency of the corporate message regarding Environmental policies, while reducing the number of EMS documents within the organization’s Environmental Management System.

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 reality, these solutions do not provide for a consistent representation of the organization’s position on Environmental issues. The first approach, when a copy of the home office Environmental Manual is used, techniques for controlling local Environmental Manuals as a rule are not determined. Differences in the corporate Manual and the site’s Environmental Manual are because the corporate office Manuals are managed by the home office, while site’s Manuals are controlled by individual sites.

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.

Those companies that adhere to the policy of maintaining a consistent corporate message regarding their position on Environmental issues will definitely experience a gap if they use methods that we discussed above.

One of our large EMS customers demonstrated this point well. The corporate ISO 14001 Environmental Manual addressed majority of the requirements of the standard and referenced appropriate regulations. At the same time, one of their US locations did not define their Environmental policy, Mexico facility did not reference local legal requirements, yet their European site failed to document their Environmental programs all together!

Summarizing my EMS auditing and consulting experiences, I am convinced that these approaches to design of the corporate Environmental Manual and sites’ Manuals do not provide a solid consistent way to document organization’s Environmental Management System and Manuals.

To solve this problem, let’s review an ISO 14001 Environmental Manual model, specifically supporting document reference structure. As a common practice, an Environmental Manual references supporting documents within the text of the Manual. For example, clause 4.3.1, Environmental aspects may read: Environmental Consultants Inc. has established, implemented and maintains Environmental Aspect Procedure to identify the environmental aspects of its activities, products and services and Significant Environmental Aspect Matrix to determine and document those aspects that have or can have significant impacts on the environment.

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.

However, what if our locations need to use different environmental aspects, programs and other site-specific Environmental Management System processes? If we use the model above and want to keep a common ISO 14001 Environmental Manual, we have to reference in the Manual corresponding documents for all locations which may not be practical. Below we will explore how a corporate Environmental Manual can practically reference location-specific documents to support commitments of the company’s common ISO 14001 Environmental Manual.

The same document reference structure as for a single-location company that we discussed above, can be used if the number of locations is small, let’s say two or three. In this case, clause 4.3.1, Environmental aspects may read: Environmental Consultants Inc. has established, implemented and maintains Environmental Aspect Procedure to identify the environmental aspects of its activities, products and services and Significant Environmental Aspect Matrix HO and Significant Environmental Aspect Matrix WA to determine and document those aspects that have or can have significant impacts on the environment. This example shows references to the common Environmental Aspect Procedure and site-specific Significant Environmental Aspect Matrixes for the Home Office (HO) and the Washington (WA) locations. While this model works well for a limited number of facilities, it becomes impractical when the number of locations is significant.

If we need to work with a company that has significant number or offices and wishes to reference in the Environmental Manual procedures controlled by its sites, we may take a different approach. For example, we can prepare a matrix to associate the corporate Environmental Manual clauses with the site-specific procedures. We can name this tool Manual Reference Matrix and consider the following reference model:

Corporate ISO 14001 Environmental Manual clause

Manual Reference Matrix Table of Contents (ToC)

Location Manual Reference Matrix

Corresponding site-specific 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

Home Office (San Francisco, California, USA)

Toronto (Canada)

St. Petersburg (Russia)

Singapore

Tokyo (Japan)

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.

A Manual Reference Matrix may be formatted as a three-column form. The first two columns are titled Corporate EMS Section No. and Corporate EMS References; the third column is called Location procedures. For the element 4.3.1, for example, the Matrix indicates that our Manual Reference Matrix references Significant Environmental Aspect Matrix HO for the corporate office and the Significant Environmental Aspect Matrix WA for the Washington facility.

Looking for samples of Manual Reference Matrix for ISO 14001 Ems and other manuals? Check links below.

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