ISO 14001 Clause 4.4

ISO 14001 clause 4.4 is the most extensive clause in the standard. There are seven sub-clauses as follows:

4.4.1 Resources, roles, responsibility and authority
4.4.2 Competence, training and awareness
4.4.3 Communication
4.4.4. Documentation
4.4.5 Control of documents
4.4.6 Operational control
4.4.7 Emergency preparedness and response

Let's take a brief look at each of the sub-clauses of ISO 14001 clause 4.4:

4.4.1 Resources, roles, responsibility and authority

The successful implementation of an EMS requires a commitment from everyone in the company or on its behalf. Environmental responsibility should not be perceived as just a responsibility of the environmental function. A sound and practical EMS is played-out at all levels and functions of a company. The commitment and practice begins at the highest levels of a company. Therefore, top management should develop the company’s environmental policy and make certain the EMS is properly implemented. They need to appoint a person or persons with defined (documented) responsibility, accountability and authority for implementing the EMS.

Management also needs to ensure there are sufficient resources to make the EMS operational and effective. In addition, key environmental management roles and responsibilities are well defined and communicated to everyone in the company and to those that do work for the company.

4.4.2 Competence, training and awareness

The company needs to determine the awareness, knowledge, understanding and skills needed by anyone with the responsibility and authority that performs work on its behalf.

The standard requires:

• Those people whose work could cause significant environmental impact(s) identified by the company be competent to perform those tasks,
• The training needs are identified and actions are taken to satisfy the need,
• Everybody is aware of the company’s environmental policy and the EMS and the environmental aspects of the company’s activities, products, and services that could be affected by their work.

The required environmental skills can be obtained or improved through training, education or work experience.

The company should require that contractors working on its behalf are able to demonstrate that their employees have the required competence and knowledge about environmental aspects.

The company’s management should determine the level of experience, competence and training necessary to ensure the capability of personnel, especially those carrying out specialized environmental management functions.

4.4.3 Communication

Communicating within the company about its environmental aspects and the EMS is necessary to implement an effective EMS. This can be accomplished through the chain-of-command, work team meetings, newsletters, bulletin boards and intranet web site or any method that works for the company.

The company should implement a procedure for receiving, documenting and responding to communications from interested parties. This procedure may include a dialogue with interested parties and consideration of their concerns. In some circumstances, responses to interested parties may include information about the environmental aspects and impacts associated with the company’s operations. The procedure should also address necessary communication with public authorities regarding emergency planning and other issues.

The company might want to plan its communication taking into account the decisions made on target groups, the appropriate messages and subjects, and the choice of means.

4.4.4. Documentation

The detail and amount of documentation for the EMS should be sufficient enough to describe the EMS and how its various parts work together. And, to provide guidance on where to find more detailed information on the operations of particular parts of the EMS.

You can integrate the EMS documentation into the documentation of other systems, if you wish. Although many companies develop an EMS manual, the documentation doesn’t have to be in the form of a manual.

How much documentation a company develops will depend on principally three conditions as follows:

1. The size and type of company and its activities, products and/or services,

2. The complexity of processes and their interactions, and

3. The competence of the people in the company.

4.4.5 Control of documents

The primary focus of the company should be the effective implementation of the EMS and improving environmental performance, not documentation. Create and issue documents only where absolutely necessary to guarantee the effective operation of the EMS. However, the documents that are issued must be controlled to ensure the current and correct information is being used.

4.4.6 Operational control

The company needs to evaluate its operations where significant environmental aspects are present and develop methods to ensure that exposure is controlled and that it meets the objectives and targets. Don’t forget, this includes all operations (office, janitorial, maintenance, etc.).

This sub-section of the standard gives direction on how to take the EMS requirements into the day-to-day operations by requiring a documented procedure to control situations where absence of documentation could lead to deviations from the required method and the environmental policy, objectives and targets.

4.4.7 Emergency preparedness and response

Every company should have procedures for responding to emergencies and accidents that could impact the environment. When developing its procedure(s) the following should be taken into consideration:

• The nature of the on-site hazards (i.e. flammable materials, compressed gases, storage tanks and facilities),
• The most likely type and size of an emergency situation or accident,
• The best way to respond to the situation,
• Internal and external communication methods
• The actions that will be absolutely necessary to minimize environmental damage,
• The different type of action needed based on the situation,
• A procedure/method for post-accident investigation and corrective action, and
• many additional items are covered in our ISO 14001 Implementation Guide 

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