Using a Parent Corporation's Environmental Policy Statement

[Marty50]

I am doing a survey for a company of around 500 employees to see wether they could obtain ISO14001 certification.

The company say they have adopted the Environmental Policy statement of their parent organisation a large multinational with a large range of industries across the world including the one I am looking at on this specific site. This policy, in my opinion, is not necessarily appropraite to the nature, scale and impacts of this site's activities, products and services. It is dated 2003 and not signed off by their CEO but rather the CEO of the parent body.

I have met with some concern to my recommending they should define their own policy statement that says what they do, is signed off by their own CEO and dated regularly to show that it is reviewed by senior management.

Annex A of ISO14001 suggests that an organisation should define the scope to clarify boundaries to which its EMS will apply, especially if the organisation is part of a larger organisation at a given location.

When setting the scope, it should be noted that the credibility of the EMS will depend upon the choice or organisational boundaries. If a part of the organisation is excluded from the scope of its EMS, the organisation should be able to explain the exclusion.

It also says its area of application (i.e. scope) should be clearly identifiable and should reflect the unique nature, scale and enviromental impacts of the activities, products and services within the defined scope of the EMS.

Looking at Singapore Airlines policy statement its starts with "We fly thousands of people all over the world every day....". Thats pretty clearly stating what they do and how they sit in the world. The policy statement I am looking at adopted from the parent organisation doesnt in any way indicate what this company does on this site.

My questions to you guys are:

Can an organisation adopt the policy statement of the organisation of which it is a part of to obtain accreditation for a particular site if that policy statement doesnt define what this site does?

How do we prove that its supported by local senior management if its signed off by only by the CEO of the parent organisation?

And how often is regularly reviewed; surely not every five years?

Marty

 

[Randy]

Re: Environmental Policy Statement

Marty50...............you posted this in your Profile and you have now provided evidence of it in all your postings

My recommendation would be that you get some education real fast before you get found out.

How did you find the Elsmar Cove Web Site?:
google
What information are you Searching for?:
have taken a job looking at iso14001 for a large company knowing nothing about it
Location:
australia
Company or School Name:
midland brick
Company Product(s), Processes and/or Services:
brick manufacture and sales
Company Size (Number of Employees):
~500
Your Occupation:
project manager/researcher
Phone:
61 892502849
Biography:
retired state manager of govt dept, quals in communication engineering, law and management just come out of retirement to take on project
Interests:
scuba diving, wind surfing, mountain biking, motorcycles, photography

We will go out of our way to help out, but there should at least be some kind of foundation to start with.

The org can adopt a policy and provide evidence of that in some type of memo or record. Breaking sweat over a policy statement that in essence will say....

"We the Acme Brick Company a manufacturer of bricks, commit ourselves to preventing pollution; complying with all applicable environmental laws and other requirements under which we have to operate; and to the continual improvment of our environmental performance through the establishment of environmental objectives and performance targets.".......

.....is like a real waste of effort.

The policy above took a whole 45 seconds to create.

Get a copy of ISO 14004:2004 to help as well.

 

[Marty50]

Re: Environmental Policy Statement

Thanks for the advice Randy,

I have already created an alternative policy statement for them not unlike your 45 second job but containing the elements of their preferred one but also including the requirements under 4.2.

But they seem to have a preference for the multi national parent company one that doesnt describe their business but rather starts with a definition for sustainability and saying they are committed to it.

And yes my experience with ISO14001 is limited to what have learned in the last five months and they knew that when they took me on. I was originally sceptical myself but have found my management experience helps me to take an outside view of the company and the statory interpretation form my legal background seems to work well with with ISO as it did with legislation.

I guess what I was hoping to find at The Cove was someone with practical experience as an auditor that could confirm yes or no you need to comply with the requirements of 4.2. I figured thats partly what this site is about.

The opionion I am currently expressing to them is that they need this if and when they decide to be audited. I wont be doing that audit for them but helping them to a position where they could pass.

Marty

 

[Randy]

If they insist on using the corporate policy there is nothing that restricts them from doing so and it is done by many organizations globally. The issues that come out of this practice are an ownership one and a real personal committment.

ISO 14001 is only as hard as you make it. What is says it what it means. You've already found a couple of great tools to help out, the 1st being Annex "A" (You'd be surprised the number of folks that never read that), and then this place (with the exclusion of me and my occasional rudeness).

There is a real strong "SEARCH" tool here and the best way to use it is in the "Advanced Search" mode so you can norrow things down.

Don't get into too much of a frenzy worrying over nits when using ISO 14001. Approach the thing in a methodical order and really pay attention to what the document is saying and what it requires. You'll find that every "clause" (that's 4.2, 4.3.1, 4.4.7, 4.5.5 and all the other numbers) are actually nothing more than a small "process" each with a specific input-required action-output, and almost always will require some documentation or record to show they were performed. The output's of the "clauses", more often than not, are the "inputs" into other clauses.

Hey, keep coming here and don't be discouraged by hard-butts like me.

 

[RoxaneB]

We have a Corporate level Environment Policy applicable to all our sites. It is signed by our top Corporate mangement, but the site copy is signed by the top person at the site. Anything that is specifically related to the site in regards to the EMS is detailed in the Business Management Systems manual.

 

[Marty50]

Randy, your advice is always very much appreciated I hope that when I am more experienced with this stuff I will be able to pass the benefit of my newly acquired knowledge on to others instead of asking so many questions.

I have always been very passionate about our environment including, as a PADI instructor/diver, under the ocean. I sometime annoy people by commending PADI's AWARE program to them. It is as a consequence of my voluntary involvment in environmental issues, including the cleanup of contaminated industrial sites, that lead me to where I am now. That is being paid to learn about ISO14001 and see if I can identify what this site need to do before they get an auditor in.

I have pretty good handle on the ISO14 documentation by now but lack literal interpretations of it. Randy I will use the advanced search facility here as you have advised.

Roxanne, thanks for the comment.

Can I ask the question do all your sites carry out pretty much the same business? What I am looking at is a multi-national that makes bricks on one site, runs a asphalt road making business on another, and has hotels as well. each has a very different set of aspects/impacts.

And I figure if they want to get accreditation for the brick making site they have to cordon that off and set policy for digging holes in the ground for clay to controlling their kiln air emissions. Unlike yours their "Policy Statement" is broad, does not mention what they do here, and signed off by the head of the multi national rather than the CEO for this site.

As an example under 4.2 (g) it states "is available to the public". This policy statement doesnt appear on their web site and no where can I find anything that says it has been adopted. I'm going to look for a way they can show an auditor that they have adopted it if thats what they want to use. I just figured it was easier to write a new one on what this site actually does and its impacts. Perhaps that better explains my dilemma. I will come to a solution soon but wonder if I am running against the heard.

Thank folks I really appreciate your input.

Marty

 

[Randy]

Thank you for the kind comments Marty.

You really will benefit from using the Search. I would also recommend that you just go into the ISO 14001 Forum itself and just start reading the Threads that interest you. There has been information contributed there since 1998 and you will find no greater free source of it anywhere.

As for their adopting the policy...all they have to do is make it a matter of record at any management meeting. The availability to the public is one of the easiest...on the internet is fine, but you can post it in a "public" lobby (where the general public has real access) or even nail it to a tree out front (just joking, but it's that simple). Just say how the public can get it and then do it.

 

[RoxaneB]

Can I ask the question do all your sites carry out pretty much the same business? What I am looking at is a multi-national that makes bricks on one site, runs a asphalt road making business on another, and has hotels as well. each has a very different set of aspects/impacts.

We are all in the same business, however our processes and aspects/impacts may be differ from site to site due to location, proximity to community, ecologically sensitive regions nearby, etc.

Personally, I think it is possible to develop a generic policy statement that applies to all of your organization and have the specific "stuff" in your manual and site-level processes.

As an example under 4.2 (g) it states "is available to the public". This policy statement doesnt appear on their web site and no where can I find anything that says it has been adopted.

Like Randy said, "available to the public" is rather open to you. I like the nailing it to the tree option, but some of us have a warped sense of humour here on the Cove. You could simply make it available by issuing it to anyone who calls up or asks for a copy.

Adoption can be accomplished through your orientation of new employees (i.e, training) and demonstrating that your site EMS complies with what is in the policy (and the ISO 14001 requires, all regulations, etc.).

 

[M Greenaway]

I dont see a problem with basing a site EMS on a corporate policy.

Yes your site EMS has to be specific to what is done on that site, but the policy does not necessarily have to be process specific in my opinion.

Its generic nature is probably the reason it has been unchanged since 2003, this also is not a problem in itself.

 

[Quality-Geek]

We basically have one policy - and one manual - for two sites. The sites are in similar industries but not the same. One site is automotive components, the other is seats for recreational vehicles (motorcycles, waterjets, etc.). Our auditor told us that we have to specify each site in our policy. So our policies are different in that they name the specific site. Otherwise, they are identical. We handle the differences in site requirements by having as much of the manual and procedures the same. Where there are differences, we specify that at the procedure and work instruction level.

We review the policy at least once a year in the Management Review meetings.

As for informing the public, we state that we will honor written requests for the policy, and we do so. Using an External Communications Log shows when we have done this, and who it was for.

By the way, I'm not a 14000 specialist, I'm a quality geek who "gets" to take over the EMS every time we lose an EHS coordinator. So I have a working familiarity of the system but that's about it.