ISO 14001 Environmental Policy Content

[Randy]

The auditor is messed up in his/her reasoning

You can say "prevent pollution" if you want or state "minimize negative environmental impact" or anything else that can be construed to mean the same thing....It ain't so much how you say it as it is how you do it.

Now if you used all those words you said you did... “seek to minimise waste arising, promote recycling, reduce harmful emissions and, where possible, to work with suppliers who themselves have sound environmental policies.” you're gonna have to prove to me (provide solid objective evidence) that you are:
seeking,
promoting,
reducing,
working, and
provide a definition for what is considered "sound environmental policies"
(You gotta quantify this stuff)

Your policy is 100% auditable and actually becomes an "other requirement" you have to meet under clause 4.3.2 and is in fact an objective of sorts.....It's a self inflicted wound!

 

[gstewart]

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

I don't know if this is still a live thread after such a long time, but I have a similar issue.

An auditor who got very literal on me didn't like our policy stating "minimize the impact on the environment".

I personally don't like to say we will "stop pollution" because this is a total lie.
We will not stop putting out a small amount of exhaust from various processes, and we will not stop producing prescribed waste and other rubbish.

What we will in fact be doing is looking for ways to reduce the above and when introducing new processes and facilities we will be taking pollution and the environment into consideration.

We in fact use a global policy covering environmental and quality issues, and now it looks like we need to opt out, to fulfil the needs of one pedantic guy. ( our parent company has had no issues being audited against the same policy ).

If there is a procedure which is an expanded interpretation of the policy can that be a solution?

 

[insect warfare]

An auditor who got very literal on me didn't like our policy stating "minimize the impact on the environment".

That phrasing is ambiguous. The wording of it implies that all impacts are negative and must be minimized, and does not give consideration to positive impacts, which should be promoted.

I personally don't like to say we will "stop pollution" because this is a total lie.
We will not stop putting out a small amount of exhaust from various processes, and we will not stop producing prescribed waste and other rubbish.

Since pollution is a negative aspect and cannot be completely eliminated in certain scenarios, you do want to minimize its impact through prevention. What you choose to state about this should never be taken to mean something that is impossible or impractical to achieve.

What we will in fact be doing is looking for ways to reduce the above and when introducing new processes and facilities we will be taking pollution and the environment into consideration.

We in fact use a global policy covering environmental and quality issues, and now it looks like we need to opt out, to fulfil the needs of one pedantic guy. ( our parent company has had no issues being audited against the same policy ).

You do not have to submit to pedantics in order to have a well-rounded policy statement. It just needs to be appropriate to the scope of your organization. If your parent company already has a well-defined policy, then there may be no need to duplicate their efforts, but if their policy does not include what you do, a site policy may be what's needed, provided it supports the corporate one and does not come into conflict with it. Or you could consider reviewing and (possibly) revising the corporate policy instead.

If there is a procedure which is an expanded interpretation of the policy can that be a solution?

Your EMS objectives and targets should always serve as your expanded interpretation of the EMS policy. That is what makes your policy auditable.

Brian

 

[gstewart]

I'm really not concerned about "positive/negative" impacts ambiguity.
Simply there is nothing within the scope of our operation that will cause positive impacts to the environment. We are not cleaning the air, or putting out wastewater that is cleaner than we got it, and we won't be. We wont be planting any new tree's on our small strip of concrete so I'm quite happy to assume that any environmental impact we have will be negative.

The corporate thing is driving me nuts. Our parent company is much more sizeable and has the same and additional potential to cause environmental impact, yet their auditors have never questioned the policy, maybe it translates better in other languages.

 

[Helmut Jilling]

I don't know if this is still a live thread after such a long time, but I have a similar issue.

An auditor who got very literal on me didn't like our policy stating "minimize the impact on the environment".

I personally don't like to say we will "stop pollution" because this is a total lie.
We will not stop putting out a small amount of exhaust from various processes, and we will not stop producing prescribed waste and other rubbish.

What we will in fact be doing is looking for ways to reduce the above and when introducing new processes and facilities we will be taking pollution and the environment into consideration.

We in fact use a global policy covering environmental and quality issues, and now it looks like we need to opt out, to fulfil the needs of one pedantic guy. ( our parent company has had no issues being audited against the same policy ).

If there is a procedure which is an expanded interpretation of the policy can that be a solution?

What you are describing is EXACTLY the intent of ISO 14001...the way it is written, it clearly does not expect companies to have ZERO environmental footprint. Rather, to assess the current footprint, and seek ways to REDUCE it. Thus, an insurance office has the same responsibility to shrink their footprint, as a heavy industrial concern...the principle is that everyone does what they reasonably can, to reduce their footprint. That way, everyone benefits from a cleaner environment.

 

[Randy]

The auditor didn't like? Tell the auditor to stuff his likes or dislikes because they're not to be any part of the equation.

There is absolutely no one single requirement that says you must state something verbatum...Not one!

Prevent Pollution is not stop pollution....The intent of "Prevent Pollution" is to take a pro-active, at the beginning of the process approach to environmental management, and that is what has to be evident to the auditor or anyone else. You're doing stuff from the git-go to reduce or minimize the potential for adverse environmental impact instead of waiting for it to happen resulting in a requirement to "mitigate"....It doesn't matter what you call it, it matters just matters that it's understood what you mean and it matters what you do.

Tell the lame-a%% auditor to choke on his likes!

 

[gstewart]

The auditor didn't like? Tell the auditor to stuff his likes or dislikes because they're not to be any part of the equation.

There is absolutely no one single requirement that says you must state something verbatum...Not one!

Prevent Pollution is not stop pollution....The intent of "Prevent Pollution" is to take a pro-active, at the beginning of the process approach to environmental management, and that is what has to be evident to the auditor or anyone else. You're doing stuff from the git-go to reduce or minimize the potential for adverse environmental impact instead of waiting for it to happen resulting in a requirement to "mitigate"....It doesn't matter what you call it, it matters just matters that it's understood what you mean and it matters what you do.

Tell the lame-a%% auditor to choke on his likes!

I've decided to do just that, but I may change the wording a little.
I've written out a comprehensive review of our policy and I actually prefer the term environmental impact to pollution.
It seems clear that all pollution causes a negative environmental impact.
But there are other grey area's like CO2. Is CO2 a pollutant? it's a natural part of the environment, its not poisonous. However if it causes and environmental impact the argument is moot.


Unfortunately I'm now stuck on how our policy addresses " other requirements "

I'm sorely tempted to change to a new policy that simply states.

We will:

1. continually improve and prevent pollution,
2. comply with applicable legal requirements and with other requirements to which
the organization subscribes which relate to its environmental aspects,
3. routinely review environmental objectives and targets,
4. Tell our auditor to choke on his likes.

NOTE "this policy is available to the public" .

 

[Randy]

CO2 not poisonous?

Maybe not, but try breathing a 50% atmosphere of CO2 and see how long you last

Try this one on for size..

We the XYZ Company promise to not break any relevant environmental laws and abide by other environmental obligations imposed upon us.

We also promise to do our best to not cause damage to the environment and to do those things that we can to keep such things from happening.

We also promise to do things better and better all the time and will establish goals that will help us do so

There's nothing, not one blessed thing that says you have to use the exact language from clause 4.2...And your auditor can choke on it

Oh yeah, you don't have to mention the public in your policy either and you can nail it to a tree in front of your building to make it available

Doesn't have to be dated or signed either....Just a known revision

 

[gstewart]

Yeah I know, you cant breath a lot of Nitrogen or water either. As I said you can quibble over this, but impact on the environment

FWIW your policy wording would suit me fine. I think its foolish to quibble over wording, its the actions a company takes under that policy that matters most to me.

I've just be reading our last report.
He states that there is no "explicit" commitment to the prevention of pollution.
I challenge him find a way to cause pollution without voiding the term, "minimize the negative impact on the environment".

 

[Randy]

I challenge him find a way to cause pollution without voiding the term, "minimize the negative impact on the environment".

I've accepted more than 1 with almost the exact same phrasing and I've looked at more than 2 policies in my career

If you appealed this you'd most likely win especially if it went to ANAB. How do I know? I've seen it done and I had to follow up after the "person" who wrote the NC to begin with