14001 - Environmental Manual for Multi-Location Enterprises

By Mark Kaganov

Since introduction of ISO 14001 Standard for Environmental Management Systems the market has developed numerous practical models of Environmental Manuals for organizations with single sites. At the same time, formats for management system structures for multi-facility businesses are limited at best in technical publications. This paper discusses a model for structuring a top-level documentation that allows an organization with multiple sites to use common ISO 14001 Environmental Management System Manual. Discussed approach noticeably improves consistency of the organization's Environmental policies.

As a professional EMS assessor with leading certification bodies, I audited many large multi-site enterprises that had problems with aligning their corporate ISO 14001 Environmental Manuals with the corresponding procedures issued by their locations. To fill this gap, some companies create Environmental Manuals for their locations as copies of the main Environmental Manual; other businesses develop location-specific Environmental Manuals that are completely independent form the home office Environmental Manual.

In reality, these solutions do not provide for a consistent representation of the organization's position on Environmental issues. The first approach, when a copy of the home office Environmental Manual is used, techniques for controlling local Environmental Manuals as a rule are not determined. Differences in the corporate Manual and the site's Environmental Manual are because the corporate office Manuals are managed by the home office, while site's Manuals are controlled by individual sites.

The 2nd approach, when companies permit their sites to establish their own Environmental Manuals, differences in all those Environmental Manuals lead to noticeable disconnect between the corporate and site-specific Environmental Manuals.

If an organization wishes to deliver a consistent message regarding its Environmental policies and their position on prevention of pollution, the deficiencies of discussed methods become obvious.

One of our large EMS customers demonstrated this point well. The corporate ISO 14001 Environmental Manual addressed majority of the requirements of the standard and referenced appropriate regulations. At the same time, one of their US locations did not define their Environmental policy, Mexico facility did not reference local legal requirements, yet their European site failed to document their Environmental programs all together!

Summarizing my EMS auditing and consulting experiences, I am convinced that these approaches to design of the corporate Environmental Manual and sites' Manuals do not provide a solid consistent way to document organization's Environmental Management System and Manuals.

To solve this problem, let's review an ISO 14001 Environmental Manual model, specifically supporting document reference structure. As a common practice, an Environmental Manual references supporting documents within the text of the Manual. For example, clause 4.3.1, Environmental aspects may read: Environmental Consultants Inc. has established, implemented and maintains Environmental Aspect Procedure to identify the environmental aspects of its activities, products and services and Significant Environmental Aspect Matrix to determine and document those aspects that have or can have significant impacts on the environment.

This method of referencing supporting procedures is very common for Environmental Manuals for companies with single location. Interestingly, it also works for a multi-site business for those documents that are common for all sites. For instance, Audit Procedure, Data Analysis procedure, and others may be common for all your sites and be referenced in your Environmental Manual as shown.

While references to common procedures in an ISO 14001 Environmental Manual are clear, we still have to address those documents that are specific to particular locations such as site-specific aspect, programs, Hazmat handling and others. When we wish to maintain just one Environmental Manual, we need to reference in it supporting procedures for all sites which may easily clutter the Manual. To solve this problem we will examine how a common Environmental Manual can efficiently reference facility-specific procedures to address statements of the organization's ISO 14001 Environmental Manual.

As with a single-location company, a business can still use discussed reference structure if the number of locations or sites is small; let's say not to exceed three. For example, clause 4.4.1 Resources, roles, responsibility and authority may read: Hazmat Experts Company ensures the availability of resources essential to establish, implement, maintain and improve the EMS per the Resource Procedure and the Organizational Chart HO and the Organizational Chart Singapore This example references the common Resource Procedure and site-specific organizational charts for Home Office (HO) and Singapore facility. This format works well for limited number of facilities, but it becomes ineffective when the number of company's locations increases.

If we need to work with a company that has significant number or offices and wishes to reference in the Environmental Manual procedures controlled by its sites, we may take a different approach. For example, we can prepare a matrix to associate the corporate Environmental Manual clauses with the site-specific procedures. We can name this tool Manual Reference Matrix and consider the following reference model:

Corporate ISO 14001 Environmental Manual element

Manual Reference Matrix Table of Contents (ToC)

Location Manual Reference Matrix

Facility document

We will structure our Manual Reference Matrix as a list of all facilities and their corresponding Manual Reference Matrixes, as shown below:

Manual Reference Matrix Table of Contents

Corporate Office (Dubai, UAE)

Toronto (Canada)

Cleveland, OH (USA)

Buenos Aires, (Argentina)

Los Angeles, CA, USA

etc,

To illustrate this model, let's document element 4.3.1 Environmental aspects of our corporate ISO 14001 Environmental Manual with references to site-specific significant environmental aspect matrixes: Environmental Consultants, Inc. has established, implemented and maintains Environmental Aspect Procedure to identify the environmental aspects of its activities, products and services and site-specific significant environmental aspect matrixes per the Manual Reference Matrix ToC. This example shows references to the common Environmental Aspect Procedure and site-specific Significant Environmental Aspect Matrixes. To locate a site-specific Matrix, we need to refer to the Manual Reference Matrix Table of Contents (ToC).

Let's say we need to locate a Communication Procedure for our Singapore plant. When we find this clause in our Manual Reference Matrix table of contents, we actually will connect to the location's Manual Reference Matrix. Finding the corresponding clause number in the site's Manual Reference Matrix, we will find a site-specific procedure title that addresses our clause of the Environmental Manual.

Our experience shows that a Manual Reference Matrix works well as a 3-column form with the 1st column titled Corp. Manual Section, the 2nd column Corp. References, and the 3rd column called Site References. For the element 4.5.1, for example, the St. Petersburg's Matrix indicates that Manual references Key Characteristics Matrix HO for the home office and Key Characteristics Matrix SP for the St. Petersburg site.

For examples of the Manual Reference Matrix, follow the links below.

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