Mark Hammar Have you ever wondered about the applicability of the ISO 14001 requirements for operational control? What procedures do you need to comply with these operational control requirements, and how do they relate to environmental aspects? Do you really need to have procedures for everything you do? Is operational control really necessary? The answers to some of these questions might surprise you.
In a recent article on Deciding which procedures to document in the EMS, I talked about when you might need to create a documented procedure for the environmental operational control of your processes. I mentioned that a process that emits wastewater into the sewer might need a “Guideline for wastewater & sewage management,” but if you don’t have hazardous waste (or it was not a significant environmental aspect), then you would not need a “Guideline for hazardous substance management.” The company must decide for themselves what the definition of significant is, and write an appropriate procedure accordingly.
However, what if none of your environmental aspects are significant?
It all comes back to what environmental aspects are significant
Environmental aspects are the ways in which your organization interacts with the environment, and these are critical in the assessment of which operational controls are needed for ISO 14001. The requirements of section 4.4.6 hinge on three main criteria for creating an operational control procedure:
- Operations’ association with significant environmental aspects
- Lack of control could deviate from the environmental policy
- Lack of control could deviate from the objectives and targets
So, when you have an operation that has significant environmental aspects, you need to identify and plan that operation to be consistent with your environmental policy, and your environmental objectives and targets, to make sure they are carried out to specified conditions. This is done by establishing, implementing, and maintaining a documented procedure to control these situations and stipulate operating criteria in the procedure. This is clear when you have an operation where you have a significant environmental aspect. For these cases, it is necessary to have operational control.
For more on how to set the criteria for significance in your environmental management system, see this article on What makes an environmental aspect significant in ISO 14001?
When is it necessary to have operational control procedures?
So, it is clear that you do not need a documented procedure for every operation you do to meet these requirements, only those with significant environmental aspects. The question that remains is if it is possible to have a situation where none of these operations have significant environmental aspects. It is true that the organization needs to identify what constitutes significance for their identified environmental aspects; however, for certification purposes these criteria need to be justified to the auditors of a certification body who will review your environmental management system for compliance with the requirements of ISO 14001.
This might be a stretch, but I would argue that it might be possible to have an organization with no significant environmental aspects, although I would think this is a very rare case. One example I could think of would be a small company that specializes in producing computer codes for customers with the assumption that they lease their computers and do not need to dispose of them. This company could potentially identify environmental aspects but not identify them as having significant impacts on the environment. So, it could be possible, but not necessarily likely, that such a company could exist without significant environmental aspects, and therefore no operational control procedures for ISO 14001 compliance.
So, when is operational control necessary in an ISO 14001 environmental management system? If you have identified operations with an environmental aspect that you deem to be significant, then you need to have procedures to control these operations. These aspects are often identified in one of the following categories (from appendix A3.1 of ISO 14001):
- Emissions to air
- Releases to water
- Releases to land
- Uses of raw materials and natural resources
- Uses of energy
- Energy emission such as heat, radiation, or vibrations
- Waste and by-products
- Physical attributes of the organization affecting the environment
Remember why you have an environmental management system
Remember, the reason for implementing an environmental management system is not to please a certification body or to find ways to avoid documentation. An environmental management system is there to help your company identify and control your interactions with the environment. If these interactions have the potential to cause negative impacts on the environment, then it makes sense to have the procedures in place to properly stipulate the necessary criteria to control the operational situations. In this way, you can avoid the negative impact on the environment, and this is why you have your environmental management system in place.
To find out more about what needs to be documented for an ISO 14001 environmental management system, click here to download a free white paper: Checklist of ISO 14001 Mandatory Documentation.
