Key Elements of ISO 14001

The Resources, Roles, Responsibility, and Authority; Legal and Other Requirements; Evaluation of Compliance; and Nonconformity, Corrective Action and Preventive Action elements of ISO 14001 are all essential to the ongoing effectiveness of the EMS. This section describes how they function within the overall scheme.
1. Resources, Roles, Responsibility, and Authority (ISO 14001:2004, ?4.4.1)
?4.4.1 of ISO 14001 establishes three important requirements:
1. That management ensure the availability of resources to establish, implement, maintain, and improve the EMS;
2. That roles, responsibilities, and authorities be defined, documented, and communicated in order to facilitate effective environmental management; and
3. That top management appoint a management representative(s) who, irrespective of other responsibilities, will have responsibility and authority for implementing and maintaining the EMS and for reporting to top management on the performance of the EMS.
Ensuring Availability of Resources – Provision of resources for the EMS is almost always an issue within organizations. Although top management usually understands and accepts, at least in principle, the requirement to provide resources, the level of management that makes decisions on capital deployment and operating budgets often does not subscribe to the same requirement. Making the case for resources typically requires the implementation team or management representative to quantify intangibles such as the avoided cost of regulatory fines or the value to the environment of reducing environmental impacts.
When considering the requirement to provide resources, especially financial resources, it may be important to recognize that ISO 14001 requires the provision of resources for the establishment, implementation, maintenance, and improvement of the EMS, not necessarily resources to correct or prevent environmental impacts or to register to ISO 14001. When contemplating the cost of implementing ISO 14001, organizations, again, should think in terms of three separate cost categories:
1) Internal labor and external consultant costs to establish, implement, maintain, and improve the policy and procedural elements of ISO 14001;
2) Capital costs for correction or prevention of environmental impacts; and
3) Costs of registration to ISO 14001, if the organization elects to register.
Roles, Responsibilities, and Authorities – In the past, some organizations have employed a practice of not delegating responsibility and authority for environmental affairs to specific management representatives, reasoning that if the responsibility was diffused throughout the organization, no one person could become personally accountable for non-compliance with regulations or for environmental liabilities. §4.4.1 of ISO 14001 limits such ‘willful ignorance’ by requiring top management of the organization to appoint “specific management representative(s)” to ensure that the EMS is implemented and that top management be apprised of EMS performance. It also requires that the delegation of responsibility and authority be documented and communicated, thus eliminating circumstances where responsibility and authority for the EMS are diffuse or uncertain.
When §4.4.1 is read together with the requirement of the Environmental Policy for a commitment to comply with applicable legal requirements, §4.3.2, Legal and Other
Requirements, requiring a procedure for identifying legal requirements (following), and §4.5.2, Evaluation of Compliance, requiring a procedure for evaluating regulatory compliance, it is evident that the management representative is also responsible for ensuring that the organization is in compliance with applicable regulations. While this responsibility and authority can be delegated, the chain of delegation begins with top management and is passed to the management representative, effectively eliminating any uncertainty as to who is responsible and authorized to ensure regulatory compliance.
EMS Organizational Structure – There is an almost universal norm for the management structure of the EMS organization under ISO 14001. It begins with the top management position, proceeds to the top manager’s leadership team, and then to an EMS implementation team that is generally chaired by the management representative. The departments making up the relevant functions and levels of the organization and environmental, safety, and health professionals comprise the typical implementation team.
Defining Roles, Responsibilities, and Authorities for the EMS – In defining, documenting, and communicating EMS roles, responsibilities, and authorities, it makes sense to begin with top management and proceed through all of the positions having EMS responsibilities. Following is a generic example of how roles, responsibilities, and authorities might be documented and communicated in an EMS Procedures Manual:
Plant Manager
Authority: The Plant Manager has the authority, responsibility, and accountability for managing all aspects of ABC Company’s activities, products, and services at the Anytown facility.Source: Senior Vice President, Manufacturing, ABC Company, Inc.
EMS Responsibilities: Under the requirements of ISO 14001, the Plant Manager shall be specifically responsible for:
1) Defining the Environmental Policy;
2) Delegating authority and responsibility for the establishment, implementation, maintenance, and improvement of the EMS;
3) Providing human, technological, infrastructure, and financial resources and specialized skills; and
4) Periodically reviewing the EMS for suitability, adequacy, and effectiveness and directing changes as necessary to achieve the goals for an EMS and the commitment to continual improvement.
Leadership Team
EMS Responsibilities: The Leadership Team shall advise the Plant Manager on the exercise by
the Plant Manager of his/her responsibilities for the EMS.
Management Representative, Implementation and Maintenance Responsibilities
EMS Authority: The Plant Manager delegates to the Manager, ______ _______, the authority
to establish, implement, maintain, and improve the Environmental Management System and to
ensure that it conforms to the requirements of ISO 14001. In the context of ISO 14001, the
Manager, _____ _________, shall be the Management Representative.