I just took over the position of managing the EMS we got our initial certification and now are going for 2004. The person before me made the EMS a lot more complicated than it had to be. I am trying to simplify it and have questions regarding the verbage "maintain a procedure"

Does that mean it does not need to be in the EMS? For example 4.3.2 legal and other states that "the org shal...maintain a procedure" Do we need a written procedure if we can show that the legal and other requirements were identified and applied to the aspects?

Thanks

The short answer is that procedures need not be documented. See 3.19 (page 3 of the standard). The word "maintain" does indicate that the procedure will be accurate and up to date.

One additional thing....

4.4.4 e) requires documentation that you determine to be necessary to ensure the effective planning, operation and control of your processes. And 4.4.6 a) requires documented procedures where their absence could lead to a deviation. Both of these mean that although the standard does not require documented procedures, necessity might!

Hope that helps.

Can you effectively identify and keep track of your legal and other requirements without a documented procedure telling you how to do it? If the answer is yes, blow it off. If the answer is no, or would become no in your absence then document it. Other than what is specifically required in 4.4.6 you are the determining factor in what procedures get documented or not.