BM2017

DOCUMENTS AND THEIR CONTROL

ISO 14001 Documentation

The baseline documentation requirements of an environmental management system (EMS) cover the law;
and the environmental policy, objectives, and targets that have developed from them (Sheldon & Yoxon,
2006).
Documentation is an important element of an EMS, as they provide written evidence of procedures,
records, and instructions. They can also provide a history of the EMS, enabling auditors to check whether
continual improvements are being made. The development of the documentation and record control
system defines the creation, publishing, withdrawal, and use of documents and records. It is up to the
organization to create the most suitable documentation because it will affect how it maintains and
improves its EMS. Before developing EMS documentation, it is important to get a clear picture of each
type of document's purpose and where it belongs in the documentation hierarchy.
There are several types of documents used to establish an EMS as follows (Stojanovic, 2016):
 EMS Policy. It represents a declarative statement by an organization – a constitution of the system
– and all other documents arise from it. The top management writes the policy and its purpose is to
define the general direction and aim of the EMS. The Environmental Policy also provides a
framework for establishing EMS objectives.
 EMS Manual. Although it is not a mandatory document according to ISO 14001, it is often used to
document the EMS scope and the main elements of the EMS and their interaction and reference to
related documents. Since it is a very common document, it is usually the first document that the
certification body wants to see to get familiar with the system. If it is a small company or a company
with simple hazards, all procedures can be placed into an EMS manual.
 Procedures. These can have different formats and structures. They can be narrative (i.e., described
through text); they can be more structured by using tables; they can be more illustrative (i.e.,
flow charts); or any combination of the above. Procedures should include title, purpose, scope,
responsibilities and authorities, description of activities, and reference to relevant work
instructions, standard operating procedures (SOPs), and records.
 Work instructions, guidelines, and SOPs. The main purpose of work instructions is to avoid
nonconformities by explaining exactly how a certain activity is carried out. It is usually written for
the activities within the process with the highest chances of nonconformities occurring or for
complex or rarely conducted activities. Work instructions can be part of a procedure, or they can
be referenced in a procedure. Generally, work instructions have a similar structure to the
procedures and cover the same elements; however, the work instructions include details of
activities that need to be realized, focusing on sequencing the steps, tools, and methods to be used
and required accuracy.
 Records and forms. These are evidences that activities and processes are conducted in the way
prescribed in the procedures and work instructions. Most of them are filled in by employees, but
some of them (e.g., Management Review Minutes) are filled in by the top management. The best
way to make them practical is to avoid requiring employees to write essays. Having records with
checkboxes instead of empty rows for employees to write sentences will ensure that the forms or
records are filled quickly and easily.
Basic Steps for Effective Documentation (Sheldon & Yoxon, 2006)
Organizations must establish a consistent method for writing procedures and documentation of files/
records. Note that ISO 14001 and ecomanagement and audit scheme (EMAS) require a procedure to

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approve all documents (not just procedures) for adequacy before use, so for those pursuing external
recognition, it is a nonoptional formality.
The basic steps that go towards effective documentation are as follows:

1. Analyze need and define purpose. Documentation procedures fall into roughly five (5)
categories, which can be remembered using the mnemonic “PAIRS”. These are
described below:
a. Planning. It involves written procedures in conceptualizing new projects and
determining environmental aspects related to research and development, production,
purchasing, design, finance, etc.

b. Activity. It involves written procedures related to control of processes, suppliers

and contractors, raw material use, pollution reduction, monitoring of emissions
and discharges, maintenance routines, etc.
c. Information. It involves documenting minutes of the meeting to determine
attendees, meeting agendas, circulation lists, etc.
d. Risk. It involves written procedures related to safety issues, emergency drills, response to
accidents, emergency services, and other contingencies for abnormal events.
e. System. It involves documenting changes in procedures and keeping records of
legal requirements, significant impacts, and other vital information.
2. Draft. After identifying all the needs and analyzing what each procedure is designed to
achieve, a firm may start to draft a procedure. If a firm only uses narrative form to describe its
procedures, it may consider using flow charts to illustrate processes.
3. Test. Companies may conduct trials of the draft procedure, one trial with someone who
knows nothing of the actual job and one with an experienced employee. Each will have their
perspective, and each will spot different facets of the procedure that needs changes.
4. Revise and print. Companies must ensure that their document control procedures are among the
first ones they write to track identified issues on drafted written procedures, the date of issue,
revisions made, etc. Also, a firm must maintain a list of employee responsibilities, a basic description
of the procedure, crossreferences of other material and/or procedures, and the signature of
whoever authorizes the written document.
5. Update. Companies must review their documentation procedure regularly. They may set a 12 month
cycle for the review of documented information. Also, firms must create a record detailing which
documents exist (not just those that relate to the management system itself), where they can
be found, and who is responsible for them. This can be a really useful tool, especially when a revision
of a particular procedure may directly affect other documents and forms.
Control of Documents (Sheldon & Yoxon, 2006)
In essence, document control requires ensuring that records can be easily identified and located; they
are approved and on the current version. The firm must also establish a procedure for archiving/
disposing of old or obsolete documents and assign people to oversee them.
The following are the elements of the EMS (based on IS0 14001 and EMAS), affected by documentation
and control:
 General requirements (ISO 14001 Clause 4.1 /EMAS Annex IA.1). This clause ensures that readers
understand the difference between the documented information that serves as guidance (i.e.,
introduction, definitions, scope, annexes, etc.) and the core requirements. The key requirement
is to include a documented definition of the scope of the EMS.
 Environmental policy (ISO 14001 Clause 4.2 /EMAS Annex IA.2). Firms must document their
environmental policy accordingly based on either ISO 14001 or EMAS. Companies must ensure
that the policy is aligned with the documented EMS scope. Effective distribution to staff is also an
important issue, as awareness of the overall policy by all employees is crucial to a successful EMS.
 Objectives, targets, and programs (ISO 14001 Clause 4.3.3 /EMAS Annex IA.3.3). For ISO 14001 and
EMAS registration, these elements must be documented and accessible to relevant personnel.
The firm’s policy and the nature of its objectives define what is relevant.
 Resources, roles, responsibility, and authority (ISO 14001 Clause 4.4.1 /EMAS Annex IA.4.1). The
structure and associated responsibilities need to be defined and documented, mainly to avoid the
mutual recrimination (or pointing of fingers) that happens after something goes wrong. Everyone
should know what they have to do, both on a daytoday basis and when things don’t go according
to plan. A chart outlining the structure of responsibilities for environmental work may be
sufficient, but firms must make sure the right people can access it.
 Communication (ISO 14001 Clause 4.4.3 /Annex IA.4.3). Firms should document their decision to
communicate with external parties about their significant environmental aspects. Whatever
decision is finally made, even if it is a negative one, it should be documented somewhere in the
system.
 Documentation (ISO 14001 Clause 4.4.4 /Annex IA.4.4). The system itself will require a certain
amount of documentation to be maintained efficiently. For a firm pursuing ISO 14001, the
requirements are defined as “a description of the main elements of the EMS” and their interaction.
Many organizations choose to organize the contents of a central “management system manual”
around the clause structure of ISO 14001 to ensure that they have covered all the requirements.
 Control of documents (ISO 14001 Clause 4.4.5 /EMAS Annex IA.4.5). Firms must keep a record of
document approval and control procedures to ensure that document control procedures
themselves are consistently followed.
 Operational control (ISO 14001 Clause 4.4.6 /EMAS Annex IA.4.6). It relates specifically to written
procedures of a firm’s functional controls. The written procedures must be aligned directly to
operations or activities that affect the significant environmental impacts.
 Monitoring and measurement (ISO 14001 Clause 4.5.1 /EMAS Annex IA.5.1). These involve
documented procedures covering the assessment of “key characteristics” of the identified
significant impacts of a firm. Some monitoring is required by law. As a minimum, firms must ensure
that procedures match those requirements and that they have established a way of auditing
against those requirements (i.e., if a regulator instructs a firm to monitor the outflow daily, and its
procedures ask for monitoring weekly, how would the firm discover that such a problem existed?).
Companies must also consider the monitoring equipment itself; this will have to be calibrated and
maintained regularly.
 Evaluation of compliance (ISO 14001 Clause 4.5.2 /EMAS Annex IA.5.2). It involves keeping records
of the periodic evaluations of the legal compliance of a firm. This information can be linked with
corrective and preventive action records (for audit purposes) and can be used as part of the
management review process.
 Nonconformity, corrective action, and preventive action (ISO 14001 Clause 4.5.3 /EMAS Annex I
A.5.3). It is difficult to undertake effective corrective and preventive actions without
documentation. Firms must maintain a neat paper trail of identified problems, including internal
audit findings and the actions taken to correct them. That way, the system is kept updated to
changing circumstances, processes, and materials.
 Control of records (ISO 14001 Clause 4.5.4 /EMAS Annex IA.5.4). The law often requires firms to
keep defined records and maintain them over a specific amount of time. In addition, a firm’s
 procedures for recordkeeping should cover training and audit records and any other type of
evidence that relates to the way it manages its environmental impacts (i.e., legal and other
requirements, communications with external parties, objectives and targets, calibration records,
monitoring and inspection data, nonconformities, corrective actions, and management reviews).
 Management review (ISO 14001 clause 4.6 /EMAS Annex IA.6). It is the periodic assessment of the
management system to check whether it is still synchronized with the other business drivers of the
organization. The management review also involves identifying opportunities for improvement.
Documenting the review minutes provides records of the decisions made, which may prove valuable
when circumstances change in the future.

References:
Sheldon, C. & Yoxon, M. (2006). Environmental management systems: A stepbystep guide to
implementation and maintenance (3rd ed.). Earthscan.
Stojanovic, S. (2016). How to structure ISO 14001 documentation.
https://advisera.com/14001academy/blog/2016/11/28/howtostructureiso14001 documentation/