5468_14001pitfalls_0206.qxd 5/6/06 9:36 AM Page 26
THE ROUTE TO 14001:2004 THE ROUTE TO 14001:2004
Avoiding the Pitfalls Avoiding the Pitfalls
The ‘resources’ part is rather more difficult since it may only 4.4.2 COMPETENCE TRAINING AND AWARENESS
be apparent when the resources are not in fact provided!
The ‘Management Representative’ is the person (or
It is pointless having an EMS if the people who should make it work
sometimes persons) who ensures the EMS is established,
are not competent, are untrained, or are not aware of the existence of
implemented and maintained and who reports on its
the company’s policy and procedures.
performance to Senior Management.
KEY REQUIREMENTS
COMMON PITFALLS
a73 identification of training needs and competence relative
to significant aspects
a73 It may not always be clear who is responsible for what.
This can be a common fault of system documentation
a73 staff awareness of environmental issues related to their job
which is based on flow charts.
a73 provision of necessary training and records to
substantiate this
a73 Sufficient resources may not have been made available.
A situation was encountered where the EMS manager
a73 awareness of people working for or on behalf of the organisation
had been made redundant and the new incumbent was
clearly not adequately trained to fill the post.
COMMON PITFALLS
a73 Occasionally the ‘environmental’ expertise is bought in by
a73 On another occasion, ‘head office’ had decided not to fund
the programme which was dealing with the organisation’s
an organisation. This is perfectly acceptable, but needs to
most significant aspect (a study to establish whether the site
be recognised and maintained within the EMS, including
was contaminated).
any relevant training or competence records relating to the
bought-in expertise.
a73 Management Representative function shared between
two individuals without clear definition of responsibility to
a73 As will be seen later, there is a need for the audit resource
ensure the whole of the function is covered.
to have a knowledge of ISO 14001. This issue may not be
covered and auditors may well know how to audit to
establish compliance with procedures but may not be
STRUCTURE AND RESPONSIBILITY a19 OR ✘ COMMENT/PLAN
capable of verifying that the procedures themselves
Responsibilities for EMS clearly defined
comply with ISO 14001.
in manuals, job specs, organisation
charts, procedures etc? a73 On many occasions it is found that staff are neither aware
Staff aware of responsibilities?
of, nor trained in, the relevant emergency procedures.
Management Representative appointed?
a73 Awareness of non-conformance criteria and procedure
Responsible for reporting to may often be poor. This leads to the non-reporting of
management review?
problems and eventually to repetition of the problem
Trained and competent?
rather than its prevention.
Resources defined and adequate?
a73 Occasionally the Aspects evaluation has missed or
misunderstood important issues due to a lack of training
or competence on the part of those carrying out this vital
process, eg not realising that Halon fire extinguishers contain
ozone-depleting substances (Chloro-Fluoro-Carbons).
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