The new version of ISO 14001 puts an incredible amount of emphasis on the top management of an organization. Previously, it was still well known that unless the top management is on board in terms of implementing and environmental management system (EMS), it’s nearly impossible to have an effective and well functioning EMS. The terms “top management”, “senior management” and “leadership team” have been used interchangeably in this article.
Based on my experience in five (5) different countries of auditing and consulting, I’ve witnessed some different scenarios:
1. Top management feels like the EMS and ISO 14001 certification is useless and nothing but a paperwork burden, a waste of time and energy. EMS is implemented at its bare minimum. The only reason it’s implemented is either because a customer or corporate requires it.
2. Top management appointed a person with no environmental background or training to implement the EMS on their own, and the person does not have the resources, the authority or the knowledge to do anything. In addition, the appointees are not supported by top management.
3. Top management is heavily involved and hands-on in implementing the EMS. They support the environmental department, they walk the talk, and they established a good bridge between the environmental department and the operations.
Of course, these are not the only scenarios that can be seen out there! It’s not that hard to guess which EMS will function well and be successful right? You guessed it, it’s number 3!
It’s so important to understand that without the full involvement and support of the top management, it just won’t work!
Let’s take a quick look of what ISO 14001:2015 requires from top management:
- Overall responsibility of the EMS effectiveness
- Ensuring that the strategic direction of the organization is in line with the EMS objectives, environmental policy, internal and external issues of the organization, EMS intended outcomes and interested parties and their requirements from the organization
- Allocation of proper resources: human, financial, knowledge and any other resource that would be required to effectively implement the EMS
- Being knowledgeable about the regulatory compliance status of their organization
- EMS has to be integrated with the company’s activities. EMS needs to be interlinked with business instead of being implemented separately. It’s the senior management responsibility to make this become a reality.
- Effective EMS communication
- Effective EMS support
- EMS continual improvement
There has to be demonstrable evidence for these requirements. Obviously, trying to get ready three days before a registrar audit may not be a good idea!
How can the leadership team demonstrate these requirements? There are so many different ways. I will share the ones that I witnessed working the best for different companies:
- Periodic environmental site inspections (weekly, monthly, etc.) They could be alternated among the leadership team members.
- Staff meeting agendas including EMS items
- Giving priority to EMS issues and corrective actions. It never looks good when an auditor comes on site, and observes that the EMS corrective actions have not been fixed for months, and no action was taken by the senior management.
- Leadership team attending ISO 14001:2015 or other EMS related courses (i.e. webinars, internal auditor, regulatory, etc.)
- Leadership team understanding ISO 14001:2015 requirements including EMS and regulatory expectations
- The visibility of adequate resource allocation at a facility: evaluation of compliance is conducted by competent people with proper background, the EMS is not individualized (facility-wide high engagement level), EMS representatives are well trained, etc.
- Holding management teams accountable
- Applying effective enforcement
- Each senior management team will be responsible for an environmental program. For example, the plant manager can own the stormwater program, and the director of operations can own the hazardous waste program, etc. They can delegate the requirements of these programs, however, ultimately, they would be responsible of correct and compliant implementation of those programs.
- Aligning operational key performance indicators with EMS objectives and actions planned.
- Incorporating EMS requirements into performance reviews, bonus structures throughout the organization.
These are just a few examples.
My advice to environmental staff who are working on ISO 14001: Please make sure that your leadership team is aware of all these requirements.
My advice to the members of the leadership team: Please understand and be aware of ISO 14001:2015 requirements and the environmental regulatory responsibilities of your company including the needs and expectations of all your interested parties.
Please support your environmental folks by empowering them with proper resources and authority. Always remember that establishing, implementing and maintaining an EMS is never only one person’s job, but it belongs to the entire company and ultimately, you, as the leadership team of the organization, are responsible for the success of your EMS.
Thanks for reading and good luck!
Mel DeGregorio ISO 14001:2015 Lead Auditor