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Small and medium size businesses with a single location that employ ISO 14001 Environmental Management System have developed solid models for the top level documentation. At the same time, information on Environmental Manuals for multi-facility companies has not been addressed in professional publications. This publication proposes a model of an Environmental Manual for establishing the top-level documentation structure that allows a business with more than one site to use a common ISO 14001 Environmental Management System Manual.

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 the first case, when a site-specific Environmental Manual is a copy of the corporate Manual with modifications specific to a given site, mechanisms to keep these documents coordinated are rarely defined. Difficulties of keeping these documents in sync are due to the fact that corporate Environmental Manuals are controlled by the home office, while local EMS Manuals are responsibility of site’s documentation control departments.

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.

Those companies that adhere to the policy of maintaining a consistent corporate message regarding their position on Environmental issues will definitely experience a gap if they use methods that we discussed above.

As an example, we can examine one of our international clients with facilities in the United States, Thailand and Europe. This organization established pretty complete Environmental Manual for their corporate office in the US. When we visited their plant in Thailand, we found that their Environmental Manual did not include reference to local regulations; the facility in Italy did not address control of EMS records, etc.

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.

Fortunately, there is a solution. Let’s review an example of ISO 14001 2008 Environmental Manual model that references supporting documents within the text of the Manual. For example, element 4.3.2, Legal and other requirements, may read: EMS Associates, LLP has established, implemented and maintains Legal Requirements Procedure to identify and have access to the applicable legal requirements related to the organization’s environmental aspects per the Environmental Aspects Procedure,

This model proved to be effective for a single-location company. It also will work for a multi-site business, but only for common EMS documents that are used at all locations. For example, such procedures as Documentation Management, Environmental Audit, CAPA and others may be the same for your all facilities and therefore be referenced in the Environmental Manual as shown above.

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 section

Manual Reference Matrix Table of Contents (ToC)

Site-specific Manual Reference Matrix

Location procedure

The Manual Reference Matrix is simply a list of all facilities and their Manual Reference Matrixes, as shown in the example below:

Manual Reference Matrix Table of Contents

Home Office (San Francisco, California, USA)

Toronto (Canada)

Springfield, IL (USA)

Buenos Aires, (Argentina)

Los Angeles, CA, USA

Etc.

To show how this approach works, we will document element 4.5.1 Monitoring and measurement. Our Environmental manual may state: Recycling Experts, Inc. has established, implemented and maintains a Monitoring Procedure to monitor and measure, on a regular basis, the key characteristics of its operations that can have a significant environmental impact per the site-specific key characteristics matrixes per the Manual Reference Matrix ToC. This clause indicates that the organization uses the corporate Monitoring Procedure and facility-specific Key Characteristics Matrix. To locate a facility-specific Key Characteristics Matrix, one simply needs to go to the Manual Reference Matrix 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.

Environmental Manual Reference Matrix may be formatted as a three-column table with the Manual Clause in the first column, HO References in the second and Location References in the third column. For example, for the element 4.4.6, Operational Control, the Los Angeles plant’s Matrix indicates that the Manual references Operational Controls Procedure HO for the corporate office and the Operational Control Procedure LA for the Los Angeles plant.

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