John Nolan September 2015 saw the new ISO 14001:2015 replace the 2004 standard, with the resulting changes in how an organization should administrate and run its EMS (Environmental Management System). Amongst several important changes in the new standard is the change to the role of the “management representative.” In the 2004 standard it was stated that “top management shall appoint a management representative,” while the 2015 version states that “responsibilities may be assigned to an individual, shared by several individuals, or assigned to a member of top management.” So, it is clear that organizations have the opportunity to appoint responsibility in different ways according to the new standard, but what are the positives and negatives of these options, and why have these changes come about?
Why did the standard change?
Undoubtedly, the ISO International Committee only makes changes to a standard for good reason; therefore, it is wise to consider the thinking behind changes like this before taking action. In the article How to demonstrate leadership according to ISO 14001:2015 we examined the new leadership requirements, and similarly, the article How to get management buy in before ISO 14001 implementation looked at the importance of management commitment to the implementation project and the EMS itself. It seems likely that the changes in options in terms of who should be responsible for the EMS are embedded in this factor, and that the 2015 standard is designed to try and ensure that top managers take a greater interest and involvement in both the strategies and the day-to-day workings of the EMS, with the ultimate target being the improved performance of the EMS and the benefit to the environment itself. So, given that we understand why the changes have been made, what option is best?
EMS coordination, who is best placed to do it?
The 14001:2015 standard gives three options as to who should coordinatean EMS, and similarly, you will have your own ideas of who is best placed to coordinate: perhaps the Ops Manager if he has process knowledge, or the Quality Manager if he has the relevant skillset. However, let us consider the options stated by the standard individually:
- Coordinated by an individual: Similarly to previous arrangements, a “management representative” can be used. This ensures that responsibilities lie with one employee who will have the necessary training, ability, and knowledge of the standard to coordinate all aspects of the EMS. The negative is that this may limit the knowledge and involvement in tasks of fellow employees and despite what the 2015 standard aspires to achieve, the involvement and knowledge in the EMS will remain more localized than is desired.
- Shared by several individuals: Your EMS coordination can be shared by a group or committee. This involves more stakeholders and employees in the process, shares the education across a wider base, and also involves more input, opinions, and feedback into your EMS, which is a positive thing. On the negative side, it may be more difficult to ensure that tasks are scheduled correctly when performed by various members of this group, each with different workloads, priorities, and vacation times.
- Assigned to a member of top management: In line with the standard’s ethos of involving top management, this seems like a good idea. Having a top manager involved surely raises the internal perception of the organization’s stance on environmental issues, and a top manager can also integrate strategic vision and knowledge that lower-ranking members of the team do not have. On the negative side, coordinating the EMS may be a full-time job in some companies, and many organizations may understandably suggest that employing a well-paid executive to administrate an EMS is not the best use of available resources.
So, given that we now have these options – and any combination of them – what is the best option for your organization?
EMS coordination – What is best for your business?
Given that all organizations are of different sizes, have different shapes, and incorporate people of different capabilities, the decision on who coordinates the EMS will have to be made by the organization itself. However, given the 2015 standard’s requirement for leadership involvement in terms of risk, commitment, and communication, it may pay to have your EMS coordinated by a small committee with one of your top managers as the chair. That way, your chair can provide the bridge between the boardroom and the EMS committee, provide insight into actions and initiatives passed up or down, and critically, provide strategic insight into the goals, objectives, and environmental aspects that belong to the EMS. Importantly, this top manager can help delegate realistic and time-bound activities to your committee or team without having to spend management time performing the tasks him/herself.
No matter what decision you make on how best to coordinate the EMS, you can see above that involving your leaders to some degree is vital. Previously, a management representative could coordinate the EMS with very little senior management intervention, and this cannot be a positive thing for an ambitious, aspirational, and conscientious business. Take time to consider how best to coordinate your EMS with the tools you have at your disposal, and concentrate on the ethos of the 14001:2015 standard. The benefits will soon be obvious internally and externally.
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