Procedures in Communication, Operational Control, etc. - ISO 14001

[Daminda]

In 3.19 standard says about Procedure. It says "specified way to carry out activity or a process". But there is no details that need to cover under Procedure(s).

The Standard mention about establishing, implementing and maintaining procedures in Communication, Operational Control, Evaluation of Compliance and etc.

Can any one explain me the patterns and the things that should be included when documenting "Procedures" to above mention areas?.

I think, there should be one "Communication Procedure" for a company but there can be many "Operational Control Procedures". Is it better to keep one good format for Procedure writing.

The standard also says that " Procedure can be documented or not". Then how the company prove the verbal Procedure is enough? and how the auditors prove that verbal is not enough?

 

[db]

There is no requirement for any of those to be documented, however many companies decide to document procedures to ensure continutiy and constancy in the operation of processes.

The best way to write the procedure is to flow chart the major steps of the process. Then you can add details about each step, showing responsibilities, resources, information, metrics and the like. Add as much detail as the process operators need.

For example, in the process for communication. What are the basic steps you use to communicate? Then who performs which step? What resources, information, materials, etc are needed? How will you know the step was performed properly? All of these questions could be asked for each step of the process. And as needed, that information could be included in the procedure (which is the annotated flowchart, or a narrative of the steps you outlined in the flowchart)

Hope that helps

 

[Daminda]

Mr. Dave,

Your explanation helped me lot.We are a construction company. We have sites at all over the country and performs different activities in different sites. Is it better to keep one good Procedure format (covering all needs) to avoid the generation of different patterns?.

Auditors ask for documented procedures specially in the area of "Operational Control" always. Please attach if you have any sample procedures.

Can you please explain me the item "4.4.6 Operational Control". Specially "The organization shall identify and plan those operations that are associated with the identified significant environmental aspects consistent with its environmental policy, objectives and targets, in order to ensure that they are carried out under specified conditions,"

 

[db]

Your explanation helped me lot.We are a construction company. We have sites at all over the country and performs different activities in different sites. Is it better to keep one good Procedure format (covering all needs) to avoid the generation of different patterns?.

That would depend on if the activites were very similar. If there is a good deal of variation between sites, then a site-specific procedure would be more beneficial. Another option (and I think the best) would be to have one generic procedure to cover all sites, but have site specific addendums to cover the variations.

Auditors ask for documented procedures specially in the area of "Operational Control" always. Please attach if you have any sample procedures.

I will try to find something to attach, but at best it would only be a reference. You need to have something that meets your individual needs. BTW, although auditors may ask for documented procedures, no documented procedure is required by the standard.

Can you please explain me the item "4.4.6 Operational Control". Specially "The organization shall identify and plan those operations that are associated with the identified significant environmental aspects consistent with its environmental policy, objectives and targets, in order to ensure that they are carried out under specified conditions,"

The operational controls relate to your significant aspects. So, therefore, they probably should not be conflicting with your EMS. For example, part of the environmental policy has to include prevention of pollution. Your operational controls probably should not include dumping construction waste in a local ditch. In most cases, operational controls will be spelled out in the environmental programs. In some cases, you add environmental operational controls into the normal process control.

Hope that helps.

 

[Daminda]

Mr Dave,

Thank you very much for the help. One question remains with me Sir, Are Operational Controls based on to "Activities" or "Aspect"?

 

[db]

Mr Dave,

Thank you very much for the help. One question remains with me Sir, Are Operational Controls based on to "Activities" or "Aspect"?

The short and confusing answer is yes. Now for the explaination. Aspects are elements of your activites, products and services. So, in regard to operational controls, we typically control the activity. However, there may be times when we control the product, such as in storage of liquids. You might have operational controls that involve inspection, maintenance, etc of liquid storage containers. Moving the liquid is an activity, so you would have operational controls for that activity.

I have found that most operational controls will be on the activity, because that is where the aspect is at greatest risk for variation. Make sure you consider start up, shut down, normal operation and emergency operations.

Hope that helps.

Good questions!

 

[Randy]

Mr Dave,

Thank you very much for the help. One question remains with me Sir, Are Operational Controls based on to "Activities" or "Aspect"?

Neither and both........They are based on meeting the requirement of controlling significant aspects to prevent not fulfilling or meeting policy commitments (continual improvement, complying with applicable legal and other requirements, preventing pollution) and achieving objectives and targets.

Your "controls" must also contain specific language about operational criteria, performance parameters and operational charaterisitics that can be monitored and/or measured to ensure ability/adequacy of meeting requirements and the effectiveness of the control itself.

 

[Daminda]

Can anyone please explain me, do we have to write Operational Controls only for significant aspects?.

 

[Randy]

Here's what ISO 14001 states and only you can figure out how to make it work for your organization.

The answer is right in front of you...........

4.4.6 Operational Control

The organization shall identify and plan those operations that are associated with the identified significant environmental aspects consistent with its environmental policy, objectives and targets, in order to ensure that
they are carried out under specified conditions, by

a) establishing, implementing and maintaining a documented procedure(s) to control situations where their absence could lead to deviation from the environmental policy, objectives and targets, and

b) stipulating the operating criteria in the procedure(s),

 

[Daminda]

Sir, according to the standard I understand Operational Controls only for activities that are associated with the identified Significant Aspects. But our Auditor asked operational controls for every activity.

I want to clarify this. What was point applied by our auditor?.