In this article, I’m going to cover clause 5.2 Environmental Policy from ISO 14001:2015, which of course is all about the environmental policy. I’m going to break this clause down and turn it into something you can all understand. You will then be able to apply this to your own organization's system and understand what the requirements will look like for you. No more guessing! Keep on watching as I can show you just how easy this is!
Ok, let’s get started! You will note that this clause is in clause 5 Leadership, so it’s not something that is buried in the system. This means that Top Management is responsible. I’d better remind you who top management is then. The official definition for top management is … the person or group of people who directs and controls an organization at the highest level. I always say that top management is the decision-makers. Depending on the structure and size of the business, top management could be the owners, shareholders, board of directors, general manager, or even a project manager if the scope of the system is down to a project level only.
As mentioned previously it is top management who are responsible for establishing, implementing, and maintaining the environmental policy. I always say that a policy is the high-level intent and commitment of the business. A policy isn’t supposed to tell you WHAT to do, it’s created to ‘set the standard’ of what the business is committed to achieving.
The areas to be considered when establishing, implementing, and maintaining the Environmental policy are:
We determine the context of the organization in an earlier clause - Clause 4.1 – understanding the organization and its context. Be sure to check the video out for this on ATOL.tv if you need a refresher. This will help you to then align your environmental policy with the context of the organization. This section does also require the policy to be appropriate to the nature, scale, and environmental impacts of its activities, products, and services.
This means that you can’t just download a template or someone else’s environmental policy as they will not be appropriate or relevant to YOUR business activities. I always review the environmental policy to see how well it aligns with the environmental aspects and impacts identified as well as the objectives set. Speaking of objectives, the next section - Section b) states that the policy provides a framework for setting environmental objectives. This is always a confusing one for most people. The requirement doesn’t mean that you have to list your objectives within the policy. All they are asking is for there to be a commitment or statement in the policy that demonstrates or documents the commitment to setting objectives. It could be as simple as stating ‘
We are committed to setting environmental objectives that support our commitment to the protection of the environment, including prevention of pollution and are appropriate to the nature, scale and environmental impacts of our activities, products and services. The objectives are established, communicated, measured and reviewed at least annually or when changes to the business and system occur’.
Something like that – You can see that this just simply explains the very high-level intention for the objective framework within your business.
Moving along to point c) now, where it states that the policy is to include a commitment to the protection of the environment, including prevention of pollution and other specific commitment(s) relevant to the context of the organization.
Do these words sound familiar? Yep – I just used them in my previous example of how to include the framework for setting environmental objectives. I worked smart and not hard and also included this requirement for section c). I’ll repeat this again – so the example statement was ‘
We are committed to setting environmental objectives that support our commitment to the protection of the environment, including prevention of pollution and are appropriate to the nature, scale and environmental impacts of our activities, products and services. The objectives are established, communicated, measured and reviewed at least annually or when changes to the business and system occur’
See how just that one statement and a couple of sentences pull in multiple requirements of this policy clause?
We then move on to section d) where it states that the policy is to include a commitment to fulfill its compliance obligations.
Further along in ISO 14001:2015, there is actually a clause 6.1.3 Compliance obligations. And then there is clause 9.1.2 Evaluation of compliance. Both of these clauses work together to identify what compliance obligations are relevant and determine how they apply in the environmental management system and then check whether they are being followed. Oh, and you probably would have also identified which needs and expectations of interested parties are or could become compliance obligations way back in Clause 4.2. Be sure to check out that video on ATOL.tv if you need a refresher.
Moving along though, amongst these other clauses in the Standard whatever compliance obligations you identify and then action and check is more on the operational or DOING side. All the environmental policy wants is a commitment to fulfill what you identify. It can be as simple a statement as ‘we are committed to fulfilling all compliance obligations identified as relevant to our activities, products, and services.
And then finally point e) states that the policy is to include a commitment to continual improvement of the environmental management system to enhance environmental performance. Yep – yet another commitment is required! And honestly, it can be as simple as making that statement in your policy ‘we are committed to continual improvement of our environmental management system’. You could even combine this statement with the earlier one I shared for the framework of your objectives combining several commitment requirements from this clause. So, it could go something like this ‘
We are committed to continual improvement of our environmental management system through setting environmental objectives that support our commitment to the protection of the environment, including prevention of pollution. Our objectives are appropriate to the nature, scale, and environmental impacts of our activities, products, and services. The objectives are established, communicated, measured, and reviewed at least annually or when changes to the business and system occur’
Of course, it’s all well and good making all of these commitment statements. What you have to remember is that if you make the commitment then you have to back it up in your system. This isn’t about a warm and fuzzy policy being created and then forgetting about HOW you are going to demonstrate your commitment. Be very aware that ISO 14001 will throw more clauses at you where it WILL require you to figure out HOW you will meet these commitments. This is the brilliant thing about the Standard – every clause supports each other.
Now that you understand WHAT is included in the policy let’s look at HOW it is to be communicated and made available. The first point states that the policy is to be maintained as documented information.
Easy – write your environmental policy up! It needs to be documented; we need to see it. It can’t just be in your head 😊 Normally an environmental policy is just one-page. Remember it’s a high-level intent and commitment so there’s not a lot of detail or HOW to do things in the document. That’s why it is normally just one page.
Now the next point states that the policy is to be communicated within the organization. This is further backed up by clause 7.3 Awareness and 7.4 Communication further on in the Standard – be sure to check those out on ATOL.tv too. So once again this policy isn’t just documented to look pretty and create all warm and fuzzy feelings for you. It is required to be communicated – how, is up to you. The standard is not specific on this. Normally a policy is communicated within the organization by being displayed at the reception, on a noticeboard, and as a part of staff induction and training.
Next up the policy is also to be available to interested parties.
These interested parties are what you would have identified as part of Clause 4.2 Understanding the needs and expectations of interested parties.
We have already touched on this in the previous point when communicating within the organization, however, making the policy available to external interested parties could be managed by having the policy available on your company website or including it in tenders. It is up to the organization to determine the best method to make the policy available to interested parties based on what communication channels you already currently use with them.
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