What should be the content in the Environmental Policy?

[newkid]

Hi guys,

Hope someone can help me with this. What should be the content in the Environmental Policy?

My company was issued a non-conformity by a certification body recently as the Environmetal Policy did not include the statement "..... available to the public". The auditor also commented that "ISO 14001" needs to be written in the policy (he didn't raised this though).

Are these requirements mandatory and what do you think of the auditor's comment?

Thanks.

 

[BadgerMan]

We just post our policy in the entrance to the lobby. No auditor has ever had an issue with that. There is no such language within our policy.

 

[Dean P.]

I think the auditor is wrong in both comments. First, you don't have an ISO14001 system, you have an Environmental Management System. No where in 4.2 does it mention, or even imply, ISO14001 (or any standard for that matter).

Second, the policy has to be available to the public. It doesn't have to say that, you just have to prove that it is. Post it in your lobby, and your satisfy this requirement. About the only items that have to be in a policy are to define the scope of your EMS, commit to continual improvement, commit to pollution prevention, and commit to obeying the law. There are a few things that should be in there as well, but don't necessarily have to (refer to objectives and targets, for example).

I would challenge your auditor on this. Don't form your policy to match what the auditor thinks it should be, form it to comply with 4.2, but most importantly, make it meaningful to your organization.

Dean

 

[Claes Gefvenberg]

Are these requirements mandatory and what do you think of the auditor's comment?

I think you already know the answer? Dean is quite right and the auditor is making a prize fool of himself... I sincerely hope that he was able to provide you with some useful input as well?

Anyway:

4.2f tells us that the policy must be available to the public, not that the text should say so. One simple way to comply with the requirement is to post it on your internet site and/or send it to anyone saking for a copy.

Why it should have to mention ISO14001 is beyond me... I would like to see him show me the requirement.

/Claes

 

[Randy]

Another case of an auditor making it up as he goes. Listen to Dean.

 

[IEGeek - 2006]

We posted in our lobby, added it to our website and even took out a small ad in a trade magazine congratulating our employees. This was advised by our consultant as well. Our auditor really had no comment on the issue, but I think we all remember the infamous consultant debacle I encountered, for those of you that dont remember, just try and think of the worst consultant story you have ever heard and multiply it by 100 and you would be close to our experience.

I agree with Dean, Clas and Randy, post it in the lobby and be done with it. A public posting is the most minor part of an environmental system. Identify your significant impacts and aspects and work on those. That's the bottom line.

Just some thoughts.....

 

[Randy]

You learned well Grasshopper...

 

[newkid]

thanks guys. would know what to do now.

 

[jmurph01]

I agree with everyone else that commented but had an additional thought... we state in our EMS procedures that we have a policy and that it is available to the public. maybe the auditor was looking for this in your procedures, not in the policy?? or maybe he's an idiot! who knows!!!

As an example this is what our procedure says, including the commitment to have it available to the public:

PROCEDURE AND RESPONSIBILITIES

3.1 The Director of Operations and a cross functional team defines the environmental policy and ensures that it is:

a) Appropriate to the nature, scale and environmental impacts of our activities, products and services;
b) Includes a commitment to continual improvement and prevention of pollution;
c) Includes a commitment to comply with applicable environmental legal requirements and other environmental requirements to which the organization subscribes which relate to the environmental aspects;
d) Provides the framework for setting and reviewing environmental objectives and targets;
e) Documented, implemented, and maintained;
f) Communicated to all persons working for or on behalf of the organization;
g) Made available to the public

3.2 The environmental policy will be reviewed through internal audits to ensure that it is still relevant to the operations. Recommended changes will be reviewed during the management review meetings.


our policy is posted on our website and in the reception area and that meets our procedure. As far as I know, it wouldn't actually be required that you have written in your procedure that it is available to the public and I can only see this being a concern on an audit if it was in fact not available.

hope this helps.

 

[Claes Gefvenberg]

we state in our EMS procedures that we have a policy and that it is available to the public.

Good point, Murph. So do we.

our policy is posted on our website and in the reception area and that meets our procedure. As far as I know, it wouldn't actually be required that you have written in your procedure that it is available to the public and I can only see this being a concern on an audit if it was in fact not available.

Exactly. I have nothing further to add.... Except maybe the old and often repeated plea to auditors:


Audit acc. to the standard concerned, not your own opinions! It will make all our lives (particularly your own) so much easier. Thank you.


/Claes