Practical Environmental Management Systems
Part 5 - Operating the EMS




The fifth in a series of Worksheets by Jonathan Churchman-Davies and Dr. Robin Kent for Envirowise on how to implement Environmental Management Systems in the plastics industry.

UK Government Environment and Energy Helpline 0800 585 794

This Worksheet concentrates on operating the EMS and considers many of the areas where ISO 14001 makes specific demands.


Envirowise publications provide sample documents and forms that will assist in writing many of these procedures.

Emergency procedures

Use the existing emergency procedures to develop a procedure to deal with emergencies that:

Section 4.4.7 of ISO 14001 requires a written procedure for dealing with emergencies.


Monitoring and measurement

Measuring to manage: If you don’t measure it then you can’t manage it.

General principles of monitoring and measurement

The EMS should include a procedure for monitoring and measurements related to the significant aspects, including waste production. Data collection and analysis is a vital tool in reducing resource use and minimising waste.

Although ISO 14001 specifies a minimum frequency of annual measurements, more frequent measurement is necessary to identify variations and opportunities to reduce waste. The sooner corrective action is taken, the more cost savings will be achieved. The measurements can be used in the Management Review, displayed internally to report success and even turned into a full Environmental Report. Parameters that should be measured include:

Waste and utility data should always be related to a measure of production, e.g. tonnes of waste per tonne of product or tonnes of waste per number of units.

Section 4.5.1 of ISO 14001 requires procedures to monitor and measure significant aspects and impacts on the environment. There must be adequate calibration procedures for any measuring equipment used.

This section also requires an evaluation of compliance with all relevant legislation.


A procedure is needed for the calibration of monitoring and measurement equipment.

Assessing legislative compliance

Assessment of legislative compliance should be performed at least annually, and always after updates to the Register of Legislation. For some issues, there may be a statutory requirement to supply compliance information to regulators more frequently.


Identifying and correcting problems

Non-conformances are system failures found during audits, inspections and day-to-day activities. They should be investigated and corrective action agreed. The same process should also be used to carry out preventative actions before things go wrong. Check any existing ISO 9000 quality procedures to see if an additional procedure is needed or simply changes to existing procedures.

Written records of non-conformances and agreed corrective/preventative actions must be kept by using a corrective action request form.

Section 4.5.2 of ISO 14001 requires procedures to ensure that when things go wrong (or don't follow the system), there is a process for recognising the non-conformance and defining corrective actions.


Keeping records

The records required for an EMS include:

There are legal requirements for the retention of some environmental documents and, although not a legal requirement, some other documents should be held forever to maintain the property asset value.

Keeping records should be dealt with under an ISO 9000 QMS and existing quality procedures may only need simple changes to meet the ISO 14001 requirements.

Section 4.5.3 of ISO 14001 requires procedures for the identification, maintenance and archiving of environmental records.


Internal audits

Auditing checks if you are ‘doing things right’.

Internal audits are a systematic inspection and comparison of actual operating methods with policies, procedures, work instructions, etc. Environmental auditing helps to maintain environmental awareness and a sense of responsibility among employees.

There are three ISO standards dealing with EMS auditing. These cover ‘General Principles’, ‘Audit Procedures’ and ‘Criteria for Auditors’ (ISO 10010 to ISO 14012 respectively). Check that existing ISO 9000 audit procedures meet the requirements of ISO 14001 - particularly with respect to auditing objectives/targets and compliance with legislation.

Section 4.5.4 of ISO 14001 requires procedures for audits to periodically assess the effectiveness of the EMS in relation to both the standard itself and good environmental management. These procedures should also confirm that the system has been properly implemented and maintained.

An audit should focus on the significant environmental aspects and compliance with legislation.

An audit should allow you to:

The auditor should have no management responsibility for the procedure being audited and should have been trained in auditing and the essential aspects of the procedure.

Audit frequency should be linked to the significance of the environmental impacts and all procedures must be audited at least once a year. The audit programme should take account of areas/issues identified for particular attention by previous audits.

Auditing often works best if the auditor has a list of key questions to ask about the procedure - preferably with simple yes/no responses. These questions can also be part of the procedure. 

All non-conformances and agreed corrective/preventative actions should be recorded in an Audit Report and followed up to check that corrective and preventative actions have been taken.


Management review

The Management Review checks if you are ‘doing the right things’.

Management Review allows senior managers to consider the effectiveness of the EMS. The discussion and its conclusions should be minuted and agreed actions implemented.

Section 4.6.1 of ISO 14001 requires regular reviews to assess the overall effectiveness of the EMS.

The agenda for management meetings should allocate time to discuss:

Senior management should consider whether to report externally on progress in reducing the impact of environmental aspects. 


More Information

Available free from the Environment and Energy Helpline (0800 585 794)

"Practical Environmental Management Systems" Series.

The "Practical Environmental Management Systems" series is designed to give plastics processors an insight into how to implement an Environmental Management System. The series is being published in Polymer Engineering on a monthly basis and is published here after the Polymer Engineering publication. The series is:

Part 1: Clean business = good business

Part 2: Starting out

Part 3: Managing interactions with the environment 

Part 4: The basic EMS system

Part 5: Operating an EMS system  (This section)

Download the complete series as an Adobe Acrobat file.

Last edited: 11/03/10

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