John Nolan One of the critical parts of administrating an ISO 14001 certified EMS (Environmental Management System) is the management and recording of change. Change will occur all throughout the lifecycle of your EMS, whether that is through new legislation, changes in existing legislation, or new projects and initiatives that are established and implemented to drive improved performance against your agreed objectives. So, while change is vital to ensure your EMS performs and ultimately achieves continual improvement, it is also key that all changes are recorded accurately on your EMS for the sake of both effective implementation and historical purposes. So, what necessities drive this change, and what factors should we consider when deciding how to record evidence of change?
Change in the EMS: Why should it be recorded?
As hinted at above, change can take place in the EMS for many reasons, whether systemic, legislation, or procedural. The ISO 14001:2015 standard mentions “change” many times, specifically as being a critical factor in managing the EMS in such a way that the intended outcomes can be achieved. The standard mentions that the management of this change could include management of suppliers, employees, external providers, or compliance obligations by way of example. So, we can see that there are some good reasons for recording change, but are there any other factors we have to take into account when considering this element? Let us look in more detail:
- Legislation changes: These are date specific, and changes should be recorded and actioned in a timely fashion. If your organization fails to comply with legislation, it may be fined or face negative publicity, so it is vital that changes of this nature are recorded accurately.
- Changes to supplier details: Changes of this type are also critical in terms of date. If a supplier or manufacturing partner’s circumstances change, then it is critical that any changes are known immediately in order for vital manufacturing and purchasing decisions to be made. For example, if a manufacturing partner’s ISO 14001 certification expires, you may not want to use them any more – this type of change is time critical and must be recorded accurately.
- Operational control and process changes: These are very important from an internal consistency and product/service quality point of view. When changes need to be implemented that affect the way that a product or service is delivered, it is critical that they are both timely and accurate. Details of the changes should be recorded in your statement of work or process documents, and don’t forget that these need to be communicated and acknowledged properly by your employees to make sure the changes are understood, implemented correctly, and then repeated consistently. You can read more about this in the article Defining and implementing operational control in ISO 14001:2015.
- Control of records: As mentioned above, any documents you have need to be controlled and changed accordingly, both for employee and process accuracy and also to prove under audit circumstances that you have proper control over your documented information, which you can read more about in the article A new approach to documented information in ISO 14001:2015.
So, now that we understand what details we need to record, what suggestions can be made over how it can be done effectively?
EMS change: How do we record it?
As stated above, version control is critical in terms of ensuring your documented information is correct and changed at the appropriate time. There are, however, several other methods that large organizations may use to keep an accurate record of change in a fast-moving business environment:
- Create an EMS change log: This can be a very effective way of capturing the “headlines” of a change to anything in your EMS. Listing any major changes that need to be made, and, for example, the level of communication that is needed to publicize that change, can be a positive. It can also be of great assistance during both internal and external audits, where the evidence of change management can be illustrated to the auditor.
- Create an EMS diary: This is similar to the change log, but you could create a diary on your EMS to remind you of important dates in the future – risk assessment and audit dates – and also record change that has occurred in the past. Many EMS representatives and managers prefer this method to a change log, as it has both a proactive and reactive element, and encourages future planning.
So, now that we understand both why and how to record change, is there anything else that we need to know?
Controlling change, meeting objectives
As change is such a part of modern day business, controlling the change that affects your EMS can go a long way towards helping you meet your objectives. Organizations that are on top of organizational and process control are a huge way towards achieving the goals that have been set for the EMS. Failing to do so can lead to inconsistent product, an unnecessarily negative environmental impact, and failure to comply with legislation, all of which can be expensive financially and in terms of reputation. Manage the change in your EMS, and ensure your organization and the environment benefit accordingly.
Why not use our free ISO 14001 Foundations Course to learn about EMS change management?
