Environmental Policy

Environmental Policy and ISO 14001 Guide

INDEX
1

1.1

Company Policy

Policy Statement

2

2.1

Responsibilities and Assistance

Organisational Arrangements

3

3.1

3.2

3.3

3.4

3.5

3.6

3.7

3.8

3.9

3.10

3.11

2.12

3.13

3.14

3.15

3.16

3.17

ISO Standards

Environmental Policy

Environmental Aspects

Legal & Other Requirements

Objectives and Targets

Environmental Management Programme

Structure and Responsibility

Training, Awareness and Competence

Communication

Environmental Management System Documentation

Document Control

Operational Control

Emergency Preparedness and Response

Monitoring and Measurement

Non-Conformance and Corrective and Preventative Action

Records

Environmental Management System Audit

Management Review

4

4.1

4.2

4.3

4.4

4.5

Audits

Environmental Management System Documentation

Internal Quality Audits

Third Party Assessment

What Will the Auditors Look For?

How to Personally Prepare For An Audit

1.1 Environmental Policy Statement

Sustainable economic development is key to the future welfare of the Company and society in general. To be sustainable, economic development must provide for the protection of human health and the world’s environmental resource base.  It is the Company’s policy that its operations and services accomplish their functions in a manner that provides responsibility for the protection and health of the environment.  With respect to health and environmental concerns, regulatory compliance represents a minimum. In seeking appropriate ways to protect health or the environment, the issue of cost alone does not preclude consideration of possible alternatives, and priorities are based on achieving the greatest anticipated practical benefits while striving for continuous improvement. The Company’s policy of responsibly protecting health and the environment is based on the following principles:

Protection of health and the environment is an important consideration in business decisions and is a Company wide responsibility.

  • Consideration of potential health and environmental effects as well as present and future regulatory requirements is an early, integral part of the planning and buying process.
  • Company services, processes and facilities are planned and operated to incorporate objectives and targets which are periodically reviewed so as to minimize the extent of the creation of waste and pollution, and any adverse impact on health or the environment.

Managers in all divisions are expected to accept their responsibility as an important priority and to commit the necessary resources. Employees at all levels are expected to carry out this responsibility within the context of their particular assignments and are to co-operate with Company objectives. The adoption and enforcement of responsible, effective and sound laws, regulations, policies and practices protecting health and the environment are in the Company’s interest. The Company participates constructively with government officials, interested private organisations and concerned members of the public towards these ends. Likewise, it is in our interests to provide timely and accurate information to our clients and the public alike on environmental matters involving the Company.

Roland Conn 

Managing Director

 

  1. List of Controlled Copy Holders
  • Managing Director
  • Director of Compliance and Business Development 

Notes on the distribution, amendment and control of this handbook

  1. The following rules apply to the distribution, amendment and control of this handbook.
  2. The issue and control of this handbook is the responsibility of the Director of Compliance and Business development.
  3. No other individual other than the Directors of the Company has the authority to issue or amend these documents without authorisation from the Director of Compliance and Business development.
  4. Controlled copies of this handbook are allocated to named individuals (as per the list of controlled copyholders) in order to ensure currency and control.
  5. Uncontrolled copies may be issued for internal use for the purposes of staff awareness training.
  6. Uncontrolled copies may be issued for external use for the purpose of procurement of new business, or as part of a tender submission.
  7. Uncontrolled copies of the office environmental sections may be available for reference locally for visitors and sub contractors.
  8. In all cases it is the responsibility of the Regional Health and Safety Representative to ensure that any amendments to this section are advised to those affected. 

3 International Standards Organization –Standard 14001

ISO14001 is a series of environmental management system standards developed by the International Organisation for Standardisation. They are generic standards and provide a framework for integrating environmental responsibility into every day business operations. ISO14001 also provides the world with a benchmark for auditing businesses to ensure that they are all working to the same goal of protecting the long-term future of the planet.

3.1 Environmental Policy

Management defines the Company’s environmental policy and ensures it is appropriate to the nature, scale and environmental impacts of its activities and or services. The policy includes a commitment to continual improvement, prevention of pollution and compliance with relevant environmental legislation and regulations and with other requirements to which the Company subscribes.

ISO provides the framework for setting and reviewing environmental objectives and targets. Management will document, implement and maintain policy, communicate it to all employees, and make policy available to the Company’s clients and public alike.

3.2 Environmental Aspects

Establish and maintain a procedure to identify the environmental aspects of the Company’s activities and services that we can control and influence to determine those aspects, which have or can have significant impacts upon the environment.

Ensure that the aspects identified with these significant impacts are considered in setting environmental objectives and keep this information up to date.

3.3 Legal & Other Requirements

Establish and maintain a procedure to identify, and have access to, legal and other requirements to which the Company subscribes, directly applicable to the aspects of its activities or services.

3.4 Objectives & Targets

Establish and maintain documented environmental objectives and targets at each relevant function and level within the Company. Consider the legal and other requirements, significant environmental aspects, technological options, financial, operational and business requirements. Ensure consistency with the environmental policy, including the commitment to prevent pollution.

3.5 Environmental Management Programme

  • Establish and maintain a programme for achieving objectives and targets.
  • Designate responsibility for achieving objectives and targets at each relevant organisational level.
  • Establish the means and time frame by which targets and objectives are to be achieved. If a project relates to a new development, and new or modified activities or services, the programme shall be amended where appropriate to ensure that environmental management applies to such projects.

3.6 Structure & Responsibility

Define, document and communicate roles, responsibilities and authorities to facilitate effective environmental management.

  • Provide resources essential to the implementation and control of the environmental management system, including personnel resources and specialised skills, technologies and financial resources.
  • Ensure that the environmental management system requirements are established, implemented and maintained in accordance with the Company policy and procedures as well as the standard.
  • Report on the performance of the environmental management system for review by the Company’s Directors and as a basis for improvement of the environmental management system.
  • Appoint specific management representatives who will have defined roles, responsibilities and the authority to ensure that the environmental management system requirements are established, implemented and maintained in accordance with the policies and procedures and the standard.
  • Representatives will report on the performance of the environmental management system to operating management for review, and as a basis for improvement of the policy and procedures.

3.7 Training, Awareness and Competence

  • Identify training needs and requirements of all personnel whose operational tasks may create a significant impact upon the environment.
  • Establish and maintain procedures and practices to make employees at all levels aware of the importance of conforming to the environmental policies and procedures, and the requirements of the Company’s environmental management system.
  • Make all employees aware of significant environmental impacts, actual or potential, of their working activities and the environmental benefits of improved personal performance.
  • Ensure all employees know their roles and responsibilities in achieving conformance to the environmental policy and with the requirements of the environmental management system including  emergency preparedness and response requirements; this may vary from site to site.
  • Managers are to ensure that all employees are aware of the local procedures.
  • Make clear the potential consequence of departure from specified assigned procedures.
  • Ensure that all personnel performing operational tasks, which can cause significant environmental impacts, are competent on the basis of appropriate education, training and/or experience.
  • Facilitate access to legal and other requirements to which the organisation subscribes, directly applicable to the environmental aspects of its activities and services.

3.8 Communication

  • Establish and maintain procedures for internal communication between various levels and divisions of the Company.
  • Receive, document and respond to relevant communications from external interested parties regarding environmental aspects and the environmental management system.
  • Consider the process for external communications on significant environmental aspects and record the decisions made by the Company in relation to these significant environmental aspects.

3.9 Environmental Management System Documentation

  • Establish and maintain information, in paper or electronic form, to describe the core elements of the management system and its interaction within the Company.
  • Describe the relationship between the Quality System and the Environmental System. Provide direction to related documentation.

3.10 Document Control

  • Establish and maintain procedures for controlling all documentation required by the standard. Ensure that documents can be located, periodically reviewed, and revised as required by the Company and approved by authorised officers of the Company.
  • Make available current versions of relevant documentation at all locations where operations essential to the effective functioning of the environmental management system are performed.
  • Promptly remove obsolete documents at all points of issue and points of use or otherwise assure against unintended use within the Company. Identify any obsolete documents retained for legal and / or knowledge preservation purposes.
  • Ensure documents are legible, dated (with dates of revision) and readily identifiable, maintained in an orderly manner, and retained for a specified period.
  • Establish and maintain procedures and responsibilities for the creation and modification of various types of documents.

3.11 Operation Control

  • Identify operations and activities that are associated with significant environmental aspects in line with the Company’s policies, procedures, objectives and targets.
  • Plan these activities, including industrial cleaning, office cleaning, ambulance deep cleaning and all other services provided by the Company in order to ensure that they are carried out under specified conditions.  This will be achieved by establishing and maintaining documented procedures to cover situations where their absence could lead to deviation from the Company’s environmental policy, procedures and the objectives and targets.
  • Establish and maintain procedures related to the identifiable significant environmental aspects of services and materials used by the Company, and communicating relevant procedures and requirements to suppliers and contractors alike.

3.12 Emergency Preparedness and Response

  • Establish and maintain procedures to identify potential for, and respond to, environmental accidents and emergency situations, and for preventing and mitigating the environmental aspects that may be associated with them.
  • Review and revise, where necessary, emergency preparedness and response procedures, in particular, after the occurrence of environmental accidents or emergency situations.
  • Periodically test such procedures, where practicable.

3.13 Monitoring & Measurement

  • Establish and maintain documented procedures to monitor and measure, on a regular basis, the key characteristics of operations and activities that can have a significant impact upon the environment.
  • Record information to track performance and implement audits that verify conformance to objectives.
  • Calibrate and maintain monitoring equipment where necessary and retain records according to established Company procedures.
  • Establish and maintain documented procedures for periodically evaluating compliance with relevant environmental legislation and regulations.
  • Identify and have access to legal and other requirements directly applicable to the environmental aspects of services provided and materials used.

3.14 Non-Conformance and Corrective & Preventative Action

  • Establish and maintain procedures for defining responsibility and authority for handling and investigating non-conformance, taking action to mitigate any impacts and their causes, and initiating and completing corrective actions as required.
  • Assure corrective or preventative action to eliminate the causes of actual or potential non-conformances appropriate to the magnitude of problems and commensurate with the environmental impacts encountered.
  • Implement and record any changes in the documented procedures resulting from corrective and preventative action.

3.15 Records

  • Establish and maintain documented procedures for the identification, maintenance and disposition of environmental records including training records and the results of audits and reviews.
  • Ensure environmental records are legible, identifiable and traceable to the activity or service involved.
  • Store and maintain environmental records in such a way that they are readily retrievable and protected against damage, deterioration or loss.
  • Establish and record retention times.
  • Maintain records, as appropriate, to demonstrate conformance to the requirements of the standard.

3.16 Environmental Management System Audit

  • Establish and maintain programmes and procedures for periodic environmental management systems audits.
  • Determine whether or not the environmental management system conforms to planned arrangements for environmental management, including the requirements of this standard.
  • Determine if the system has been properly implemented and maintained.
  • Provide information on the results to management.
  • Base audit programme and schedule on the environmental importance of the activity concerned and the result of previous audits.
  • Cover the audit scope, frequency and methodologies as well as the responsibilities and requirements for conducting audits and reporting results.

3.17 Management Review

At intervals it determines, senior management reviews the environment management system to ensure its continuing suitability, adequacy and effectiveness. by:

Ensureing necessary information is collected to allow management to carry out this evaluation. This review shall be fully documented.

Addressing the possible need for changes to policy, objectives and other elements of the environmental management system in light of the audit results, changing circumstances and the commitment to continual improvement.

  1. Audits

4.1 Environmental Management System Documentation

Documentation of the Company’s Environmental System is a requirement of ISO14001, however, unlike ISO9002, it does not have to be in the form of a manual.

Environmental system documentation integrated and shared with the documentation may include:

  • Process information
  • Organisational Charts
  • Operational Procedures
  • Operational Emergency Plans and Procedures
  • Works Instructions
  • Records / Documents

Environmental procedures and works instructions may be maintained and stored in electronic form or in hard copy.

4.2 Internal Quality Audits

Internal audits of the Company’s Environmental Systems are required by ISO14001 to ensure that the system is performing as planned by the Company. The Company must identify and train internal auditors. The internal audits verify that the Company employees work to the specified documented procedures.

Internal audits are not surprise visits. They are conducted according to a published schedule. Each division, region, contract or site to be audited will receive notification of the time, date and scope of the internal audit. Internal audit frequencies depend upon the importance of the service or contract being audited.

Internal auditors must be independent of the division, region, contract or site being audited. Persons conducting the audits should be in a position to do so impartially and objectively. The internal audits will verify that:

  • Environmental systems procedures are in place
  • Procedures are followed
  • Employees are trained and competent in their use of the Company’s procedures
  • Results are documented

At the conclusion of the internal audit, a summary will be prepared and presented to the Company’s senior management. Management is responsible for following up on the implementation and effectiveness of corrective actions. Records of these management reviews must be maintained.

4.3 Third Party Assessment

The Company will be scheduled for an ISO14001 audit by an accredited third-party assessment organisation such as the British Standards Institute. The purpose of this audit is to independently verify that the Company’s Environmental System conforms to all of the ISO14001 standards.

Prior to scheduled divisional, regional, contract or site visitation, the auditors will review the Company’s environmental management system documentation to verify that the system satisfies the ISO14001 standards.  Following the document review, the auditors will assess conformance to the environmental management system:

  • Do employees know the Company’s environmental policy?
  • Do they know and have access to procedures and works instructions?
  • Are procedures and work instructions being followed?

Anyone and everyone may get an opportunity to demonstrate their knowledge of and conformance to the ISO14001 standards.

A minor non-conformance may only require evidence of corrective action. A major non-conformance will require on-site verification by the third-party auditors at a later date. Subsequent external surveillance audits will continue on a regular basis.

4.4 What Will Auditors Look For?

  • Employee knowledge of the Company’s environmental policy
  • Employee knowledge, access and adherence to procedures and works instructions
  • Employee knowledge of significant environmental aspects specific to their operation or contract.
  • Documented objectives and targets for how the Company will strive to continually improve performance on significant environmental aspects.
  • Training Records
  • Monitoring and measuring of significant environmental aspects.
  • Emergency preparedness and response procedures
  • Documentation control procedures.

4.5 How to Personally Prepare for an Audit

You should:

  • Know the Company’s environmental policy
  • Know the environmental aspects of your Division, Region, Contract or Site, and process, and those which are significant
  • Know your objectives and targets for continual improvement
  • Know and have access to the legal requirements and other environmental regulations that apply to your plant and process
  • Know your job and how to access the most current environmental procedures and work instructions that affect you
  • Know the system to introduce or change documents
  • Answer only questions directed to you –be factual and brief. Think before you answer. Do not elaborate or lead conversation
  • Remember, the auditor is assessing your sites environmental system – NOT YOU.