Small and medium size businesses with a single location that employ ISO 14001 Environmental Management System have developed solid models for the top level documentation. At the same time, information on Environmental Manuals for multi-facility companies has not been addressed in professional publications. This publication proposes a model of an Environmental Manual for establishing the top-level documentation structure that allows a business with more than one site to use a common ISO 14001 Environmental Management System Manual.

As a professional EMS assessor with leading certification bodies, I audited many large multi-site enterprises that had problems with aligning their corporate ISO 14001 Environmental Manuals with the corresponding procedures issued by their locations. To fill this gap, some companies create Environmental Manuals for their locations as copies of the main Environmental Manual; other businesses develop location-specific Environmental Manuals that are completely independent form the home office Environmental Manual.

In practice, neither one of these approaches produce a consistent result. In the 1st instance when a modified Environmental Manual is used for a location, methods for updating local Environmental Manuals are not defined. This disconnect arises from the fact that the corporate office manuals are controlled by the home office, while local Environmental Manuals are facilities’ responsibility.

The 2nd approach, when companies permit their sites to establish their own Environmental Manuals, differences in all those Environmental Manuals lead to noticeable disconnect between the corporate and site-specific Environmental Manuals.

Those companies that adhere to the policy of maintaining a consistent corporate message regarding their position on Environmental issues will definitely experience a gap if they use methods that we discussed above.

One of Quality Works’ EMS clients illustrated this deficiency. The home office Manual documented majority of the applicable requirements. At the same time, their facility in Canada did not document Environmental policy, another missed a commitment to prevention of pollution, yet the third one forgot to document their EMS communication procedure at all!

As we can see, both approaches to creation of location’s ISO 14001 Environmental Manuals as copies of the corporate Manuals or independent Manuals do not appear to be practical. Besides, if a company has already spent time on developing an Environmental Manual, why should another employee in the same organization spent more time to create a similar or duplicate document?

To solve this problem, let’s review an ISO 14001 Environmental Manual model, specifically supporting document reference structure. As a common practice, an Environmental Manual references supporting documents within the text of the Manual. For example, clause 4.3.1, Environmental aspects may read: Environmental Consultants Inc. has established, implemented and maintains Environmental Aspect Procedure to identify the environmental aspects of its activities, products and services and Significant Environmental Aspect Matrix to determine and document those aspects that have or can have significant impacts on the environment.

This method of referencing supporting procedures is very common for Environmental Manuals for companies with single location. Interestingly, it also works for a multi-site business for those documents that are common for all sites. For instance, Audit Procedure, Data Analysis procedure, and others may be common for all your sites and be referenced in your Environmental Manual as shown.

While references to common procedures in an ISO 14001 Environmental Manual are clear, we still have to address those documents that are specific to particular locations such as site-specific aspect, programs, Hazmat handling and others. When we wish to maintain just one Environmental Manual, we need to reference in it supporting procedures for all sites which may easily clutter the Manual. To solve this problem we will examine how a common Environmental Manual can efficiently reference facility-specific procedures to address statements of the organization’s ISO 14001 Environmental Manual.

A method identical to a single-site organization can be used when the number of facilities is relatively small, let’s say 2 – 3. For example, element 4.5.2, Evaluation of compliance, may read: Consistent with Green Products’ commitment to compliance, we have established, implemented and maintain a Compliance Evaluation Procedure for periodically evaluating compliance with applicable legal requirements per the Legal Requirements Matrix HO and the Legal Requirements Matrix Canada. This example references to the common Compliance Evaluation Procedure and facility-specific Legal Requirements Matrix HO (Home Office) and Legal Requirements Matrix Canada. This approach works well for a company with limited number of locations, but it becomes bulky and unworkable when the number of facilities grows.

When an enterprise has significant number of facilities and needs to reference in its corporate Manual numerous procedures including those controlled by its sites, we have another choice. We can develop a matrix to connect our Environmental Manual elements with the location-specific supporting documents. We will title this document Manual Reference Matrix and establish the following documentation reference structure.

Corporate ISO 14001 Environmental Manual section

Manual Reference Matrix Table of Contents (ToC)

Facility Manual Reference Matrix

Corresponding site-specific document

Our Manual Reference Matrix ToC is simply a list of company’s locations or sites’ Manual Reference Matrixes, as shown in the illustration below:

Manual Reference Matrix Table of Contents

Main Office (Washington, DC USA)

Toronto (Canada)

Springfield, IL (USA)

Singapore

Tokyo (Japan)

etc,

Let’s see how this model works. We will document section 4.4.1 Resources, roles, responsibility and authority: Hazmat Experts Company ensures the availability of resources essential to establish, implement, maintain and improve the EMS per the Resource Procedure and the organizational charts per the Manual Reference Matrix To locate a site-specific organizational chart, we simply need to consult the Manual Reference Matrix ToC.

Let’s say we need to locate a Communication Procedure for our Singapore plant. When we find this clause in our Manual Reference Matrix table of contents, we actually will connect to the location’s Manual Reference Matrix. Finding the corresponding clause number in the site’s Manual Reference Matrix, we will find a site-specific procedure title that addresses our clause of the Environmental Manual.

A Manual Reference Matrix may be formatted as a three-column form. The first two columns are titled Corporate EMS Section No. and Corporate EMS References; the third column is called Location procedures. For the element 4.3.1, for example, the Matrix indicates that our Manual Reference Matrix references Significant Environmental Aspect Matrix HO for the corporate office and the Significant Environmental Aspect Matrix WA for the Washington facility.

For examples of the Manual Reference Matrix, follow the links below.