Mark Hammar Do you have trouble understanding and explaining why ISO 14001 has a section on competence, training and awareness? Do your employees and management understand what the requirement for competence, training and awareness means to your organization? Truly understanding this requirement will help you a lot to adequately implement this critical part of the environmental management system (EMS). Without these requirements being properly met, you could easily miss critical areas that need to be in place to make sure your processes do not pose a negative impact on the environment around you, which is the reason behind implementing an ISO 14001 EMS in the first place.
What does ISO 14001 require?
Unlike ISO 9001, which looks at the ability of the employees to maintain the processes in order to produce good product, ISO 14001 is concerned with how the processes interact with the environment. In essence, how does the organization ensure that employees (or other outside workers) who are running processes with the potential for significant environmental impacts are able to do so in such a way that those impacts do not happen? There is a basic three-step process for this, called competence, training, and awareness.
Competence. The first step is to identify what skills and abilities are required for a person to perform the job function so as to avoid the potential significant impacts. This competence can be gained in the form of outside education, training, or experience. For instance, if you have a chemical process that must maintain the concentration of a bath to a certain pH, or else there will be unwanted air emissions, then this bath concentration must be maintained.
If you require the operator to measure the concentrations and adjust the pH level through addition of an acid or base, then there is a level of chemical knowledge required to perform this action. It may not require the operator to hold a degree in chemistry, but chemical knowledge must be there in order to avoid the unwanted environmental impact of air emissions.
Training. After identifying what competencies are required for the processes to avoid potential significant environmental impacts, you need to find people with these competencies to fill these positions. Of course, in reality there will often be a choice of candidates who have many of the required competencies, but not all of them. This is where training comes into place, especially when you are first implementing your environmental management system and find that the people already doing a job do not have all of the competencies that are newly identified for the position.
Training can come in many forms, from enrollment in external programs offered by colleges, universities, or specialized training companies, to on-the-job training where an experienced person works with a less-experienced individual to teach them the knowledge they need to perform the job. The employee in the example above need not attain a degree in chemical engineering to perform the job, but they may need to gain an understanding of the chemical processes required to safely perform their tasks.
Awareness. Even those who have the desired competencies need to be made aware of how their tasks can lead to the identified potential environmental impacts. The requirements of ISO 14001 separate the need for awareness into four distinct areas:
- Conforming to the environmental policy and procedures. When people understand why a policy or procedure is in place, they are much more likely to follow that requirement. Telling employees that they need to prevent pollution from their process is one thing, but when they understand that not following the process can lead to environmental damage and potential fines that can lead to company insolvency, they may be more likely to follow the rules.
- Significant environmental aspects and potential impacts. The person running a chemical process may know that uncontrolled waste emissions from that process can be harmful to the environment if not properly controlled, but they may not understand what those controls need to be. Awareness of the proper procedure and the benefits of following it are important to compliance with the rule.
- Roles and responsibilities to achieve conformity. If a person does not understand what their role is, they are very unlikely to perform that role. This is particularly important when you are dealing with a temporary employee or contractor who will not know your specific processes unless you tell them. For example, if you expect that all fluorescent light bulbs will be collected and stored for proper recycling, but do not tell a contractor or summer student who is employed to replace the bulbs, then they may just throw them in the regular garbage because they did not understand that this was their role.
- Potential consequences of departure from procedures. This links directly back to my first point: if employees are aware of the consequences of not following the procedures, such as environmental damage or fines for the organization, they are more likely to understand why the procedure needs to be followed rather than just following it because that is what is written. Many employees gain a great deal of pride and satisfaction in their work if they better understand why it is important.
What records do you need to keep?
As I have indicated in previous blogs, it is important to keep records of the information that is needed to show that you have successfully achieved your plans for the EMS. This is evident in the requirements for competence, training, and awareness, since ISO 14001 specifies that you should keep records to show that competencies have been achieved through education, training, or experience. So, you need to ask yourself; for activities that can have a significant environmental impact, do I have everything I need to show that the people performing these activities are competent and trained to properly perform the tasks in such a way that the risk is avoided?
Why not use our ISO 14001:2015 Foundations Training Course to enhance your knowledge of the ISO 14001 standard and good practices?
