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COMPANY NAME Reference #: E-RF-13.12.

01
ENVIRONMENTAL MANAGEMENT SYSTEM Issue Date: Nov. 13, 2001
Document: Gap Analysis Revision Date: NEW

TERRASTAR EMS PAGE 1 of 1

GAP ANALYSIS

The purpose of this Gap Analysis is to indicate the relative degree of conformance between the facility's
current approach to environmental management against the requirements of ISO 14001. The Gap
Analysis, together with the Register of Legal and Other Requirements (Step 1.4) and the identification of
Environmental Aspects (Step 1.5), helps to identify strengths and weaknesses in the organizations
approach and facilitates the EMRs development of the EMS Implementation Plan (Step 2.1)


Instructions

Yes Column Many questions have a simple Yes answer, and other questions may have
more complex implications, such as whether a policy or procedure has been
formally approved and been allocated appropriate resources. Answer Yes if
the EMS element:
has been formally approved, with responsibility and resources assigned
where work has started against an established time frame, and
if appropriate internal communication has been issued.

No Column Provide either a simple No answer or answer No where any of the three
conditions cited above in Yes have not been met.

Comments Column This column can be used by the EMR or EMS auditors to identify or prioritize
issues with a No answer that require further work, or to document additional
stages toward the successful completion of EMS Implementation. Issues that
could be considered include if, for example:
the EMS element has been addressed thru appropriate training
the EMS element has appropriate documentation, where required
the EMS element has been Evaluated
the EMS element has been Tested
the EMS element has been Reviewed, and/or
the EMS element has been Audited


A similar checklist will be used near the end of the implementation process, during the EMS Internal
Audit (Step 3.8).
COMPANY NAME Reference #: E-RF-13.12.01
ENVIRONMENTAL MANAGEMENT SYSTEM Issue Date: Nov. 13, 2001
Document: Gap Analysis Revision Date: NEW

TERRASTAR EMS PAGE 2 of 2

4.2 Commitment and Environmental Policy

No. Question Yes No Comments
1 Top management has made a commitment to address
environmental issues related to the organizations activities
products and services?

2 Has the environmental policy been defined and approved by
top management (at the site)?

3 Is (or does) the policy:
a) appropriate to the nature, scale and environmental
impacts of its activities, products and services?

b) include a commitment to continual improvement?

c) include a commitment to the prevention of pollution?

d) include a commitment to comply with relevant
environmental legislation and regulations?

e) include a commitment to comply with other requirements
to which the organization subscribes?

f) provide the framework for setting and reviewing
environmental objectives and targets?

g) documented, implemented and maintained?

h) communicated to all employees?

i) available to the public?



4.3 Planning

No. Question Yes No Comments
4.3.1 Environmental Aspects
4 Has a procedure to identify the environmental aspects of the
facilitys activities, products or services that it can control or
those over which it can be expected to have an influence
been developed?

5 Has the concept of "control" and "influence" been
consistently and effectively applied?

6 Has the procedure been effectively applied (have all of the
obvious environmental aspects of the business been
identified)?

7 Are the significant environmental impacts (actual and
potential) related to the environmental aspects identified
(have all of the obvious environmental impacts related to the
environmental aspects of the organization been identified)?

8 Are the criteria for evaluating significance relevant,
appropriate and consistently applied (have all of the
obviously significant environmental impacts been classified
as such)?

9 Are the environmental aspects related to the significant
environmental impacts identified for consideration in setting
environmental objectives and targets?

10 Has the information been kept up-to-date?


COMPANY NAME Reference #: E-RF-13.12.01
ENVIRONMENTAL MANAGEMENT SYSTEM Issue Date: Nov. 13, 2001
Document: Gap Analysis Revision Date: NEW

TERRASTAR EMS PAGE 3 of 3

No. Question Yes No Comments
4.3.2 Legal and Other Requirements
11 Has a procedure to identify the legal and other requirements
to which the organization subscribes directly applicable to
the environmental aspects of its activities, products or
services been developed?

12 Does the procedure provide for access to the information?

13 Are the directly applicable legal and other requirements fully
(all of those obviously relevant) identified?

14 Does the procedure provide for keeping the information up-
to-date?

15 Does the procedure provide for the information to be
available for use in setting environmental objectives and
targets and for the stipulation of operating criteria?


No. Question Yes No Comments

4.3.3 Objectives and Targets
16 Has the organization established and maintained
documented environmental objectives and targets, at each
relevant function and level within the organization?

17 Have the following areas been considered in the
establishment of the environmental objectives and targets:

a) legal and other requirements?

b) significant environmental aspects?

c) technological options?

d) financial, operational and business requirements?

e) the views of interested parties?

18 Have the objectives and targets been reviewed?

19 Did the review consider the requirements noted when
establishing the objectives and targets?

20 Are the objectives:
a) consistent with the environmental policy?

b) inclusive of the commitment to prevention of pollution?

21 Are there environmental aspects and impacts of the
organization that obviously require an objective and target
but where one has not been established?

22 Is each environmental objective and target:
a) quantified where practicable?

b) set with a relevant timeframe?

c) relevant to each functional level?

d) understood by the relevant staff at each level?


COMPANY NAME Reference #: E-RF-13.12.01
ENVIRONMENTAL MANAGEMENT SYSTEM Issue Date: Nov. 13, 2001
Document: Gap Analysis Revision Date: NEW

TERRASTAR EMS PAGE 4 of 4


No. Question Yes No Comments
4.3.4 Environmental Management Program
(Environmental Action Plan)

23 Has the organization developed an environmental
management program or action plan(s)?

24 Does the program/plan include:
a) designation of responsibility for achieving objectives and
targets at each relevant function and level of the
organization?



b) the means and timeframe by which they are to be
achieved?

25 Does the program/plan relate to new developments and new
or modified activities, products or services?

26 If so, has the program/plan been amended where relevant to
ensure that environmental management applies to such
projects?



4.4 Implementation and Operation

No. Question Yes No Comments
4.4.1 Structure and Responsibility
27 Are roles, responsibilities and authorities
a) defined,

b) documented, and

c) communicated?

28 Does the system facilitate effective environmental
management?

29 Has management provided the resources essential to the
implementation and control of the environmental
management system?

30 Does the resource base include:
a) human resources and specialized skills?

b) technology and financial resources?

31 Has top management (at the site) appointed a management
representative?

32 Does the management representative have the following
roles, responsibilities and authority, irrespective of other
responsibilities:
a) ensuring that environmental management system
requirements are established, implemented and maintained
in accordance with this standard?

b) reporting on the performance of the environmental
management system to top management for review and as
a basis for improvement of the environmental management
system?

COMPANY NAME Reference #: E-RF-13.12.01
ENVIRONMENTAL MANAGEMENT SYSTEM Issue Date: Nov. 13, 2001
Document: Gap Analysis Revision Date: NEW

TERRASTAR EMS PAGE 5 of 5


No. Question Yes No Comments
4.4.2 Training, Awareness and Competence
33 Has the organization identified training needs?

34 Have all personnel whose work may create a significant
impact upon the environment received appropriate training?

35 Have procedures for environmental training been
established?

36 Do the procedures ensure that employees or members at
each relevant function and level are aware of:
a) the importance of conformance with the environmental
policy and procedures and with the requirements of the
environmental management system?

b) the significant environmental impacts, actual or potential,
of their work activities and the environmental benefits of
improved personal performance?

c) their roles and responsibilities in achieving conformance
with the environmental policy and procedures and with the
requirements of the environmental management system?

d) emergency preparedness and response requirements?

e) the potential consequences of departures from specified
operating procedures?

37 Have the competency requirements for tasks, which can
cause significant environmental impacts, been developed
(based on appropriate education, training, and/or
experience)?

38 Are the competency requirements subject to review and
have they been kept up-to-date?

39 Do the personnel performing the tasks which can cause
significant environmental impacts meet the competency
requirements (Have competency requirements relevant to
each environmental impact been identified)?

40 Have contractors been considered and/or included in the
implementation of each aspect of this clause?


No. Question Yes No Comments
4.4.3 Communication


41 Has the organization established and maintained procedures
for:
a) internal communication between the various levels and
functions of the organization?



b) receiving, documenting and responding to relevant
communication from external interested parties regarding its
environmental aspects and environmental management
system?



42 Have processes for external communication on its significant
environmental aspects been considered?



43 Has the decision been recorded?






COMPANY NAME Reference #: E-RF-13.12.01
ENVIRONMENTAL MANAGEMENT SYSTEM Issue Date: Nov. 13, 2001
Document: Gap Analysis Revision Date: NEW

TERRASTAR EMS PAGE 6 of 6

No. Question Yes No Comments

4.4.4 EMS Documentation
44 Has documentation to describe the environmental
management system been established and maintained?

45 Does the documentation describe the core elements of the
management system and their interaction?

46 Does the documentation provide direction to related
documentation?


No. Question Yes No Comments

4.4.5 Document Control
47 Has a document control procedure been established and
maintained?

48 Are all of the documents required to implement this standard
identified and controlled in accordance with the procedure?

49 Are the relevant documents:
a) readily locatable?

b) periodically reviewed, revised as necessary and approved
for adequacy by authored personnel?

c) available at all locations where operations essential to the
effective functioning of the system are performed in the
current version

d) removed from all points of issue and points of use or
otherwise assured against unintended use when they
become obsolete?

e) suitably identified as obsolete if retained for legal and/or
knowledge preservation purposes?

50 Are the documents:
a) legible?

b) dated (with dates of revision)?

c) readily identifiable?

d) maintained in an orderly manner?

e) retained for a specified period?

51 Have appropriate procedures and responsibilities been
established and maintained concerning the creation and
modification of the various types of document?


No. Question Yes No Comments

4.4.6 Operational Control
52 Have the operations and activities that are associated with
the identified significant environmental aspects been
identified?

53 Are the operations identified in line with the organizations
environmental policy, objectives and targets?

54 Has the organization planned these activities, including
maintenance, in order to ensure that they are carried out
under specified conditions by:
a) establishing and maintaining documented procedures to
cover situations where their absence could lead to deviations
from the environmental policy and the objectives and
targets?

COMPANY NAME Reference #: E-RF-13.12.01
ENVIRONMENTAL MANAGEMENT SYSTEM Issue Date: Nov. 13, 2001
Document: Gap Analysis Revision Date: NEW

TERRASTAR EMS PAGE 7 of 7

b) stipulating operating criteria for the procedures

c) establishing and maintaining procedures related to the
identifiable significant environmental aspects of goods and
services used by the organization?

d) communicating relevant procedures and requirements
related to the identifiable significant environmental aspect of
goods and services used by the organization to suppliers
and contractors?

55 Do the specified conditions result in conformance with the
system, legislative compliance, prevention of pollution and
continual improvement?


No. Question Yes No Comments

4.4.7 Emergency Response and Preparedness
56 Has the organization established and maintained procedures
to identify the potential for and to respond to accidents and
emergency situations?

57 Does the procedure provide for the prevention and mitigation
of the environmental impacts that may be associated with
them?

58 Have the emergency preparedness and response
procedures been reviewed?

59 Have any identified revisions been implemented?

60 Were the procedures reviewed after the occurrence of any
accidents or emergency situations?



4.5 Checking and Corrective Action

No. Question Yes No Comments
4.5.1 Monitoring and Measurement
61 Has the organization established and maintained
documented procedures to monitor and measure on a
regular basis the key characteristics of its operations and
activities that can have a significant impact on the
environment?

62 Does this include:
a) the recording of information to track performance

b) relevant operational controls?

c) conformance with the organization's objectives and
targets?

63 Is monitoring equipment calibrated and maintained?

64 Have records of this process been retained according to the
organization's procedures

65 Do the procedures provide for the action to reduce
environmental impact and notify relevant interested parties if
monitoring equipment is found to be out of calibration?

66 Has the organization established and maintained a
documented procedure for periodically evaluating
compliance with relevant environmental legislation and
regulations?

COMPANY NAME Reference #: E-RF-13.12.01
ENVIRONMENTAL MANAGEMENT SYSTEM Issue Date: Nov. 13, 2001
Document: Gap Analysis Revision Date: NEW

TERRASTAR EMS PAGE 8 of 8

67 Have records of this evaluation been retained according to
the organization's procedures?


No. Question Yes No Comments

4.5.2 Non-conformance and Corrective and
Preventative Action

68 Has the organization established and maintained procedures
for:
a) defining responsibility and authority for handling and
investigating non-conformances?

b) taking action to mitigate any impacts caused?

c) for initiating and completing a corrective and preventive
action?

69 Has corrective or preventative action been taken to eliminate
the causes of actual and potential non-conformances been
appropriate to the magnitude of problems and
commensurate wit the environmental impact encountered?

70 Has the organization implemented and recorded any
changes in the documented procedures resulting from
corrective and preventive action?


No. Question Yes No Comments

4.5.3 Records
71 Has the organization established and maintained procedures
for the identification, maintenance and disposition of
environmental records?

72 Do these records include:
a) training records?

b) audits?

c) management reviews?

73 Are the environmental records for each activity, product or
service involved:
a) legible?

b) identifiable?

c) traceable?

74 Are environmental records stored and maintained in such a
way that they are:
a) readily retrievable, and

b) protected against damage, deterioration or loss?

75 Are their retention times established and recorded?

76 Are the records appropriate to the system and organization?

77 Are the records sufficient to demonstrate conformance to the
standard?



No. Question Yes No Comments

4.5.4 Environmental Management System Audit
78 Has the organization established and maintained program(s)
and procedures for periodic environmental management
system audits?

COMPANY NAME Reference #: E-RF-13.12.01
ENVIRONMENTAL MANAGEMENT SYSTEM Issue Date: Nov. 13, 2001
Document: Gap Analysis Revision Date: NEW

TERRASTAR EMS PAGE 9 of 9

79 Do the audits determine whether or not the environmental
management system:
a) conforms to planned arrangements for environmental
management including the requirements of this standard?

b) has been properly implemented and maintained?

80 Is information on the results of audits provided to
management?

81 Is the audit program, including any schedule, based on the
environmental importance of the activity concerned and the
results of previous audits?

82 Do the audit procedures cover the
a) audit scope?

b) frequency?

c) methodologies?

d) responsibilities and requirements for conducting audits?

e) the reporting of results?


4.6 Management Review

No. Question Yes No Comments
83 Has top management determined an interval for review of
the environmental management system?

84 Has management review of the environmental management
system been completed in accordance with the organization
procedures?

85 Did the review determine its continuing
a) suitability?

b) adequacy?

c) effectiveness?

86 Does the management review process ensure that the
necessary information is collected to allow management to
carry out this evaluation?

87 Are the reviews documented?

88 Do the reviews address the possible need for changes to:
a) policy

b) objectives?

c) other elements of the environmental management
system?

89 Does the review consider the effects of the following:
a) environmental management system audit results?

b) changing circumstances?

c) the commitment to continual improvement

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