I have been dealing with environmental management systems (EMS) for many years -whether developing them, auditing them or training folks about them, one thing that I have generally noticed is that they are often more complicated than they need to be.
More does not mean better! I think the following are good reasons as to why it is worth slimming down an EMS:
- A complex EMS is less likely to be used and understood by staff – for example environmental manuals, procedures are sometimes longer and complex than they need to be.
- More time is spent maintaining the EMS – a bigger more complex EMS requires more time filling in forms, updating environmental aspects and impacts registers etc
- Increased cost – more staff time will be needed to maintain and update the system.
- Paper work – the effectiveness of the EMS at controlling risk can be substantially decreased with most effort being placed on generating paperwork.
Take into account however that when I say less is better, I do not mean that the bare minimum is acceptable, it is just that the complexity of an EMS should represent the organisation activities and therefore its level of risk. For example an EMS for a small office would not need the same depth of EMS as a large chemical plant.
I have always been an advocate of simple and effective EMSs for many years, so here are my thoughts on how an organisation can simplify its EMS:
- Are the environmental aspects and impacts you identified too detailed ?- for example have you assessed every single chemical in the lab when it may have been just as effective to assess them together in group (for example acids, alkalis etc).
- Consider ditching the complex scoring system for assessing environmental aspects and impacts for one that uses simple questions – see my post on environmental aspects and impacts to give you an example.
- Your environmental manual does not need to have an in depth description of your EMS and should not include actual procedures themselves. Briefly describe procedures and reference them so that the reader can see the actual procedure if they need to later. The manual that I develop for clients tends to be no more than fifteen pages.
- Try not to generate a form or record within your EMS unless you really need to – some records/forms you must keep as there is a compliance obligation to retain them but for others ask yourself does the record/form add an value to the EMS. Filling in records/forms is a time consuming business.
- Do not use long complex procedures (unless you need to) – alternatives include flow chart procedures, pictures and even films (or a combination of these). You might understand a procedure but will someone else who reads it?