ISO 14001 Environmental Policy Content

D

dylangaudi

#1
My question is regarding the content of the environmental policy. I am an intern that is responsible for starting the environmental management system at a product packaging manufacturer. Right now as an EMS committee we are reviewing our proposed env policy before submitting for upper management approval. The question is regarding the inclusion of "committment of prevention of pollution". Members on the EMS committee feel that the term pollution gives a negative conotation and that we should find a way to exclude it from the policy. Attempting to meet this challenge I am concerned with the fact that the standard states, "b) includes a commitment to continual improvement and prevention of pollution."

As of now I have attempted to replace this point with "We will actively seek to reduce our impact on the environment by establishing objectives and targets that aim to continually improve our overall environmental performance."

I know how important an appropriate environmental policy is to the EMS and want to get it right the first time and avoid any red flags or noncomformances. I would appreciate any and all feedback. Thanks for your time

 
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Randy

Super Moderator
#2
If you say "We will actively seek to reduce our impact on the environment by establishing objectives and targets that aim to continually improve our overall environmental performance." , my question as an auditor could be

"Are you going to reduce you negative or positive impact?"

The phrase you want to use is very unclear, whereas to practice "pollution prevention" is clear and proactive

But, as long as you can both explain and demonstrate "prevention", you can call it anything you want
 
D

dylangaudi

#3
Would including the word "negative impacts" be more clear? The term pollution just comes off as very negative to the committee but they understand that the policy must be appropriate to the standard and our manufacturing processes. We are a zero landfill plant, and we have very effective recycling programs in place. We still have a long way to go till our certification audit, and we want to establish a policy that will be as effective as possible the first time around.
 

kgott

Quite Involved in Discussions
#5
My question is regarding the content of the environmental policy. I am an intern that is responsible for starting the environmental management system at a product packaging manufacturer. Right now as an EMS committee we are reviewing our proposed env policy before submitting for upper management approval. The question is regarding the inclusion of "committment of prevention of pollution". Members on the EMS committee feel that the term pollution gives a negative conotation and that we should find a way to exclude it from the policy. Attempting to meet this challenge I am concerned with the fact that the standard states, "b) includes a commitment to continual improvement and prevention of pollution."

As of now I have attempted to replace this point with "We will actively seek to reduce our impact on the environment by establishing objectives and targets that aim to continually improve our overall environmental performance."

I know how important an appropriate environmental policy is to the EMS and want to get it right the first time and avoid any red flags or noncomformances. I would appreciate any and all feedback. Thanks for your time
I know this is a little off topic but seening how you are starting out this may be helpfull when writing documents. I was once told by someone who knew a lot more than me, to not use the word contaminents or contaimate.

The reason was is that these words have legal implications and may infer liability. The person went on say that its for the courts to determine if contamination occured. The advice was to use words/phrases like 'emmission of pollutents' instead.

I appreciate this may lot apply in your particular legislative environment in which case my appologies for posting off topic material.
 
S

ssz102

#6
i think the policy should be describle the awareness amd improve direction for your company
so take this policy for example such as save resource continually and stop pollution
 
G

Graruss

#7
Following on from the posts on policy content I would welcome any discussion an advice. We have a policy which includes ?seek to minimise waste arising, promote recycling, reduce harmful emissions and, where possible, to work with suppliers who themselves have sound environmental policies.?
As an engineering company we cut steel, weld, use natural gas for heating and use motor vehicles, therefore we have emissions. The Auditor said that the policy does not include the statement ?to prevent pollution? and therefore is a non conformance. I tried to reason that the core activities will have emissions and as I see it a degree of pollution. Am I misinterpreting this clause and requirement of the standard?
 
G

Graruss

#8
Can anyone give any advice or guidance regarding my earlier post.

Following on from the posts on policy content I would welcome any discussion and advice. We have a policy which includes ?seek to minimise waste arising, promote recycling, reduce harmful emissions and, where possible, to work with suppliers who themselves have sound environmental policies.?
As an engineering company we cut steel, weld, use natural gas for heating and use motor vehicles, therefore we have emissions. The Auditor said that the policy does not include the statement ?to prevent pollution? and therefore is a non conformance. I tried to reason that the core activities will have emissions and as I see it a degree of pollution. Am I misinterpreting this clause and requirement of the standard?
 

Colin

Quite Involved in Discussions
#9
Can anyone give any advice or guidance regarding my earlier post.

Following on from the posts on policy content I would welcome any discussion and advice. We have a policy which includes ?seek to minimise waste arising, promote recycling, reduce harmful emissions and, where possible, to work with suppliers who themselves have sound environmental policies.?
As an engineering company we cut steel, weld, use natural gas for heating and use motor vehicles, therefore we have emissions. The Auditor said that the policy does not include the statement ?to prevent pollution? and therefore is a non conformance. I tried to reason that the core activities will have emissions and as I see it a degree of pollution. Am I misinterpreting this clause and requirement of the standard?
Technically the auditor is correct - para b) states that the policy must include a commitment to continual improvement and prevention of pollution. In practice you have made a commitment to reduce emissions which is one source of pollution but there are others.

I can only think that the auditor was concerned about something else or s/he is just one of those people who want everything done by the letter of the law.
 

Sidney Vianna

Post Responsibly
Staff member
Admin
#10
I think that if an auditor forces an organization to blindly and meaninglessly regurgitate the standard, s/he is not adding much. It seems to me that the organization in question is ADDRESSING prevention of pollution in relation to the significant impacts and aspects which are part of their EMS. What is the point of forcing an organization to have the words in the policy, if they don't follow through in the real world?

Prevention of pollution, in the context of the ISO 14000 family of documents is a broad concept:

3.22 - prevention of pollution
use of processes, practices, techniques, materials, products, services or energy to avoid, reduce or control (separately or in combination) the creation, emission, or discharge of any type of pollutant or waste, in order to reduce adverse environmental impacts (3.8)

NOTE Prevention of pollution can include source reduction or elimination, process, product or service changes, efficient use of resources, material and energy substitution, reuse, recovery, recycling, reclamation and treatment.
Practical help — Prevention of pollution
Prevention of pollution can be incorporated into the design and development of new products and services, as well as into the development of associated processes. Such strategies can, for example, help an organization to conserve resources and reduce waste and emissions associated with products and services. (Guidance on product design concepts and practices can be found in ISO/TR 14062.)

Source reduction can often be the most effective practice because it has the double benefit of avoiding the generation of waste and emissions and simultaneously saving resources. However, prevention of pollution through source reduction may not be practicable in some circumstances and for some organizations. The organization should consider using a hierarchy of approaches for prevention of pollution. Such a hierarchy should give preference to preventing pollution at its source, and can be structured as follows:

a) source reduction or elimination (including environmentally sound design and development, material substitution, process, product or technology changes and efficient use and conservation of energy and material resources);
b) internal reuse or recycling (reuse or recycling of materials within the process or facility);
c) external reuse or recycling (transfer of materials offsite for reuse or recycling);
d) recovery and treatment (recovery from waste streams on or offsite, treatment of emissions, and releases on wastes on or offsite to reduce their environmental impacts);
e) control mechanisms, such as incineration or controlled disposal, where permissible. However, the organization should use methods such as these only after other options have been considered.
 
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