EMS Communications – What is required? [ISO 14001 4.4.3]

Internal EMS communication and awareness is typically one of the weaker parts of most management systems we audit.  Management teams often times do not clearly understand what information to share with employees and how to share it.  The ISO 14001:2004 internal communication requirements are overly general and provide little help. The ISO standard specifies:

4.4.3 Communication

With regard to its environmental aspects and environmental management system, the organization shall establish, implement and maintain a procedure(s) for…..

Internal communication among the various levels and functions of the organization,……..

So the requirement is to communicate information about your Environmental Aspects and Environmental Management System to employees at Various Levels and Functions. To keep matters simple we will talk about three basic levels of employees:

1)      Management

2)      Supervisors

3)      Production Employees

As an auditor, I have different expectations for each population of employee.

Personnel at all levels (including temporary) should get an awareness level overview of your EMS during their new hire orientation. This is the beginning of the communication process and where the problems typically start.  Some sites merely have the new employee read and sign their EMS policy while others create programs that are too complex.  The following topics should be covered in any orientation process:

1)      EMS Policy

2)      Summary of Significant Aspects

3)      Current Objectives/Targets

4)      Overview of Work Instructions

5)      Emergency Response Procedures

Once you have a well-focused and clear orientation process you need to sustain this awareness through your communication process.

Production employees and all other people working on behalf of the organization need to be aware of the general information included in their new hire orientation (see ISO 14001:2004 element 4.4.2 (a-h)).  Now it is up to the communication process to maintain and support the employee’s awareness of the EMS. Communication to all employees starts with posting the environmental policy at key locations in the plant – lobby, break room, time clock, etc..  The facility should also maintain an EMS communication board(s) that includes the environmental policy, list of significant aspects, EMS measurables, and EMS objectives.  Action: Verify that your policy is posted in key areas and update communication boards.

The facility also needs a ‘proactive verbal’ communication process. Most sites will have regular meetings with employees on a weekly, monthly, or quarterly basis to discuss production, quality or safety information.  It is these meeting that you need to add “EMS update” to the agenda and a ‘brief” 1 to 3 minute EMS update given. It is important that supervisors and department managers deliver these EMS updates because it requires them to keep up to date on the EMS topics.  For each meeting the environmental management representative (EMR) should provide a brief EMS update to the person leading the meeting.  To this process proactive simply put together an annual EMS communications plan that includes all methods of communication (download FREE EMS Communications plan).  Action: Review regular plant communication process and integrate EMS information.

The key is to explain the EMS in very clear terms.  You can explain that our EMS policy is that you are “Committed to the Prevention of Pollution” and that they prevent pollution by making good parts, recycling, containing oil/spills, turning off machines, etc.. They should also understand their responsibilities to control significant aspects and impact on the facility objectives/targets.

Supervisory employees should be aware of the sites EMS policy, identified significant aspects, work instructions, and emergency response procedures.  Typically supervisors will have very specific responsibilities during both fire and spill response.  They should clearly understand their role in controlling the identified significant aspects.

Management level employees should have a full working understanding the EMS as it applies to their position.  As an example, a Purchasing Manager should be aware that buying new chemicals or significantly increasing quantities of chemicals purchased could impact the aspects evaluation and should be reported the EMR.  New managers should get a detailed overview of the EMS procedures and information including a review of your aspects list, objectives/targets, training, document control, corrective action, and management review. This could be something as simple as an hour meeting with the EMR to review the documentation on the network. Surprisingly, less than 20% of the sites I audit provide this very basic level of training to new managers.                                    Action: Develop management level EMS orientation process.

The EMR should communicate EMS updates to management on a regular basis. Most management teams will get together monthly to review quality, financial, and production measurable and activities.  It is during these meetings that management should get updates on EMS measurables, objectives & targets, and EMS activities that month. This update can be brief and may only require 5 to 10 minutes to each meeting.  Then on an annual basis management should conduct a comprehensive review of the EMS and environmental performance as required by element 4.6 of ISO 14001.                         Action: Integrate EMS information into regular monthly management reviews.

You will be AMAZED at how this will dramatically improve employee engagement and overall awareness of your EMS program.   Simply planning out how these communications will occur on an annual basis will improve the effectiveness of your program.           Result: EMS Success!!!

FREE General Awareness PowerPoint

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