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THE ROUTE TO 14001:2004 THE ROUTE TO 14001:2004
Avoiding the Pitfalls Avoiding the Pitfalls
APPROPRIATE a73 Problems can arise when the Policy is written with good
It is rare to find a Policy that is not appropriate to an organisation; intent or overzealous expectation of what the organisation
however it is good practice for the opening paragraph of thePolicy can do. For example your Policy might state a commitment
to give a brief idea of the organisation’s business sector so that to waste reduction and reduction in energy use; the EMS
the Policy can be viewed in context - the ‘scope’ of certification must keep such promises. They will need to be delivered
should also be detailed here.
by Objectives, Targets and Programmes.
This is, after all, the only document which ISO 14001 requires to
Anyone who reads your Policy will have a reasonable expectation
be available to the public.
that it represents what you do and how you act.
COMMITMENT TO PREVENTION OF POLLUTION AND TO
DOCUMENTED, IMPLEMENTED, MAINTAINED AND
CONTINUAL IMPROVEMENT
COMMUNICATED TO ALL EMPLOYEES
a73 Occasionally these commitments are more inferred than
a73 The ‘documented’ part is straightforward
explicitly stated in the Policy. This can lead to confusion
since the Policy should be understandable and clear. It is
a73 ‘implemented’ alludes to the need to deliver the Policy
right to show this commitment clearly and it is perfectly
in detail; ie keeping its promises
acceptable to use the exact words from the standard in a73 ‘maintained’ refers in part to making sure it is kept
your Policy - this gives a very clear mandate and direction up-to-date and relevant (this is partly covered by 4.6
to the Environmental Management System (EMS). It is part Management Review)
of the foundations of environmental management.
a73 ‘communicated to all employees and people working behalf
of the organisation’ is where most difficulty occurs
COMMITMENT TO COMPLY WITH RELEVANT LEGAL AND
OTHER REQUIREMENTS Third-party auditors always check knowledge and understanding
It may seem superfluous for a chief executive to sign a statement
of Policy with personnel encountered during the audit. They do
which commits to legal compliance - after all this is never optional!
not expect a word-for-word chant of the Policy! What they do
A commitment to legal compliance is another fundamental part of
expect to find is a knowledge that it exists, an idea of where to
an EMS and as such deserves a place in the Policy.
find it, and some idea of the relevance of the EMS to the
employee and of the organisation’s actions regarding
The matter of ‘relevant other environmental requirements’ to which
environmental management.
the organisation subscribes can be more difficult. The Policy should
indicate any other pertinent requirements to which the organisation
So to sum up, the Environmental Policy is the cornerstone of
subscribes, eg the Chemical Industries Association Responsible
an EMS. If it makes promises or raises expectations they must
Care Programme. This is because the Policy is the only (mandatory) be delivered. It is the only part of your system that must be
public window into an EMS and those who read it should made available to the public, your employees and contractors
understand the key issues and intentions of the organisation as must know about it and its relevance to them.
regards the environment.
PROVIDE A FRAMEWORK FOR SETTING OBJECTIVES
AND TARGETS
This can cause some difficulty, but again it underlines the need to
show in the Policy that you have objectives and targets and also
gives an idea of the key areas in which these are set.
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