I just wanted to share a bit of information on writing environmental policy statements with ISO 14001 particularly in mind. The word ‘good’ in the title of this post is important as you can write a policy statement that will pass a 14001 external audit, but is not as effective as it could be.
Environmental Policy 101
An environmental policy is a document that defines what the organisation is trying to achieve from an environmental point of view. It is a relatively simple document but an important one as it is used both internally and externally to market the organisation and its commitments.
A policy must be written after the aspects and impacts have been determined. It cannot be written before these stages as the significant impacts of the organisation on which the policy is based will not be known.
Before we go in to detail take a look at the list below to give you an idea of some of the basics:
- A good policy should be easy to read and understand.
- They are usually one page in length.
- They generally do not consist of quantified improvement aims. Statements like ‘we will reduce energy consumption by 25% by 2012’ are targets rather than policy aims.
- There should be some evidence within the environmental management system (EMS) that the commitments in the policy are actually implemented.
- Do not use ‘weasel words’ as a former colleague of mine once called them! I think ‘endeavour to’, ‘as far as practicable’ etc. in this context dilute a policy and show that the organisation is none committal to improvement, although they are not a breach of ISO 14001 requirements.
ISO 14001 and the Environmental Policy
Let’s take a look at what ISO 14001 requires from an environmental policy statement.First of all ISO 14001 defines a policy as:
Statement by the organisation of its intentions and principles in relation to its overall environmental performance which provides a framework for action and for the setting of its environmental objectives and targets.
More specifically ISO 14001 states that a policy should consist/ comply with the following (I have put my views on what is needed below each requirement):
Is appropriate to the nature, scale and environmental impacts of its activities, products or services.
This means that it must be based on your organisation not someone else’s and is an important reason as to why you should write the policy statement after the environmental aspects and impacts have been assessed.
Includes a commitment to continual improvement and prevention of pollution
These are key commitments which must be included within the policy (two of the three pillars in the picture below). I recommend to my clients that they use the actual words such as:
We are committed to continual environmental improvement.
If you organisation is committing itself to preventing pollution and continual improvement then it goes without saying that there must be some evidence somewhere that you are doing this within the organisation.
Include a commitment to comply with relevant environmental legal and other requirements to which the organisation subscribes.
Again this must be stated directly in the policy (the remaining pillar in the picture above), other requirements includes items that are similar to law such as international standards, guidance documents, customer requirements etc.
Provides a framework for setting and reviewing environmental objectives and targets.
The policy acts as an overall framework so for example if you state in your policy that you are going to reduce energy consumption then you should have an objective and target linked to this policy aim.
Is documented, implemented and maintained and communicated to all employees.
The policy should be written down (documented), what you state on your policy should actually be done (implemented), the policy should must be kept up to date (maintained) and communicated to employees (ways include intranet, noticeboards etc).
Is available to the public.
There are various ways this can be done including being placed on the internet.
Issues to Include in a Policy
These can be various and will differ for organisations. An important source of information, but not the only one should be the aspects and impacts assessment. There are some ISO 14001 mandatory issues which should be considered as we saw earlier. But other issues such as addressing the significant impact should be considered.
The following are guidelines on how to write an Environmental Policy:
- There should be a title such as ‘Joe Bloggs Ltd Environmental Policy Statement’.
- An opening paragraph should briefly describe the activities, products and/or services of the organisation. This only needs to be a short description of your organisation – just a few lines.
- Consider including statements that shows the organisation is committed to the three pillars of ISO 14001 (commitment to legal and other requirements, prevention of pollution and continual improvement).
- List the commitments that are relevant to the identified significant aspects and impacts of your organisation for example reduction in energy consumption, waste minimisation, pollution control etc. (remember don’t use weasel words as it shows a lack of commitment).
- The policy should be signed by the most senior person within the organisation.
- The policy should be dated.
Implementing the Policy
The policy must be implemented, that is for each statement there must be some kind of evidence to show that you are doing what is required by the statement. A policy is the start of the improvement process rather than assessing the issues. This is continued by the development of objectives, targets and management programmes, which are based on the policy commitments.
The policy should also be kept up to date. It may need amendment if there is a significant change in your organisation. It is common practice that every year the policy is reviewed (and updated if required).
- The Environment has an Economic Value!
- Top Five Tips to Simplify your ISO14001 EMS
- Environmental Key Performance Indicators
- Where to Start When Implementing ISO 14001
- How to Write a ‘Good’ Environmental Policy Statement
- Is the Environment a Burden for Business
- Environmental Objectives, Targets and Management Programmes for ISO 14001