Understanding Responsibility & Authority Identification in ISO 14001
Have you had trouble understanding the requirements in section 4.4.1 of the ISO 14001 standard on resources, roles, responsibility and authority? Are you concerned that you are going too far in how you are defining this in your processes and procedures? These are common problems, partially brought on due to the many different items covered under this requirement. My goal is to break down this multi-faceted section of the requirements in order to explain it better.
What about resources?
The first paragraph of section 4.4.1 concerns management ensuring that resources are available for the environmental management system (EMS). This includes the four aspects of the system: establishing, implementing, maintaining and improving. If, during the first audit, the only employee who understands the EMS is the main implementation person, then there might have been a problem with resources for establishing and implementing the system. If, several years later, there are troubles found with correcting problems, or the EMS improvement activities are not being accomplished, then there might be difficulty with resources for these activities.
For more information on improvement through the use of objectives and targets, see How to Use Good Environmental Objectives.
The resources are further defined to include people (human resources and specialized skills), infrastructure of the organization, technology, and finances. In effect, anything that is required to make sure that all aspects of the EMS are in place and functioning can be defined as resources. It is not limited to people and money. If, during an ISO 14001 audit, the auditor finds that many instances of the same problem are found throughout the company, they would be well within their scope to question the resources available for the environmental management system.
Some tips on defining roles, responsibility, and authority
The second paragraph talks about the roles, responsibilities, and authorities being defined, documented, and communicated so that the EMS can be effective. There are some things to keep in mind when addressing this, the most important of which is that this requirement is solely associated with the environmental management system. The requirement is not demanding that the roles, responsibilities, and authorities are documented throughout the company, although it may be a good idea to do so. If there are roles for human resources related to who needs to follow up with calling the references supplied by a potential employee, this is not something that the ISO 14001 standard is concerned with. However, if there is a skill requirement to successfully run a certain company process that can have significant environmental impact, you need to know who needs to validate that a potential candidate has this skill, who is responsible to define the skill or train the skill, and who has the authority to make the final decision on hiring the employee for this skilled position.
Another tip on documenting the roles, responsibility, and authority in your environmental management system has some very common sense applications. Try to be general in your definition, while still maintaining control of the assignment. Some people try to define the role or responsibility by using either an employee name or defined position, and this can sometimes be a troublesome choice. It will mean that if an employee changes positions in the company, or a position title changes, you will need to update all of your documentation to correct the change even though the actual process stays the same. Instead of trying to say the “human resources director” is responsible for validating the skill in the example above, it might be better to say the “human resources member of the hiring team” has this responsibility. Then an appropriate person can be assigned even if titles change.
Why have a management representative?
The last part of this section of the standard involves top management appointing a specific person to act in the capacity of management representative for the environmental management system. This person has specific roles, responsibilities and authorities defined in the standard, and these are as follows:
Make sure the EMS is established, implemented, and maintained to ISO 14001 requirements. This does not mean that this one person is responsible for doing all the work, but this is very much a situation of “the buck stops here.” This one individual is tasked with making sure that all aspects of the EMS are in place and being done by whoever is responsible for them. They need to take whatever actions necessary to ensure this happens, be they audits or records review.
Report to top management on how the EMS is performing. After this person makes sure that the EMS is working as required, they need to report on how well or poorly the management system is performing to top management. This normally takes place during the management review process, and includes any recommendations on how to improve the environmental management system performance. If done right, all other top managers understand what needs to be done so that resources are properly applied.
As simple as possible is best
Unlike many other processes in the ISO 14001 requirements, there is not always one easy document that can be used to define this for the entire system. The roles, responsibilities, and authorities are often spread throughout all the process documentation that the company defines, and as such, this can become intricate to say the least. As in many things, it is often the best idea to make things the simplest they can be. Some ideas would be to keep this information in the same part of each document so it is easy to find, and to make sure that you do not duplicate the information in case you forget to update one place and cause confusion. By setting and following some simple rules, you can greatly increase your employees’ understanding of who needs to do what for the EMS to function, which is one of the main benefits of implementing the system.
For a better understanding of the ISO 14001 requirements, check out this free online ISO 14001 Foundations Course.