Management system guidance
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5.2 Environmental policy
ISO 14001:2015 now requires your organization’s environmental policy to be appropriate to both its purpose and context. This means that once your organization has determined its context and the relevant requirements of its interested parties, top management must review its environmental policy in light of that information.
Objective evidence must include an interview with top management covering the points a) to e) of the standard to ensure thorough understanding and leadership at the highest level. If the top management is not involved; a non-conformance will likely be issued. Three specific commitments have to be included in the policy:
- To protect the environment;
- To fulfil compliance obligations;
- To continually improve the EMS and improvement of the organization’s environmental performance.
Examples of evidence of commitments that support protection of the environment as well as a framework for objectives may include:
- Sustainable resource use;
- Climate change mitigation and adaptation;
- Protection of biodiversity and ecosystems;
- Addressing other relevant environmental issues.
Your organization will need to review its environmental policy as necessary to ensure that any changes in its context, interested parties or their requirements is reflected in the policy and whether your organization’s objectives are effected (6.2.1 a).
Although the environmental policy statement may not include the exact wording of the required commitments, each commitment must be clearly included in the documented policy. The meaning and intent of the standard must be fulfilled. The former commitment to “comply with legal and other requirements” could continue to be used, as this can be considered equivalent to “fulfilling compliance obligations.”
Auditors will wish to determine if the policies meet the intent and are understood, by interviewing personnel at all levels. Although the exact content of the policies does not need to be recited by interviewees, the awareness of the policies and how their job affects the company objectives should be determined. This does not require your employees to memorize the policies but it does mean they should be aware of it, know where it may be found and be able to paraphrase, or give an interpretation as it applies to them.
If the personnel interviewed do not know what their measurable objectives are and/or do not know what the organizational objectives are that they have a direct effect upon, the auditor would be further directed to evaluate top management’s communication of the policies and objectives.
Inferred awareness through knowledge of procedures is not considered sufficient; otherwise why have the requirement in the first place? A quick and convenient way to promote and communicate the policy might be to create a shortened version of main policy; try condensing it to five key words or even a couple of short sentences. This can be posted on bulletin boards in each department.
You could even add it to the reverse side of staff security passes or ID badges. If an auditor asks an employee whether they are aware of the policy; they can point to the bulletin board, or point to it on their badge. The employee can further elaborate to the auditor, what the policy means to them and how it influences their work.
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