John Nolan September 2015 saw the 2015 revision of the ISO 14001 standard released. We have looked at the “headline” changes in some detail in the previous article: 12 steps to make the transition from ISO 14001:2004 to 2015, but there are several smaller changes that are not so publicly reviewed, yet critical nonetheless. One of the major changes between the 2004 and 2015 versions is clause 8.2, which deals with “emergency preparedness and response.” (Learn more in the article ISO 14001 emergency preparedness and response.) If your organization already holds an ISO 14001:2004 certificate, you will be familiar with this topic, which was covered in clause 4.4.7 of that revision. The new standard, however, has some far more detailed and specific requirements, which are generally linked to the whole ethos of risk-based thinking and how organizations both react to and prepare for emergency situations. So, as with all changes to an ISO standard, we have the dual requirement to comply for future audit purposes, and also to embrace that change while ensuring that there is tangible benefit for both the organization and the wider environment. So, what do we have to know, and do, to achieve this?
Emergency response – What has changed?
The clause dealing with emergency response is now subdivided to ensure the salient requirements are specified clearly. Actions to plan for removal or mitigation of risk relating to emergency situations are required, as is a plan to respond to actual emergency situations themselves. Interestingly, there is an addition to the clause regarding prevention and mitigation of risk, where the phrase “appropriate to the magnitude of the emergency and potential environmental impact” is used. Clearly, here there is the implication that a perfunctory “emergency response” plan (see the article 5 steps to set up an emergency plan according to ISO 14001 to set up an emergency plan) in a “one size fits all” format will not be acceptable, but rather the risks and aspects that an organization has identified must be assessed and weighed up, and the emergency plan must therefore be proportionally related to the aspects themselves. Clearly, the emergency plan and procedure being formulated according to the risks that you have identified has its basis in risk-based thinking. For example, if your facility has 2000 employees, and you are considering the potential of “dirty water run off” from a fire department response to an on-site fire, then hoping that this water will run down the communal drains would not be a proportional plan for the size of facility you have. This could potentially be very damaging to the immediate environment. Having special drainage ditches that can capture that water with minimal environmental damage before disposal clearly is proportional to the aspect you have identified. The latter action shows consideration of the aspect and its size, while the former action shows recognition of the risk, but the suggested action is not significant to deal with the outcome.
Not surprisingly, periodic review and revision of emergency preparedness procedures and plans is mentioned (learn more about procedures needed to respond to the emergency situations in the article List of procedures for responding to emergency situations and accidents.). Testing the plan itself is also required, and there is a statement regarding reviewing the process “especially after the occurrence of emergency situations and tests.” Again, clearly this statement is aimed at ensuring risk-based thinking is used in the general review of the plan, and just as importantly, any lessons that can be learned from incidents or testing can be recorded and actioned to support the continual improvement cycle. Perhaps if your EMS (Environmental Management System) doesn’t have a “Lessons Learned Log” or equivalent, now is the time to establish one? After all, documentation to ensure that confidence can be sustained in the integrity and effectiveness of the whole emergency preparedness system is naturally required.
Emergency preparedness – How do we sustain it?
The above question is answered by “part f)” of this clause, which specifically suggests that all involved parties shall receive the relevant training and information to ensure that the emergency preparedness planning is effective. So, not only do you need to have a plan based on identified aspects and quantified risk that is tested and reviewed regularly, but you also need to ensure that the required training and information provided to stakeholders and employees is adequate and recorded in your training records or equivalent. On reflection, this last piece of the puzzle makes perfect sense. There is no point in having the best-thought-out preparedness plan in the world, if your employees and contractors are not properly trained to ensure its effective execution.
14001:2015 Emergency preparedness – The benefits
The benefits of this improved clause of the 14001:2015 standard should be clear to see. Our plan must now be “risk based” in its thinking, tested, and reviewed, with clear identification of improvements and lessons that can be learned documented. Importantly, all stakeholders must be informed, trained, and kept up to date with any changes that may affect the ability to deliver the plan. Therefore, the requirements in ISO 14001:2015 are far more prescriptive, but the result is a far more cerebral emergency preparedness process with review, education, and improvement built in. The changes are beneficial to both your organization and the environment, and the good news is that you can implement this now. Why wait?
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