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0 03-June-2020

OM 101: Environmental Management System Module 5: ISO 14001 Clause 8 Operation

Module No. 5

MODULE TITLE

ISO 14001:2015 Clause 8: Operation

MODULE OVERVIEW

This module presents the basic concepts in Clause 8 of ISO 14001 Standard. Specifically,
it will discuss the operational planning and control requirements for Environmental Management
System.

LEARNING OBJECTIVES

By the end of this module, you should be able to:

1. Determine the Operational planning and control requirements for Environmental
Management System.
2. Operationalize the different structures of operational control and planning parts of the 2015
Standard.
3. Evaluate operational control and emergency responses applicable in organizations.

LEARNING CONTENTS

ISO 14001: 2015 Operation

ISO 14001:2015 clause 8 Operation deals with the

execution of the plans and processes that enable the
8
organization to meet its environmental objectives. There
are specific requirements that relate to the control or
Operation
influence exercised over outsourced processes and the
requirement to consider certain operational aspects
‘consistent with a life-cycle perspective’. This means 8.1 Operational
giving serious consideration to how actual or potential planning and
environmental impacts happening upstream and
downstream of an organization’s site-based operations Control
are influenced or (where possible) controlled. Finally, the
clause also covers the procurement of products and
services, as well as controls to ensure that
environmental requirements relating to design, delivery, 8.2 Emergency
use and end-of-life treatment of an organization’s Preparedness
products and services are considered at an appropriate and Response
stage.

The “Operation” clause has two sub-clauses, the a.) operational planning and control, and b)
emergency preparedness and response parts of the current standard – the ‘engine house’ of
production and control.

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a) Operational planning and control

Clause 8 of the requirements states that organizations are responsible to create, administer,
control and maintain all process needed to meet their EMS, which includes actions that were
defined in 6.1 and 6.2. For an organization to do this they must:
1. Create operating principles for the process
2. Put into action controls of the process in conformity of the operating principles

To ensure that your environmental policy is followed and that your objectives are achieved, certain
operations and activities must be controlled. The methods defined to ensure operational control will
be dependent on the organization’s activities, legal obligations, and significant operational controls.
Therefore, an organization must decide how to construct and combine processes to ensure that
total operational control of its environmental aspects is achieved. These methods of defining and
implementing controls must include constructing processes to ensure consistent results. It must
consider the life cycle of a product when establishing controls and using technology to ensure
results. It must ensure personnel is competent. It must monitor and measuring results. It must
decide on the amount of documented information required to support the above. Where an operation
or activity is complex and/ or the potential environmental impacts are significant, these controls
should take the form of documented procedures.

The operation planning and control defined must be persistent with ISO 14001:2015 life cycle
perspective, this should take into consideration:
• create controls in line with its environmental requirements to ensure that the design and
development process for the product or service considers the life cycle stage
• define the environmental requirements for the procurement of products and services
• communicate all relevant environmental requirements to external providers which include
contractors
• consider the need to provide information in regards to the end-of-life treatment of products and
services with consideration in, transportation, delivery, use, and final disposal.
• maintain detailed documentation to ensure that the processes have been carried out as
planned

The standard requires identification of operations and activities that are associated with the action
to address risk and opportunities and identified significant environmental aspects of the organization
in line with the environmental policy and its objectives. In effect, the organization is required to
control and verify all functions, activities, and processes which have or could have, if uncontrolled,
a significant impact direct or indirect on the environment. Control can include engineering controls
and procedures. the following hierarchy can be established for executing control

• Elimination
• Substitution
• Administrative

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OM 101: Environmental Management System Module 5: ISO 14001 Clause 8 Operation

As part of managing change, the organization should address planned and unplanned changes
to ensure that the unintended consequences of these changes do not have a negative effect on the
intended outcomes of the environmental management system. Examples of change include:

• planned changes to products, processes, operations, equipment or facilities;

• changes in staff or external providers, including contractors;
• new information related to environmental aspects, environmental impacts, and related
technologies;
• changes in compliance obligations.

ISO 14001:2015 has introduced the requirement for a “life cycle perspective” in environmental
management systems (EMS). The new standard does not require a formal life cycle analysis, or
quantification, but does require organizations to look upstream and downstream of the processes
performed on-site and try to reduce environmental impacts. The standard also requires the
organization to provide information to its external service providers and contractors about the
potentially significant environmental impacts of its products and services. By providing this
information, the organization can potentially prevent or mitigate adverse environmental impacts
during these life cycle stages.

The life cycle perspective can be applied in choosing, for example:

• raw materials (environmental impacts of their production, distance transported and mode of
transport)
• products to manufacture and offer for sale (same considerations as well as disposal or
recycling options at end-of-life)
• services used by the organization (environmental credentials, chemicals used, waste
generated)
• equipment purchases (distance transported, options for recycling at end-of-life, waste
generated in their use).

Environmental impacts of the organization’s suppliers come under the controls exercised under ISO
14001-Clause 8.1, as do those of contractors coming on-site or contractors used by the
implementing organization. This is especially so if the supplier’s or contractor’s methods of working
are known to conflict with the organization’s environmental policy.

So, what do we need to examine, define, and take action on to control in terms of outsourced
processes? Well, given that the organization remains responsible for all activities and impacts of
the outsourced provider, the 14001:2015 standard informs us that we must assess, define, and
maintain control over the following elements – as well as recording them in “documented
information”:

• resources knowledge, and, training/competence

• the ability of the provider to meet the stated EMS objectives
• the technical competence of the organization to define and assess the controls
• the potential effect of the product or service on environmental aspects
• how the control is shared between the parties
• how control is achieved via a procurement process
• opportunities for improvement

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If an outsourced service provider is geographically close to the organization, then it stands to reason
that the organization’s control over environmental impacts may be great. Conversely, if a service
provider is in a remote location, then direct control over the resulting impacts may often be lessened.
This is recognized by the standard; however, the following elements must be defined and actions
put in place to control:

• environmental aspects and impacts

• risks and opportunities related to the organization’s goods or services
• compliance and legal obligations

Lastly, the standard reminds us that “interested parties” must be considered, as well as the
environmental impact found during delivery, disposal, and end-of-life of product as well as general
use. The standard allows an organization to define an action its own operation controls according
to the industry it operates in and the aspects that arise from the resulting product or service. Despite
that, there are certain elements of operational control that the ISO 14001:2015 standard insists be
assessed, controlled, and captured as documented information, whether in the environmental policy
itself or as separate documents:

• Legal and compliance requirements must be met.

• Environmental objectives must be assessed and set.
• Internal processes must be defined.
• External and outsourced processes must be defined and controlled.
• Training and competence needs must be assessed, implemented, and reviewed.
• Analysis and improvement measures must be undertaken.

Start by looking at the environmental aspects and potentially significant impacts which you identified
earlier. Identify the processes from which these significant impacts arise, and consider what types
of controls might be needed to prevent or manage these impacts. If you have flowcharts of these
processes, identify the points in each process where some type of control may be appropriate.
Review them with the people who will need to implement them. This will help to ensure that the
Controls are accurate and realistic. Look at Controls you already have in place to comply with
environmental and health & safety regulations. Develop a chart to keep track of what is needed.
The more highly skilled and trained your employees are, the less critical controls will be. The more
complex the work or the greater the potential impact on the environment, the more important these
controls will be. Once you have identified operations that require control, consider what kinds of
maintenance and calibration may be appropriate. However, the need for maintenance on equipment
that could have significant environmental impacts should be obvious, and the need to plan and
control such maintenance should not be overlooked. This does not mean that an elaborate
preventive or predictive maintenance program is needed in all cases. Assess your existing
maintenance program and its effectiveness before making significant changes. Communicate your
expectations including any relevant controls to these business partners.

There are different types of operational control, including:

• Electronic or mechanical technology to reduce emissions

• Routine preventive maintenance programs to reduce wear and breakdown of equipment
• Monitoring and observation of equipment performance
• Procedures
• Signs
• Log Books
• Check lists

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• Flow charts

Examples of operational control procedures:

1. Waste management
2. Packaging waste
3. Contractors coming on site
4. Suppliers
5. Bonding inspection
6. Pipework inspection
7. Monitoring for compliance with site licenses
8. Future/Planned work
9. Construction work
10. Demolition work
11. Housekeeping

Examples of Operational control and measures

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OM 101: Environmental Management System Module 5: ISO 14001 Clause 8 Operation

Significant Environmental
Example of controls (Considering a Life
Processes Aspects (Considering a Life
cycle Perspectives)
cycle Perspectives)

• Timber sourcing
• General energy use
Timber milling and (petrol & electricity) • Management: Purchasing policy,
sawing line custody chain certificates,
• Temperature controlled procedures and policies
• Input – raw storage (electricity)
• Operational: Process flow charts,
timber and • Machine coolant use and
energy work instructions, signage, training,
disposal inspections
• Output – • Chemical use and • Equipment: Automation, designated
finished disposal for wood
timber, cut to storage areas, spill kits, metering,
treatment drain coding
specification
• Offcut and sawdust
collection/ storage

Design office

• Input –
paper, inks, • Management: Purchasing policy,
IT • Procurement
procedures, and policies
equipment, (Inks/paper/IT
Equipment) • Operational: Process flow charts
energy,
Training, IT procedures, draft
customer • Energy use (Electricity)
specification reviews
• Energy use (Gas – for
• Equipment: Default settings on
• Output – space heating)
design printers, IT equipment, metering
drawings and
support
material

b) Emergency Preparedness and Response

Despite an organization’s best efforts, the possibility of accidents and other emergency situations
still exits. Effective planning and preparation can reduce injuries, protect employees and neighbors,
reduce asset losses and minimize production downtime. An effective emergency preparedness and
response program should include provisions for assessing the potential for accidents and
emergencies, preventing incidents and their associated environmental impacts, plans/processes for
responding to incidents, periodic testing of emergency plans/processes and, mitigating impacts
associated with these incidents. Consistent with your organization’s focus on continual
improvement, it also is a good idea to review emergency response performance after an incident
has occurred. This review can help determine if more training is needed or if emergency
plans/processes should be revised. In the new standard Procedures are replaced by the phrase
‘processes needed to prepare for and respond to’ potential emergencies.

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OM 101: Environmental Management System Module 5: ISO 14001 Clause 8 Operation

This clause is clear in requiring the organization to establish, implement and maintain processes
needed to handle potential emergency situations identified in 6.1.1.

The more detailed requirements cover the need to ensure:

• That the organization plans actions to mitigate or prevent environmental consequences;

• The organization responds to actual emergency situations;
• Takes action to prevent or mitigate the consequences of emergency situation;
• Periodic testing of any procedures, plans and response mechanisms;
• Periodic reviews and updates of procedures and plans based on experience;
• Provision of relevant information and training to relevant interested parties.

The Standard requires that three components be addressed by the organization:

1. The organization shall establish, implement and maintain the processes needed to prepare for
and respond to potential emergency situations
2. Review and revise the importance of learning from incidents.
3. It must periodically test the planned response actions, where practicable.

1. Establish, implement and maintain the processes

An organization is well advised to draw up an ‘Emergency Plan’ and to consider different levels of
disaster – including the worst-case scenario. The worst-time scenario should also be evaluated
which can occur at times of shift change, weekends and holiday periods when staff may be reduced.
The emphasis of such a plan will be placed upon ensuring that the business survives – that there
will be the minimum of disruption of service, or supplies of product, to customers. Safety of
individuals, staff, and others will naturally be paramount but of course the environmental impact
must be considered to address ISO 14001-Clause 8.2. A suitable plan could cover:

• Identifying critical assets – usually major items of plant

• Defining the disaster team and describing responsibilities
• Emergency services – how to contact them
• Enforcement agencies – how to contact them
• Listing communications – including out-of-hours phone numbers
• Holding regular exercises – to test the system
• Setting up a media response team – details of who is responsible for contacting the media

Examining the function of the media response team further is worthwhile. It is tempting in the event
of an environmental incident to offer no comment to the press. However, other parties, who may be
hostile to the organization, will comment. This could be disgruntled neighbors, competitors and
others who will take the opportunity to repeat rumors or provide media with exaggerated accounts
of the incident. The media will find out, despite efforts to deter them.

It is also important to remember that just because risks are low, it does not mean that emergency
plans are unnecessary. Without an emergency plan, minor incidents can escalate into major ones

2. Review and revise the importance of learning from incidents

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In the case of near misses, it is important that such potential incidents are recorded and reviewed
and not hidden away or merely forgotten. Such incidents indicate areas of risk which on other
occasions may turn into environmental accidents.

3. Testing of emergency plans

There may be situations where full-scale testing is not practical and thus consideration should be
given to desk-top exercises that can be played out. The time to put an emergency plan to the acid
test and seek the answers to the above is not the day of the real event. Therefore, an organization
should evaluate its risks of environmental emergencies and evaluate the extent to which it should
carry out testing of its procedures.

Steps to set up Emergency Plan

Step 1: Identification. You have to identify the specific potential accident related to your
circumstances and type of activity. If you run an office, a fire may be your only potential risk.
Some types of accident and emergency:

• fire
• chemical explosion
• spillage or release of materials that are corrosive, toxic, flammable, or carcinogenic

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Step 2: Prevention. You have to brainstorm with your personnel for preventive measures related to
every type of accident. ISO 14001 states that emergency plan(s) shall include actions to prevent
and mitigate associated environmental impacts. Preventive measures depend upon your specific
situation and may include e.g.:

Type of Accident Preventive Measures

• Regular testing and maintenance of fire

extinguishers
• Providing free access for fire trucks
Fire, explosion
• Posting labels and warning signs
• Training the staff
• Supervising activities

• A waterproof concrete storage area (bonds) for

Spillage or release of materials that
are corrosive, toxic, flammable, or
carcinogenic
collecting spilled fuel from the tank
• Storage of oil only on waterproof surfaces with
controlled drainage system via the system for
wastewater treatment
• Periodic inspection and testing tightness of
bunds, reinforcement and drainage systems
• Training the staff
• Supervising activities

Step 3: Emergency plan. Depending on complexity and needs, the organization should establish
one or more emergency plans. An emergency plan aims to:

• define the types of accident and environmental impacts (step 1)

• define preventive measures (step 2)
• provide contact information to key personnel (on-site & off-site)
• identify the location of appropriate technical data and emergency equipment (site layout)
• highlight any special instructions or actions
• identify and provide names of people trained in first aid

Step 4: Training and drills (testing for training effectiveness).

You have to train your employees about preventive measures and your emergency plan, and you
should include in the training plan all necessary background information. Unfortunately, this is not
enough, because, in a real emergency situation, people’s behavior is unpredictable. To be sure that
personnel will react according to the emergency plan, you have to, as stated in ISO 14001, perform
periodic drills based on predefined scenarios.

Step 5: Evaluation and improvement.

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Drill reports have to take into consideration the gaps between the emergency plan and the drill
result. The output of the drill report should focus on closing gaps and any other recommendations
related to the improvement of the emergency plan.

Planning for unexpected events is a good all-round organizational discipline. In ISO 14001, the
aspects and impacts analysis will have highlighted potential emergency situations where a negative
environmental impact potentially could take place. It is up to an organization, therefore, to determine
the plans that can be put in place in order to avoid or minimize environmental damage.

LEARNING POINTS

In this module, you learned:

• The draft ISO 14001:2015 standard clarifies that operational controls are implemented to
prevent deviation from the environmental policy and objectives, as well as, compliance
obligations.
• The concept of “life cycle perspective” is added that requires the organization to:
a) determine environmental requirements for the procurement of its products and services;
b) ensure environmental requirements are considered in the design, delivery, use, and
end-of-life treatment of its products and services;
c) communicate relevant environmental requirements to suppliers and contractors;
d) provide information about potential environmental impacts during the delivery of
products or services during use and end-of-life treatment of the product.
• Emergency preparedness and response adds to act to prevent or mitigate consequences
of emergency situations, appropriate to magnitude of emergency and potential
environmental impact
• 8.2 adds to provide relevant information and training to relevant interested parties and
persons working under organization’s control

LEARNING ACTIVITIES

Exercise #5: After discussing important concepts about Clause 8 let us find out if you can apply
these learned concepts. For the exercises that follow, please answer them in another sheet of paper
for discussion when we shall have the online learning encounter.

Be able to accomplish the following questions:

Create a Family Emergency Plan so your family will know what do in a crisis.
1. With your family or household members, discuss how to prepare and respond to the types
of emergencies (Example: Coronavirus, Drought, Earthquake, Fire, Flood, Flu, Food Safety,
Heat Wave, Highway Safety, Typhoon, Landslide, Poisoning, Thunderstorm, Tsunami,
Water Safety, Volcano Eruption Power outage) that are most likely to happen where you
live, learn, work and play.
2. Identify responsibilities for each member of your household and how you will work together
as a team.
3. Document your emergency plan with the template by opening the attached link.

https://www.redcross.org/content/dam/redcross/atg/PDF_s/Preparedness___Disaster_Rec
overy/General_Preparedness___Recovery/Home/ARC_Family_Disaster_Plan_Template_
r083012.pdf

REFERENCES

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www.asq.org
American Society for Quality, 2020

www.epa.gov
Learn about Environmental Management Systems.

www.dnvlgl.com
ISO 14001: 2015 Environmental Management Systems – Requirements Guidance Document.

https://isoconsultantkuwait.com/2019/06/23/iso-140012015-clause-8-operation/

https://www.whittingtonassociates.com/2014/10/isodis-140012015-clause-8/

https://www.redcross.org/content/dam/redcross/atg/PDF_s/Preparedness___Disaster_Recovery/
General_Preparedness___Recovery/Home/ARC_Family_Disaster_Plan_Template_r083012.pdf

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