The ISO 14001 standard does not define the term “significant aspect” and this can create some confusion when developing an EMS and have significant impact on the effectiveness of the EMS. The goal of the ISO standard is to provide a framework for environmental management systems and NOT dictate what an organization must choose to manage in the context of their EMS. It is understood that organizations can have different impacts on the environment and varying resources available to manage these impacts.
Section 4.3.1 of ISO 14001 requires organizations to identify their environmental aspects and “determine those aspects that have or can have significant impact(s) on the environmental”. This process is designed to allow an organization to FOCUS their attention on the aspects of their business that have (or CAN HAVE) the most significant impact. The determination of significant aspects is a focusing process that allows top management of an organization to FOCUS the attention of their EMS resources on the biggest impact(s) and it is up to top management to determine what to manage within the context of the EMS.
One of the myths around EMS development is the belief there is a “correct list of significant aspects” and this simply is not true. The standard allows the organization to develop the process to determine significance and final selection of significant aspects. There is no right or wrong answers but there are effective and ineffective processes that yield a list of significant aspects.
The EMS must support top managements commitments to 1) the prevention of pollution, 2) comply with legal & other requirements, and 3) continual improvement. One of the primary ways to support the commitment to the prevention of pollution is through the control of your significant impacts.
Once you identify an aspect as significant you must do the following:
- Communicate to employees that this aspect is significant
- Train employees involved in the activity
- Develop operation controls for the aspect and written work instructions, when appropriate
- Monitor & measure the activity as needed to gauge performance
- Consider the aspect when setting EMS objectives (though setting an objective to improve is not required for each significant aspects)
Another common myth is once an aspect is determined to be significant there must be an objective set to improve the aspect. If air emissions were determined to be a significant aspect and the facility emissions are meeting the requirements of their air permit, there is no requirement that an objective be set to reduce air emissions – only that this be considered by top management.
One of the most common methods for determining the significance of an aspect is through a hybrid of the failure mode effects analysis (FMEA) process that will use criteria like frequency and severity as well as other criteria (stakeholder concern, legal requirement, cost/volume, etc.) to assess the risk of each aspect. It is through the selection of these criteria that a relative risk for each aspect can be established and the management team can then use this risk assessment to make the final determination. This is where the management team can use judgment to make the final determination of significance based on their understanding of the organization and its operations.
Through the process of selecting significant aspects top management chooses what aspects to include or Focus the EMS. This will determine the type of EMS that will be developed and are classified as follows:
- Type 1 – Unfocused EMS
- Type 2 – Focused EMS
- Type 3 – Comprehensive EMS
Type 1 – Unfocused EMS
The unfocused EMS is where either non-significance aspects are identified as significant or too many significant aspects are determined to be significant. As an auditor this is the toughest type of system to audit because the ISO 14001 standard allows the organization to determine significance and there really is not wrong answer. The problem with having too many significance aspects is that this list is hard to communicate, training requirements can become over whelming, and monitoring & measuring activities become meaningless. The number one reason for Unfocused EMS is site that defines all aspects with legal requirements as significant – this yields things like disposal of bulbs, blood borne pathogens, and others as significant. The result is an overall dilution of the effectiveness of the EMS and lack of FOCUS.
Type 2 – Focused EMS
This is where top management chooses 1 or 2 aspects to focus their attention for the purposes of defining goals and performance measures. Many newly developed EMS programs choose to start as a Focused EMS to get the organization familiar with the EMS process and focus the time of their limited EMS resources. This type of EMS can allow the program to become more comprehensive over time, however many organizations choose to keep a focused EMS program with changing priorities focusing on different EMS aspects over time. While is appears helpful to focus the program this long term approach to the EMS can be confusing to production employees and can prove difficult to measure improvements in environmental performance.
Type 3 – Comprehensive EMS
This is where an organization identifies a comprehensive yet focused set of significant aspects that represent the biggest overall impact to the environment. This will typically be a list of 3 to 5 major aspects that will be used to develop operational controls, training programs, and set objectives that are monitored & measured to determine performance. It is these aspects, regardless of the maturity or effectiveness of controls, that are the most significant.
Many sites (approximately 25% that I have audited) will reduce the significance of aspects based on having highly effective controls in place; however, I believe that we should rank the significance of the aspects without controls to gauge their true significance. A significant aspect that is well controlled only needs for the controls to fail or even be less than effective to realize the maximum possible impact – exactly what the EMS is trying to avoid.
REMEMBER the process to determine significant aspects is designed to FOCUS our EMS on the aspects that top management feels are the most significant activities the organization does to impact the environment. There is no right or wrong list of significant aspects and FMEA score does not need to dictate the final output of this process. So it is the management team and EMS that should make final determination of significance and great care should be taken to avoid the Type 1 – Unfocused EMS.
Please leave a comment to let us know what you think!!Please contact EHS Management Strategies, LLC (www.ISO14001-Training.com) with any questions on your aspects identification and significance evaluation process. We can help make your EMS work for you