DOCUMENTATION FOR ENVIRONMENTAL MANAGEMENT SYSTEMS
Marcos Antonio Lima de Oliveira, Technical Director
QUALITAS Treinamento e Consultoria
Environmental Manual establishes the Environmental Policy describing the system and the organisation.
Procedures answers the questions: what, whom, when, where.
Operational procedures are documents that explain how the activities are performed.
Records are used to prove that the activities are done in acordance to procedures, demonstrating compliance with requirements described in the Environmental Manual.
1. INFORMATION AND DOCUMENTATION
DATA: facts of any kind;
INFORMATION: items of knowledge
( The Concise Oxford Dictionary - England )
While data relate to facts, an information refers to a series of data analyzed to provide a decision. An information is an answer to a question. All informations come from data, but not any data become an information.
An information is a tool for decision making. The quality of the decision depends on the quality of information.The quality of information depends on the relevancy, the precision and the speed of the information. Information must be continuously reanalyzed and renewed. It becomes volatile if it is not registered, indexed and updated.
Usually executives who make decision receive an exaggerated quantity of data, but not always they get the information they need, presented clearly and adequately for using in decisions. Decisions are usually related to solving problems. And to solve a problem, we need information to decide.
An environmental management system requires a documentation system in order to collect, analyze, register and retrieve information.
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2. ENVIRONMENT AND DOCUMENTATION
Nowadays environment is an important item in strategic planning of any organization, specially in industry. There is an increasing awareness on the need to protect the environment. Consumers and retailers are increasingly taking purchasing decisions based on environmental aspects.This trend is pushing on the organization. In the past, many companies did not take care of these subjects. Some even tried to hide or deny any fault.
Company managers have the responsibility to demonstrate the company's ability to comply with environmental laws.The company's demonstration must be based on the existence of specific policies, requirements and procedures. It must be based also in the existence of specific assignments of responsibilities for the implementation of these policies, requirements and procedures. How can employees be aware of their responsibilities to the law unless these requirements are interpreted to them through adequate procedures? It must be assured that all employees understand these procedures.
The first answer of industry was the Responsible Care program. In order to assure credibility, many national standard organizations prepared standards related to quality management system. One of these organizations is the British Standards Institute, that issued BS 7750. ISO has published the ISO 14.000 series, related to environment. One of the purposes is to have independent certification of management systems, in a way similar to ISO 9000 series that are used for quality systems all over the world.
Other countries established a special label to put on products whose production, handling and use does not affect environment. The most important are from:
In order to have a good environment system, several steps should be established:
Good policies and requirement-type documents, including laws, codes and standards;
Good procedures in order to attain compliance with the requirements, stressing the importance of preventive actions;
Good in-process measurements and assessments in order to verify if compliance is being attained;
Effective and timely corrective action;
In this paper we propose a documentation system related to the standard BS 7750. However, it can be used for other standard based environmental management systems.
3. ENVIRONMENTAL MANAGEMENT MANUAL
An important document is the environmental manual. This document establishes the general policy of the company about this matter. It usually contains the Environmental Policy and the structure of the organization including who is in charge of the verification of activities for the maintenance of the environmental system. It explains how each requirement of the standard will be handled in the organization, including a list of all procedures.
The manual contains the description of the system which was or is being implemented. There are a lot of benefits in preparing a manual:
Useful for audit purposes;
Adequate for training of new employees;
Easier approval of licenses from protection agencies;
Useful for marketing purposes.
The first point is the top management commitment to the environmental protection practices. This commitment is made clear for all employees of the organization through the publication of an environmental policy. This document must be signed by the highest executive in the company. It should contain the vision of the organization about environment and the commitment to continuous improvement.
This document should be detailed including targets to be reached, explaining how they will be reached, with what resources, under the responsibility of whom. It is a document that deploys the company environmental policy. It is necessary to measure results in order to evaluate the correct application of the policy.
The administration shall assure that this policy is understood by all employees. That are several ways to do so: to publish a letter of the president, to publish in the company's newspaper, to display pictures with the policy, to issue in personal timetables, etc. But the most effective way is to promote presentations to all employees to be done by their supervisor or manager. In these presentations, the policy should be explained. In order to get more confidence, the group should discuss the environmental objectives to verify if it is possible to reach them using available resources in a reasonable period of time.
To prepare the Manual it is necessary to identify regulations, standards and codes that are mandatory to comply with. This is the minimum that an environmental system should attend. It is necessary to understand clearly the mandatory requirements and what must be done to comply with. The company has to identify other requirements the system should attend, for instance: headquarters policies, top management strategic vision, the client requests, etc.
We propose an index for the Environmental Manual for an industry:
ENVIRONMENTAL MANAGEMENT MANUAL
PURPOSE AND APPLICATION
REQUIREMENTS OF THE STANDARD:
ENVIRONMENTAL MANAGEMENT SYSTEM
TRAINING OF PERSONNEL
CODES AND REGULATIONS
OBJECTIVES, TARGETS AND CONTROL ITEMS
EMISSIONS AND WASTE TREATMENT
TOP MANAGEMENT REVIEW
4. ORGANIZATIONAL PROCEDURES
Every requirement of the Standard must be complied in organizational procedures. We use them to clarify how activities should be done, by whom, in what conditions, for what purposes. In general, the procedure explain activities and responsibilities of the different departments of the organization involved in some action. They are related to management rather than to technology.
BS7750 requires the preparation of procedures for the following activities:
to ensure that all employees are aware of the importance of compliance with the system, the potential environmental effects and their roles and responsibilities;
identify training needs;
identify all regulatory, code and policy requirements;
communications ( internal and external );
examining and assessing effects;
objectives and targets;
control of documents of the systems;
handling of records;
5. OPERATIONAL PROCEDURES
Operational procedures are documents that explain how the activities are performed. They are related to technology and "know-how" of the activities. Examples:
Usually every company has this type of document, even before the decision of implementing an environmental management system. So it is necessary identify which procedures among existing ones are related to this new systems. These documents are essential for the training of employees.
6. ENVIRONMENTAL RECORDS
During environmental audits it is necessary to prove that the activities are performed in accordance to procedures, demonstrating compliance with requirements described in the Environmental Manual. So it is necessary to show some documents. These documents are called records, another family of environmental documents. In most of the cases, these documents are forms that should be filled in.
The standard BS 7750 requires that the following records should be kept:
Failures and corrective action;
Complaints and follow-up actions;
Change in procedures;
Results of audits;
Contractor and procurement activities;
Measurements and monitoring data;
Measuring and testing equipment calibration .
The company has to establish and maintain procedures for identification, collection, indexing, filing, storage, maintenance and disposition of environmental management records. The records should be readily retrievable and protected against loss.
7. DOCUMENT CONTROL
The item that present higher number of non-conformities in auditing for certification of quality systems according to ISO 9000 is document control.
It is necessary to implement the following organizational procedures:
DOCUMENT EMISSION: Establishes the content of each type of document, its format of presentation and the procedures for approval and revisions;
Establishes the way documents are sent to users, how they are controlled, procedures for sending new revisions and discarding old ones;
RETENTION TIME OF DOCUMENTS:
Establishes how environmental records are filled/indexed and the period of time that they should be kept before discarding.
CONTROL OF EXTERNAL CODES AND STANDARDS:
Lists all codes, laws, regulations and standards that the company should comply with.
A critical point is to assure that documents are being used in their last revision. Documents, specially operational procedures, should be available to employees where operations are performed. Documents should be periodically revised by authorized personnel. Obsolete documents must be promptly removed. In case of necessity to retain obsolete copies ( for legal or preservations purposes ), they should be suitably identified. Document control must assure that all documents are easily located.
It is necessary to determine who is in charge of document control. All documents of the system ( except records ) should be controlled. This person should have control of who must receive a revised copy of each document
8. ENVIRONMENTAL AUDITS
An important point to provide confidence is to have an audit system, in which independent auditors ( internal or external ) are used. To audit is to compare current practices against approved standards or procedures. So, to have a good audit system is necessary to have an adequate documentation.But auditing is just one part of environmental system. When attention to environmental matters had just began, some companies believed that they should do only auditing in order to solve problems.
The scope of the audit should include an assessment in order to verify the compliance with policies, requirements and procedures. An other important point is to verify if these documents are adequate to get the degree of compliance to the company's objectives. In the beginning of the auditing program there is an emphasis in verifying the adequacy of environmental program. In the following audits we need to address the degree of implementation compliance. When the program is operating well, we should also verify if the results are according to the environmental policy. The audit objective is to assess the degree of compliance of actions with the policy, manual, procedures and instructions. This is done by verifying environmental records compared to specifications.
There is a big similarity between quality and environmental auditing ( planning, selection of auditors, reporting, corrective action, etc ). As most companies which intend to implement an environmental management systems have already implemented ( or are implementing ) a quality system, we will not detail here activities related to auditing. We suggest to use internal quality auditors, with some additional training related to environmental management.
While in quality auditing we have fixed intervals between audits, in the case of environment the laws changes ( most by addition ) and community levels of sensitivity to environmental issues also change. So the interval between audits can be reduced. In some cases additional audits can be scheduled to cover all or just a part of the system. This is important when a new activity is about to start.
Documentation is necessary for describing the environmental management system implemented. This should be understood as minimum requirement. Companies must anticipate consumers needs and expectations. So the system and its documentation should be periodically revised.
MARGUGLIO, B. W. Environmental Management Systems. Milwaukee: ASQC, 1991. 194 p
BRITISH STANDARDS INSTITUTION. Specification for environmental management systems. BS7750. London, 1992
ISO/DIS 14.001 Environmental management systems - specification with guidance for use, 1995
Certified Quality Engineer - ASQ
Brazilian Quality Award Examiner ( 1992, 1998 )
QUALITAS Technical Director
Senior Member da American Society for Quality - ASQ
Author of the books: QUALIDADE: O DESAFIO DA PEQUENA E MÉDIA EMPRESA e DOCUMENTAÇÃO PARA A ISO 9000, Ed. Qualitymark, PROGRAMA QUALIDADE BAHIA Executive Committee Member, ABIQUIM-QUALIQUIM Member
Master of Science student in Business Management, Business School of University of Bahia ( one of top five in Brazil ) - 1998/2000.
ISO 9000 FORUM member, Switzerland
Technical papers presented abroad:
"BARRIERS TO QUALITY DOCUMENTATION IN DEVELOPING
COUNTRIES", World Quality Congress, EOQ/ASQC/JUSE, 1993,
"DOCUMENTATION FOR ENVIRONMENTAL MANAGEMENT SYSTEMS", 4th International Conference on ISO 9000, EC/ISO9000, USA, 1996
"DOCUMENTATION FOR ENVIRONMENTAL MANAGEMENT SYSTEMS, 10 th World Quality Congress, Yokohama-Japan, promoted by ASQC, JUSE, EOQ, 1996