ISO 14001:2015 Clause 9 Performance evaluation
ISO 14001:2015 Clause 9 Performance evaluation is all about measuring and evaluating your EMS to ensure that it is effective and it helps you to continually improve. You will need to consider what should be measured, the methods employed and when data should be analyzed and reported on. As a general recommendation, organizations should determine what information they need to evaluate environmental performance and effectiveness. Once the EMS is implemented, ISO 14001 requires permanent monitoring of the system as well as periodic reviews to:
- evaluate the effectiveness of the implemented EMS
- objectively evaluate how well the minimal requirements of the standard are fulfilled
- verify the extent to which the organizational, stakeholder and legal requirements have been met;
- review the suitability, adequacy, effectiveness, and efficiency of the EMS;
- demonstrate that planning has been successfully implemented;
- assess the performance of processes;
- determine the need or opportunities for improvements within the environmental management system.
Internal audits will need to be carried out, and there are certain “audit criteria” that are defined to ensure that the results of these audits are reported to relevant management. Finally, management reviews will need to be carried out and “documented information” must be kept as evidence.
Clause 9 Performance evaluation has three subclause
- 9.1 Monitoring, measurement, analysis and evaluation
- 9.2 Internal audit
- 9.3 Management Review
9.1 Monitoring, measurement, analysis and evaluation
The organization must monitor, measure, analyze and evaluate its environmental performance. It must determine what needs to be monitored and measured and as applicable the methods for monitoring, measurement, analysis, and evaluation to ensure valid results. It must determine the criteria against which environmental‘ performance and its appropriate indicators will be evaluated. It must also determine when the monitoring and measuring shall be performed and when the results from monitoring and measurement will be analyzed and evaluated. The organization must ensure that calibrated or verified monitoring and measurement equipment is used and maintained, as appropriate. The organization must also evaluate its environmental performance and the effectiveness of the environmental management system. The organization must communicate relevant environmental performance information both internally and externally, as identified in its communication processes and as required by its compliance obligations. The organization must retain appropriate documented information as evidence of the monitoring, measurement analysis, and evaluation results.
As per Annex A (Guidance on the use of ISO 14001:2015 standard) of ISO 14001:2015 standard it further explains:
When determining what should be monitored and measured, In addition to progress on environmental objectives, the organization should take into account its significant environmental aspects, compliance obligations, and operational controls. The methods used by the organization to monitor and measure, analyze and evaluate should be defined in the environmental management system, in order to ensure that:
- the timing of monitoring and measurement is coordinated with the need for analysis and evaluation results;
- the results of monitoring and measurement are reliable, reproducible and traceable;
- the analysis and evaluation are reliable and reproducible and enable the organization to report trends.
The environmental performance analysis and evaluation results should be reported to those with responsibility and authority to initiate appropriate action.
An EMS without effective monitoring and measurement processes are like driving at night without the headlights on — you know that you are moving but you can’t tell where you are going. Monitoring in the sense of ISO 14001 means that the organization should check, review, inspect and observe its planned activities to ensure that they are occurring as intended. Monitoring generally means operating processes that can check whether something is happening as intended or planned. In some respects auditing processes address this, but also operational control procedures will apply. Thus if an operational control states that housekeeping audits will occur twice weekly then this is a monitoring process, i.e. the site is checked weekly for ‘good housekeeping practices’. This could also involve ‘visual’ checking of the integrity of bunding around solvent storage tanks for example. Measurement tends to mean that the size or magnitude of an event is measured, calculated or estimated with a numerical value assigned. This could include procedures for weighing wastes sent to landfill; the amount of gas or electricity consumed per week, measuring noise levels at the site boundary, etc. Additionally, any equipment used to calculate or estimate such numbers should be suitably calibrated so that a high level of confidence is gained that the numbers are indeed a true representation of the facts. Monitoring and measurement help you:
- evaluate environmental performance;
- analyze the root causes of problems;
- assess compliance with legal requirements;
- identify areas requiring corrective action, and,
- improve performance and increase efficiency.
In short, monitoring and measurement help you manage your organization better. The results of pollution prevention and other efforts are easier to demonstrate when current and reliable data are available. These data can help you demonstrate the value of the EMS to top management. Your organization should develop means to:
- Monitor key characteristics of operations and activities that can have significant environmental impacts and/or compliance consequences;
- Track performance (including your progress in achieving objectives and targets);
- Calibrate and maintain monitoring equipment; and,
- Through internal audits, periodically evaluate your compliance with applicable laws and regulations.
Example of Links between Significant Aspects, Objectives, Operational Controls, and Monitoring and Measurement
|Significant Aspect||Objective||Operational Control||Monitoring and Measurement|
|Anti-corrosive paint X||Maintain compliance||
|Non-abated emission of VOCs||Reduce VOC emissions||VOC – reduction EMP||
|Solid waste from the unmasking process||Investigate the potential for reduction||Solid waste reduction EMP||
Monitoring Key Characteristics
Many management theorists endorse the concept of the “vital few” — that is, that a limited number of factors can have a substantial impact on the outcome of a process. The key is to figure out what those factors are and how to measure them. Most effective environmental monitoring and measurement systems use a combination of process and outcome measures. Select a combination of process and outcome measures that are right for your organization.
- Outcome measures look at the results of a process or activity, such as the amount of waste generated or the number of spills that took place.
- Process measures look at “upstream” factors, such as the amount of paint used per unit of product or the number of employees trained on a topic.
To have a successful EMS, it is important to determine program measurement criteria. Determining measurement criteria, also called performance indicators, will help you evaluate the success of your overall EMS program. Performance indicators measure overall success, while key characteristic indicators measure progress against EMS objectives for specific SEAs.These performance indicators focus on how well the overall system for improving environmental management is functioning. Select performance indicators that will help you and your employees decide whether success has been achieved or whether improvement in procedures needs to be made. It is easier for management and staff to understand how things are going if they have benchmarked as guidelines. You will need performance indicators that describe how well your environmental policy is being implemented. In addition, you will need performance indicators for all of the various components of your EMS. The measurement criteria selected for each component of your EMS will probably be different. For example, how will you measure the success of communication, documentation, stakeholder outreach, or training programs?
One approach is to measure the actions, for example, the number of meetings held with stakeholders, the number of documents created, number of employees trained, or the number of hours of training. Action, however, does not always mean results. Consider the objective of each EMS component and define a way to measure results so that you would feel satisfied that the objectives are being achieved. Here are some examples of EMS results Performance Indicators for your EMS or various program components that can be tracked over time:
- number of SEAs included in environmental projects plan
- number of environmental objectives and targets met
- pounds of hazardous waste generated per unit of production
- employee sick leave absences related to the work environment
- percentage of employees completing environmental training
- average time for resolving corrective action
- energy or water use per unit of production
- percentage of solid waste recycled/reused
- number of complaints from the community; the number of responses to complaints
- number of pollution prevention ideas generated from employees
- resources used per unit of product or service
- pollution (by type) generated per unit of product or service
- percentage of products for which life cycle assessment has been conducted
- number of products which have a recycling program
- number of instances of non-compliance
It is the results shown by these environmental performance indicators that will become the basis for your plans for next year and for documenting continuous improvement. Measuring pollution prevention achievements is part of tracking performance, but may be different from, and often more difficult than, measuring environmental achievements in general. Simply measuring the reduction in a waste stream might mean only that the waste has been transferred to another medium, not reduced. It is therefore important to measure the reduction at the source of waste generation. It may also be important to measure the activities that your company directs towards pollution prevention. The following sources of information may help you track pollution prevention:
- Permit applications
- TRI reports
- Purchasing records
- Utility bills
- Hazardous waste manifests
- Material Safety Data Sheets
In addition, administrative procedures can be established to support pollution prevention activities. Your facility should consider:
- Establishing procedures in each facility area for identifying pollution prevention opportunities.
- Having a chemical or raw material inventory system in place.
- Assessing how many objectives have been met through pollution prevention.
Sample of Environmental Performance Indicators Log
Types of Environmental performance indicators (EPIs)
- Management performance indicators (MPIs): policy, people, planning activities, practice, procedures, decisions, and actions in the organization
- Operational performance indicators (OPIs): inputs, the supply of inputs, the design, installation, operation and maintenance of the physical facilities and equipment, outputs and their delivery
- Environmental condition indicators (ECIs): Provide information about the local, regional, national or global condition of the environment It help an organization to better understand the actual impact or potential impact of its environmental aspects and assist in the planning and implementation of the EPE
A component of monitoring and measurement is equipment calibration. Your facility should identify process equipment and activities that affect your environmental performance. As a starting point, look at those key process characteristics you identified earlier. For monitoring and measurement you can:
- measure the equipment itself (for example, measuring the paint flow rate through a flow gun to see if it is within the optimal range for transfer efficiency) or
- you can add measurement equipment to a process to help measure the key characteristic (for example, a thermometer on a plating bath to make sure that the temperature is within the optimal range for plating quality to reduce the need for replating which causes significant waste through product rework).
Some organizations place critical monitoring equipment under a special calibration and preventive maintenance program. This can help to ensure accurate monitoring and make employees aware of which instruments are most critical for environmental monitoring purposes. Some organizations find it is more cost-effective to subcontract calibration and maintenance of monitoring equipment than to perform these functions internally. An illustration of how calibration needs are tied to SEAs, operational controls, key characteristics of the operation, and monitoring and measurement methods is presented below a sample of Calibration Log
Step involved in Monitoring and Measurement
- Monitoring and measuring can be a resource-intensive effort. One of the most important steps you can take is to clearly define your needs. While collecting meaningful information is clearly important, resist the urge to collect data “for data’s sake.”
- Review the kinds of monitoring you do now for regulatory compliance and other purposes (such as quality or health and safety management). How well might this serve your EMS purposes? What additional monitoring or measuring might be needed?
- You can start with relatively simple monitoring and measurement process, then build on it as you gain experience with your EMS. It is better to measure fewer items consistently than to measure many items inconsistently.
- Regulatory compliance: Determining your compliance status on a regular basis is very important. You should have a procedure to systematically identify, correct, and prevent violations. Effectiveness of the compliance assessment process should be considered during the EMS management review.
- Operational performance: Consider what information you will need to determine whether the company is implementing operational controls as intended
- Progress on meeting objectives: You should measure progress on achieving objectives and targets on a regular basis and communicate the results of such measurement to top management. To measure progress in meeting objectives, select appropriate measurements of the key characteristics which apply to that objective.
- Selecting performance indicators: Performance indicators can help you to understand how well your EMS is working overall. Start by identifying a few performance indicators that are:
- simple and understandable;
- relevant to what your organization is trying to achieve (i.e., its objectives)
Data collected on performance indicators can be quite helpful during management reviews. So, select indicators that will provide top management with the information it needs to make decisions about the EMS. Make sure you can commit the necessary resources to track performance information over time. It is OK to start small and build over time as you gain experience in evaluating your performance. Keep in mind that no single measurement will tell your organization how it is doing in the environmental area.
- Communicating performance: People respond best to information that is meaningful to “their world.” Putting environmental information in a form that is relevant to their function increases the likelihood they will act on the information. Be sure to link your measurement program with your communications program and other elements of the EMS.
- Assessing regulatory compliance: Determining your compliance status on a regular basis is very important. You should have a process to systematically identify, correct, and prevent violations. Performance of the compliance management program should be considered during the EMS management review Elements of Compliance Management Program are:
- Organization policies and standards that describe how employees are to meet the regulations.
- Assignment of responsibility for compliance oversight.
- Processes to systematically ensure that policies and standards are carried out (e.g., monitoring and auditing).
- Appropriate incentives and disciplinary procedures.
- Prompt disclosure of findings.
- Prompt and appropriate correction of problems
Sample Form for Compliance Tracking Log
- Evaluating environmental performance: Go back and look at your significant environmental aspects and the objectives and targets associated with those significant aspects. What information will you need to determine if the company is achieving its objectives and targets?
Focus on things that you can do something about. Start by selecting a few performance indicators that are:
- simple and understandable
- relevant to what your organization does (i.e., its activities, products, and services)
Make sure you can commit the necessary resources to track this information over time. It is OK to start small and build over time as your company gains experience in evaluating its performance. Keep in mind that no single measurement will tell your organization how it is doing in the environmental area. People respond best to information that is meaningful to “their world.” Putting environmental information in a form that is relevant to their function increases the likelihood they will act on the information. Be sure to link your measurement program with your communications program and other elements of the EMS such as management reviews.
The distinction between audits and environmental performance evaluation can be confusing. The figure below is intended to explain the two concepts. Both are important to your EMS.
|Audits||Environmental Performance Evaluation|
|sample of data||frequent|
|verifies conformance||assesses performance|
9.2 Internal Audit
The organization must conduct internal audits at planned intervals to provide information on whether the environmental management system conforms to the requirements of ISO 14001:2015 standards, its own requirements for its environmental management system and also to check whether the environmental management system is effectively implemented and maintained.
9.2.2 Internal audit program
The organization must establish, implement and maintain internal audit program, including the frequency, methods, responsibilities, planning requirements and reporting of its internal audits. When establishing the internal audit program. the organization shall take into consideration the environmental importance of the processes concerned, changes affecting the organization and the results of previous audits. The organization must define the audit criteria. and scope for each audit. The organization must select auditors and conduct audits to ensure objectivity and the impartiality of the audit process; It must ensure that the results of the audits are reported to relevant management. The organization must retain documented information as evidence of the implementation of the audit program and the audit results.
As per Annex A (Guidance on the use of ISO 14001:2015 standard) of ISO 14001:2015 standard it further explains:
Auditors should be independent of‘ the activity being audited, wherever practicable, and should in all cases act in a manner that is free from bias and conflict of interest. Nonconformities identified during internal audits are subject to appropriate corrective action. When considering the results of previous audits, the organization should include:
- previously identified nonconformities and the effectiveness of the actions taken;
- results of internal and external audits.
Internal audits have always been a key element of ISO 14001 in helping to assess the effectiveness of the environmental management system. An audit program needs to be established to ensure that all processes are audited at the required frequency, the focus is on those most critical to the business. To ensure that internal audits are consistent and thorough, a clear objective and scope should be defined for each audit. This will also assist with auditor selection to ensure objectivity and impartiality. To get the best results, auditors should have a working knowledge of what is to be audited, but management must act on audit results. This is often limited to corrective action relating to any nonconformities that are found, but there also needs to be consideration of underlying causes and more extensive actions to mitigate or eliminate risk. Follow up activities should be performed to ensure that the action taken as a result of an audit is effective.
EMS Audit can be defined as “ A systematic and documented verification process of objectively obtaining and evaluating evidence to determine whether an organization’s environmental management system conforms to the system audit criteria environmental management set by the organization, and for communication of the results of this process to management.” Once your organization has established its EMS, verifying the implementation of the system will be critical. To identify and resolve EMS deficiencies you must actively seek them out. In a small organization, audits are particularly relevant since managers are often so close to the work that they may not see problems or bad habits that have developed. Periodic EMS audits will establish whether or not all of the requirements of the EMS are being carried out in a specified manner.
In compliance with the 14001:2015 standard, your Management Team will have identified environmental risks, set targets based on environmental legislation, and set key performance indicators to meet and eventually be improved upon – all designed to ensure that your organization’s environmental impact is as positive as it can be. The internal audit is now your chance to ensure that not only are these targets met, but that they are relevant, and meet all the needs of current legislation and internal needs. Before embarking on an internal audit on your environmental management system, it is advisable to carefully examine the targets and standards you are trying to meet, and whether you have a risk register, aspect register, or whatever way you record your results. Part of your internal audit should be assessing the accuracy and relevance of your objectives. Are they current in terms of legislation? Do any newly apparent risks exist that have not been formally identified? Has the management team considered all stakeholders when setting objectives and targets? It’s not uncommon for operators downstream to be able to identify environmental risks on a day-to-day basis that are not always apparent at a higher level. If you can find these, for example, your audit will be effective. You are identifying areas that can be improved, and aspects that may not be considered. Providing constructive suggestions for improvement is at the very core of any effective audit process. With opportunities for improvement and constructive suggestions found, you can now continue with auditing the system properly. Seek feedback on the results and process your audit. Are the set targets achievable? Are they still relevant? Are there barriers in the way to achieving them? Remember, if you can find barriers that do exist, you are one step away from finding improvement. Is legislation being met? Is your Legal Register up to date? Work collaboratively with the people who design, use, and depend on your Environmental Management System. See the internal audit process as a chance to use your combined knowledge and ability to improve performance, rather than a one-way channel where an auditor asks questions and the auditee responds defensively. Ensure you follow through on your improvements. Your company and the environment will surely see the benefits. For your EMS audit program to be effective, you should:
- develop audit procedures and protocols;
- establish an appropriate audit frequency;
- train your auditors; and,
- maintain audit records.
The results of your EMS audits should be linked to the corrective action system. While they can be time-consuming, EMS audits are critical to EMS effectiveness. Systematic identification and reporting of EMS deficiencies to management provide a great opportunity to:
- maintain management focus on the environment,
- improve the EMS, and
- ensure its cost-effectiveness.
The two methodologies for conducting audit are Compliance auditing and Performance Auditing. Compliance auditing is more of the style of ‘traditional’ auditing, i.e. ensuring that procedures are being followed in order to comply with the requirements of ISO 14001. This type of audit ensures that personnel is following procedures: i.e. taking measurements when and where they should; reviewing and updating the legislation register; generating the appropriate records, etc. Such auditing methodology will be second nature to an organization that already has a documented quality assurance system meeting the requirements of ISO 9001. It is important that the internal auditors can identify ‘environmental’ nonconformances during the audit. A compliance non-conformance is, for example, when a member of personnel neglects either due to an oversight to log onto a register the daily amounts of one waste stream going to landfill. The action is taken but not recorded. An environmental non-conformance could be a measurable target (such as the monthly figure for use of recycled paper not increasing as planned). If this has not been identified by operatives and management, for whatever reason, and corrective action not taken, then this may affect the objectives set. It may jeopardize a statement within the environmental policy and constitute a potential environmental non-compliance.
In determining the frequency of your EMS audits, some issues to consider are:
- the nature of your operations,
- the significant environmental aspects/impacts
- the results of your monitoring program, and
- the results of previous audits.
As a rule of thumb, all parts of the EMS should be audited at least annually. You can audit the entire EMS at one time or break it down into discrete elements for more frequent audits.
Auditor qualifications :
You will need to be trained in EMS auditors. Auditor training should be both initial and ongoing. Some organizations use existing and available quality systems auditors from an existing ISO 9001 system for the compliance auditing but for Performance audit, the auditor would need to have a grasp and understanding of the Standard and the EMS, and a broad understanding of environmental issues. Such requirements can certainly be achieved through an independent learning process with a combination of formal training and direct experience. EMS auditors should be trained in auditing techniques and management system concepts. Familiarity with environmental regulations, facility operations, and environmental science is a big plus, and in some cases may be essential to adequately assess the EMS. Some auditor training can be obtained on-the-job. Your organization’s first few EMS audits can be considered part of your auditor training program but make sure that an experienced auditor takes part in those “training” audits. If your company is registered under ISO 9000, consider using your internal ISO 9000 auditors as EMS auditors. Although some additional training might be needed, many of the required skills are the same for both types of audits. Auditors should be reasonably independent of the area or activity that is being audited. An auditor, auditing his own area of competence, is hardly likely to be impartial – especially if faced with a potential nonconformity directly traceable to their error!
Reporting back to management
Management can use EMS audit results to identify trends or patterns in EMS deficiencies. The organization must also make sure that any identified system gaps/deficiencies are corrected in a timely fashion and that the corrective actions are documented. As noted initially, the Standard calls for some form of feedback to management on the results of the audits. In truth, this is common sense, because if the results of the audits demonstrate major discrepancies in what was planned through objectives and targets and what is actually being achieved, then management needs to reconsider the effectiveness of the whole system in order to fulfill its obligations as set out in the environmental policy.
The methodology for performing the audits should be established within written procedures. How else can an internal auditor know how to conduct the audit? Frequencies of auditing should be specified written in a schedule, plan or even a chart and this should take into consideration the results of previous audits. Many non-conformities raised at the last audit should trigger off a more frequent re-audit until it is established that the corrective and preventive measures have worked. Finally, other types of audit used by organizations include external site audits, housekeeping (litter, etc.), the visual impact from the outside, odors, dust. These additional audits can only add to the effectiveness of the compliance and performance audits. Your EMS audits should focus on objective evidence of conformance. If you cannot tell whether or not a particular procedure has been followed, then you should consider revising the procedure. During the actual audit, auditors should resist the temptation to evaluate why a procedure was not followed, that step should come later. During the course of the audit, auditors should discuss identified deficiencies with the people who work in the area. This will help the auditors verify that their understanding is correct. It can also serve as refresher training on EMS requirements for employees. If possible, train at least two people as internal auditors. This allows your auditors to work as a team. It also allows audits to take place when one auditor has a schedule conflict. Before you start an audit, be sure to communicate the audit scope, schedule, and other pertinent information with the people in the affected area(s). This will help avoid confusion and will facilitate the audit process. Consider linking your EMS audit program to your regulatory compliance audit process. But keep in mind that these audit programs have different purposes, and while you might want to communicate the results of EMS audits widely within your organization, the results of compliance audits might need to be communicated in a more limited fashion.
The process to conduct Internal audit can be as follows
1) The Audit Schedule
Just as with any good internal audit process for any management system, the first important thing is to have an overall schedule of when you are planning to audit each process that will be audited for system conformance. The cycle for this is often a year but can be whatever you like, and the frequency of audits on any given process is linked to criteria like the environmental importance of the process and past audit conformance. If you have a process that has critical environmental aspects associated with it, you may want to look at this process more often than one that can have only a minor impact on the environment. The audit schedule should be available to employees and managers because you don’t want to have surprise audits.
2) Process Audit Planning
After confirming the audit with the process owner, the auditor can start to make preparations for the audit itself. Review of the process is critical for this – in particular, understanding the environmental aspects associated with the process. This is the key difference between an internal audit for a QMS and an internal audit for an EMS. While a QMS audit will look at a process and how well it is performing against the plans for the product or service of the company, an EMS audit will look at how well the process is performing against the plans for the environmental aspects associated with the process. A good audit plan will make sure you look for all the right data to support these process plans.
3) Performing the Audit
Probably the first thing to remember about performing the audit is that you are not using the internal audit to judge the legal compliance of the process. While a compliance audit is a good idea, and sometimes a legal requirement, this is not the goal of the internal audit program. This process is identified elsewhere in section 4.5.2 of the ISO 14001 standard. The internal audit is looking at the process against the environmental plans that the company outlined for the process. Are the environmental aspects monitored when applicable? Are any required environmental operational controls in place and maintained? Are nonconformities, corrective actions, and preventive actions against the process being addressed? In short, you are evaluating if the process meets the planned conditions with respect to how it can interact with the environment.
4) Audit Reporting
Like all audits, an EMS process audit is almost valueless if it is not properly reported. If the employees engaged in the process are doing well, they need to know this. Conversely, if there are problems, employees need to understand what these are so that they can be addressed and corrected. Opportunities to improve that are identified in the audit need to be presented to the process employees to consider their value in making their process better. These are the main ways that a company can gain value from the internal audit process, and if they are not well reported you can lose this value.
5) Follow Up on the Audit Issues and Improvements
Just as with corrective and preventive action, follow up is one of the least well-done parts of the internal audit process. If there is no closed loop to follow up on the actions and opportunities presented by the audit, then the value of identifying them in the first place is lost. Making sure that a problem that was previously identified is actually fixed can prevent the futile reporting of the same problem again and again. Use follow up to make your internal audits better.
|Example of ISO 14001:2015 Internal Audit Checklist|
9.3 Management review
Top management must review the organization’s environmental management system, at planned intervals, to ensure its continuing suitability, adequacy, and effectiveness. The management review must include consideration of the status of actions from previous management reviews. It must also include changes in external and internal issues that are relevant to the environmental management system, the needs and expectations of interested parties, including compliance obligations; its significant environmental aspects; risks and opportunities; the extent to which environmental objectives have been achieved. The Management review must take into consideration the adequacy of resources and relevant communication from interested parties, including complaints. The management review must include information on the organization’s environmental performance, including trends in
- nonconformity and corrective actions;
- monitoring and measurement results;
- fulfillment of its compliance obligations;
- audit results;
It must also take into consideration the opportunities for continual improvement. The outputs of the management review must include
- conclusions on the continuing suitability, adequacy, and effectiveness of the environmental management system;
- decisions related to continual improvement opportunities;
- decisions related to any need for changes to the environmental management system, including resources;
- actions, if needed, when environmental objectives have not been achieved;
- opportunities to improve integration of the environmental management system with other business processes, it needed;
- any implications for the strategic direction of the organization.
- The organization must retain documented information as evidence of the results of management reviews.
As per Annex A (Guidance on the use of ISO 14001:2015 standard) of ISO 14001:2015 standard it further explains:
The management review should be high-level; it does not need to be an exhaustive review of detailed information. The management review topics need not be addressed all at once. The review may take place over a period of time and can be part of regularly scheduled management activities, such as board or operational meetings; it does not need to be a separate activity. Relevant complaints received from interested parties are reviewed by top management to determine opportunities for improvement. “Suitability” refers to how the environmental management system fits the organization its Operations, culture, and business systems. “Adequacy” refers to whether it meets the ISO 14001:2015 requirements and is implemented appropriately. “Effectiveness” refers to whether it is achieving the desired results.
ISO 14001 requires that the organization’s top management shall, at planned intervals that it determines, review the environmental management system to ensure its continuing suitability, adequacy, and effectiveness. Again, common sense dictates that once a system is implemented, there should be a review process to test whether what was planned does happen in reality. Just as a person should have periodic physical exams, your EMS must be reviewed by management from time to time to stay “healthy.” Management reviews are the key to continual improvement and to ensuring that the EMS will continue to meet your organization’s needs over time. Management reviews also offer a great opportunity to keep your EMS efficient and cost-effective. For example, some organizations have found that certain procedures and processes initially put in place were not needed to achieve their environmental objectives or control key processes. If EMS procedures and other activities don’t add value, eliminate them. The key question that a management review seeks to answer is: “Is the system working? i.e., is the EMS suitable, adequate and effective, given our needs?”
ISO 14001:2004 standard sets out what is required from an organization in terms of management review, and what input and output criteria need to be satisfied to demonstrate the organization’s commitment to continual improvement. As you would expect, defining targets and objectives is also a staple of this initial management review process, and an organization’s top management team should play a key role in this, but the increased emphasis on leadership in the 2015 standard means that top management will be expected to understand and be able to talk about how the EMS is measured and improved, and how effective this has been. Therefore, an increased focus on having accurate, meaningful, and sustainable targets and objectives will arise. An increased expectation of demonstrable and measurable leadership will be expected from the ISO 14001:2015 auditor. An organization’s top management team must now take extra care in setting out its environmental targets, objectives, and authorities within the business. Can the team demonstrate leadership throughout the process, from target setting, through communication to delivery and review of performance, finally ensuring that continual improvement is possible and indeed delivered? Are all employees and stakeholders aware of the objectives and what must be done to achieve them? Formalizing these processes by recording them at your management review will help you. Sharing your management review minutes with your team and stakeholders will also help you. Everyone can then be aware that the top management team is clear on its objectives, clear on its responsibility toward achieving them, clear in providing the support and resources for the organization to achieve them, and clear in providing an EMS and support system where continual improvement can be achieved via an established review and feedback channel.
There is no correct way to perform an environmental management review – it must suit the organization’s culture and resources. As the Standard refers to ‘top’ management, this does indicate that a certain level of seniority of personnel should be present at such reviews, to demonstrate commitment. There are two kinds of people who should be involved in the management review process: people who have the right information/knowledge and people who can make decisions. Determine the frequency for management reviews that will work best for your organization. Some organizations combine these reviews with other meetings such as director meetings while other organizations hold “stand-alone” reviews. For ISO 9000 purposes, management reviews are typically held once or twice per year. Regardless of what approach your organization takes, make sure that someone takes notes on what issues were discussed, what decisions were arrived at, and what action items were selected. Management reviews should be documented. The management review should assess how changing circumstances might influence the suitability, effectiveness or adequacy of your EMS. Changing circumstances may be internal to your organization i.e., new facilities, new materials, changes in products or services, new customers, etc. or may be external factors such as new laws, new scientific information, or changes in adjacent land use
There are certain minimum areas to be reviewed and one option, used by most organizations, is to have a standard agenda for each meeting. The first point on the agenda should be a review of the Environmental Policy. This is the ‘driver’ for the whole system. Senior management should be able to examine it and say with confidence that what was planned (say 12 months ago) as stated in the policy, has occurred or that substantial progress has been made. Thus a typical agenda could be:
- Are the objectives stated in the Environmental Policy being met?
- Does the organization have the continuing capacity to identify environmental aspects?
- Does the system allow the organization to give a measure of significance to these aspects?
- Have the operational controls that were put in place achieved the desired levels of control?
- Are effective corrective actions taking place to ensure that where objectives are in danger of slippage, extra resources ensure a return to the planned time-scale?
- Are internal audits effective in identifying non-conformances?
- Is the environmental policy sufficiently robust for the forthcoming 12 months?
So, your top management team has set out its objectives, hopefully after a degree of employee consultation. The communication channel has been established; your stakeholders understand where the responsibilities lie and know that the support is in place to work toward achieving these goals. Many organizations have one management review per year. Is this sufficient to ensure targets are achieved and continual improvement is seen? As long as you have a defined vehicle to ensure all the vital aspects are reviewed, actioned, and improved, the answer is “yes.” This may be a weekly or monthly EMS meeting, and you can formally record what you discuss and decide to action there. This will keep you true to the targets and objectives you set up at that management review meeting. But, we are all human and sometimes forget things. Many companies choose to show their environmental performance results in their foyer or reception areas, whether on noticeboards or electronically. These KPIs are usually formulated at your management review meeting – why not summarize the management review minutes accordingly, and display them too? Sometimes everyone needs reminding of what they are actually trying to achieve, and having a summary of these minutes is a very effective way of doing so – and maintaining everyone’s focus on them. It could be argued that during the early months of the implementation period (perhaps prior to certification) these cyclical reviews are not appropriate and they should focus on just the progress of the implementation of the system. This is a reasonable viewpoint but, as the system approaches maturity, a review as above is beneficial at intervals of 6 to 12 months. It would be prudent for the organization to perform one full management review, following the procedure, prior to the on-site audit, to demonstrate evidence of implementation to the certification body. If it is concluded that the set objectives are being met, the organization is well on its way to minimizing its significant environmental impacts and thus complying with the requirements of the Standard.
Questions to Ponder During Management Reviews
- Did we achieve our objectives? (if not, why not?) Should we modify our objectives?
- Is our environmental policy still relevant to what we do?
- Are roles and responsibilities clear and do they make sense?
- Are we applying resources appropriately?
- Are the procedures clear and adequate? Do we need others? Should we eliminate some?
- Are we monitoring our EMS (e.g., via system audits)? What do the results of those audits tell us?
- What effects have changes in materials, products, or services had on our EMS and its effectiveness?
- Do changes in laws or regulations require us to change some of our approaches?
- What stakeholder concerns have been raised since our last review?
- Is there a better way? What else can we do to improve?
Once you have documented the action items arising from your management review, be sure that someone follows-up. Progress on these items should be tracked. As you evaluate potential changes to your EMS, be sure to consider your other organizational plans and goals. Environmental decision-making should be integrated into your overall management and strategy