John Nolan The ISO 14001:2015 standard is significantly different from the 14001:2004 standard in many ways, and the requirements of the environmental policy is one of these differences. Despite the environmental policy being one of the mandatory requirements of the EMS (Environmental Management System), clause 5.2 of the standard does leave some room for interpretation. At the same time, it also gives direction on what an environmental policy should contain and what it should provide for an organization. So, what exactly needs to be considered and included, and how detailed does the policy itself need to be?
Environmental Policy – changes to the basics
Our previous article How to write an ISO 14001 Environmental Policy examined the basics of how to write a policy. While this is still extremely relevant, there are some changes we should consider when writing the policy itself. Meeting legislation, setting objectives and ensuring continual improvement are all still mentioned, however there are certain other elements you must ensure that the policy now captures:
- The policy should be appropriate for the context and purpose of the organization, including the nature scale and impact of its activities: We examined “context of the organization” in the previous article Determining the context of the organization in ISO 14001, and it seems intuitive that the greater your organization’s environmental impact is, the more detailed this should be. If you consider the difference in impacts of the activities of a nuclear plant and a retail business, you may understand that, while both organizations may be certified to ISO 14001 and therefore have an environmental policy, the aspects and implications from the nuclear plant’s activities will be far greater. You can only decide how detailed this part of your policy needs to be only by truly considering the context of your organization.
- Prevention of pollution: This must now be considered in your environmental policy, as well as the inclusion of a commitment to environmental protection.
- Compliance obligations: This term now takes the place of “legislation.” It is closely tied in with identifying the needs of your interested parties. Some great information regarding this topic is available in the article Understanding the needs and expectations of interested parties in ISO 14001. Complying with legislation is now no longer enough, so it is likely that more detail will be needed to cover this requirement in your environmental policy.
So, are there any other requirements that we will need to consider in respect of the content of the environmental policy?
Environmental Policy – other factors to consider
Section 5.2 gives pointers on the policy, but does not specify all requirements. The clause regarding leadership suggests that the environmental policy must be aligned with the strategic direction of the organization; in other words, your environmental policy and its activities must be part of the organization’s overall vision and direction. The section suggests that your policy should provide a framework for setting out environmental objectives. It should also provide a commitment to the protection of the environment and the prevention of pollution, which is unique to the 14001:2015 standard. Compliance obligations and continual improvement must also be considered in this section. Again, how detailed you make this in your environmental policy will largely depend on the size and scope of your activities, as well as the possible resulting impacts. For example, I work with an organization that manufactures technology products that have longer lifecycles and are designed to be more easily recycled than market competition. In this case, that one statement in the environmental policy illustrates that the strategic direction of the organization and its environmental objectives are one and the same.
It is the job of each organization, and the leaders who communicate the environmental policy, to ensure that the level of detail for all these elements meets the needs of the organization, its customers, and any other interested parties. The level of detail you require will be heavily affected by the size of your organization, the scope of your activities, the size of your potential impacts and your interested parties. Consider what an external party viewing your environmental policy would think of the content. If you feel that there is no real value in a piece of information, then it may be better to place it elsewhere. Keep the level of detail relevant to the sector you operate in, ensure that this will promote confidence within your interested parties, and meet the terms of the standard. Remember: your environmental policy is an advertisement for your business. Treat it as an opportunity to showcase your company and its environmental principles.
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