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Preparatory Environmental Review (PER) or GAP Analysis
Preparatory Environmental Review (PER) or GAP Analysis
Performing the preparatory environmental review using internally available resources has its merits
in that the organization can use personnel experienced in the operations of its processes and, of
some importance costs can be somewhat better controlled. Several options exist for this approach.
One option is to send out questionnaires to each department head, requiring those individuals in
charge to complete a series of questions, including, for example:
This will form a meaningful exercise by establishing the baseline to work from after analysis by
management. Possible flaws in this approach are that staff employed to perform this task may not
have the necessary expertise to carry out a meaningful review. In fact, Careful review of the answers
in these completed questionnaires will indicate the level of training required in the person
completing them. Management tools such as ‘brainstorming’, although they are of value, will not
give the same answers as hard data collection and some investigative detective work. On occasions,
organizations have made the mistake of basing their preparatory review on environmental projects
that are currently up and running. The rationale is that if such projects are current, then they must
be important, must focus on the significant environmental impacts of the organization and,
therefore, must be a sound basis to start from.
Unfortunately, although such projects may have been started with the best of intentions, they may
be based upon previous initiatives (for example, a project that was topical at the time, or a project
that looked easy to fulfil). The project may have been used to give credence to an individual or the
organization during a marketing initiative at that time. Or again, it may have been a project which
tied in with everyone’s work schedules and was easy to manage, and with which everyone was
comfortable because of the feeling that ‘they were doing something for the environment’. Such
projects may well have been reducing environmental impacts and this is no reason to abandon
them. Unfortunately, because of the haphazard nature and methodology of such projects, they will,
in all likelihood, not be focusing on significant impacts – fundamental to ISO 14001 philosophy. It is
essential if following this option that at least one senior manager in the organization has
environmental expertise. If the expertise is not available within the organization, suitable existing
staff might be trained by external consultants.
Quite often the individual chosen to lead the environmental management team and implement ISO
14001 is the quality assurance manager. The reasons for this choice are not always valid. Those
quality assurance managers who have taken on this task invariably perform well, but usually after a
painful and steep learning curve. Just because the two Standards, ISO 14001 and ISO 9001 are now
very much aligned, ISO 9001 implementing experience may not bridge the shortfall in the required
environmental knowledge required by the individual tasked with implementing ISO 14001. There are
of course commonalities between quality systems and environmental systems and a quality manager
will certainly be comfortable in the areas of operating to documented management systems: the
concept of objectives and targets and continuous improvement; the requirement for self-policing
(auditing); the value of reviews; and a corrective and preventive action system to allow
improvements to occur. But this does not necessarily equip the manager in question with the
knowledge and skills in environmental issues required for ISO 14001. That said, the requirement for
in-depth environmental knowledge from within the organization need not be onerous, and much of
course depends upon the complexity of the organization’s environmental aspects. However, to
commence from a standing start into the complex world of environmental issues and perform a
meaningful preparatory review is something not to be undertaken lightly. In such cases, the
organization is well advised to use the services of a consultant and ask them to perform a
preparatory review prior to ISO 14001 implementation. A well-executed preparatory environmental
review will generate a ‘specification’ for the organization in the form of a report setting out very
clearly what steps are required. This will form the foundation for deriving a meaningful
environmental policy and developing a robust EMS, capable of demonstrating environmental
performance improvement. A typical format of a preparatory review is outlined below.
Steps to take – a checklist approach for a PER
A fundamental requirement of ISO 14001 is that the organization complies with environmental law
as a minimum standard. The review should identify which areas of the organization are covered by
which laws. Any areas where there are breaches of legislation should be set as priority action areas.
Solid waste to land: Is a waste management licence required for the site? If solid waste is
taken away to the landfill, do the operators of the landfill site have a licence? Does it cover
the particular waste that is being removed? Does the carrier of the waste need a licence?
Water: Is there any groundwater extracted on-site? Is a licence required for this? Is any
effluent discharged to streams, rivers, local authority sewage systems? Is a licence to
discharge required? If so, are the conditions being met?
Other requirements: For example, does the site have any obligations to comply with any
town and country planning consents or building regulations?
b) Is there any forthcoming legislation which may affect the business? For example, there may be
legislation in the draft stage that, if enacted, could put the organization under heavy financial strain
to comply. Therefore some investigative work is required.
c) Have there been previous incidents of breaches of legislation? Has the organization been
prosecuted for any breach of environmental legislation? This may point to areas of weakness in
the management system.
The preparatory environmental review should also include an assessment of previous incidents –
under both abnormal and emergency situations.
Abnormal conditions generally include unexpected events and startup and shut-down of
continuous processes.
Emergency conditions include fires, floods, chemical spillage and fugitive emissions of gases.
2. Are there emergency plans in place – especially concerning a major spillage or fire?
The outcome of the inputs and outputs exercise and the review checklist can be in the form of a
report to the senior management of the organization.
Emissions:
Discharges:
Waste management:
P- Monitor and ensure regulatory compliance with regard to maximum allowable storage requirements of dry
wastes. P- Ensure all waste disposal facilities are appropriately licensed.
G- Clearly label all waste collection areas to assist in the segregation of waste.
Storage facilities:
Suppliers:
P- Increase the environmental awareness of key suppliers through questionnaires and assistance with ISO 14001
implementation where appropriate.
Customers:
G- Provide customers with environmental performance criteria of finished products; increase their understanding of
their duty to inform end-users of the safe and appropriate disposal at end of life of products.