Cems Guidance Manual: Managing Your Environmental Responsibilities

CEMS GUIDANCE MANUAL
Managing Your Environmental Responsibilities
i
EMS GUIDANCE MANUAL
4.4 IMPLEMENTATION AND OPERATION
4.4.1 Resources, roles, responsibilities and authorities
Construction enterprises should harmoniously utilize resources to minimize

adverse environmental impacts through appropriate organizational assignments of
roles and responsibilities. In a construction company, those in the top management
should commit to provide resources that are essential in establishing, implementing,
maintaining and improving the EMS. The essential resources may include human
resources with specialised skills, technological, and financial resources. Human
resources such as trained site supervisors in the area of environmental aspects and
impacts, environmental engineer, technology such as spun drilling and financial
resources for the implementation of mitigating measures such as silt traps and
environmental training programmes among other things.
Proper organizational structure of the construction company is needed to identify

the line of responsibility and mode of reporting. This enables the organization to
manage their on site operations to improve environmental performance. Top
management should further ensure that desired roles, responsibilities and
corresponding authorities of key personnel are clearly defined, well documented and
effectively disseminated.
4.4.1.1 Resources required to manage system

Identify organizational structure especially on site where most of the construction
activities are happening. Responsible personnel to manage the system in a
construction site is divided into on site and office management. Those that are
involved on site include site manager, site engineer and site environmental officer.
These personnel should have the correct attitudes, values and beliefs in the
implementation of the EMS and should be assigned to manage the implementation
of the EMS. Their roles, responsibilities and corresponding authorities, which should
be clearly defined by the office management of the contractor or developer.
1
EMS GUIDANCE MANUAL
What to do?
a) Identify the responsible personnel; eg site supervisor, site
manager, environmental officer
b) Determine the type, number and composition of the human
resources, especially on site;
c) Assign and mobilise these personnel;
d) Monitor the needs of the personnel, such as the need to train the
personnel in projecting and identifying possible impacts;
e) Co-ordinate their roles so that the developer or contractor can
effectively apply the EMS; and
4.4.1.2 Roles, responsibility and authority

All personnel should clearly understand their environmental roles and
responsibilities, as well as understand the importance of the environmental
objectives and targets that they can affect.
What to do:
a) Identify the persons in the top and other management levels
responsible for managing the implementation of the EMS;
b) The commitment of the top management should be rely to the site
office
c) Define and communicate their EMS roles, job responsibilities and
authority;
d) Identify the roles and responsibilities on site and the conveyance
Example of roles and responsibilities
EMS Reference Title EMS Manual Section Number Accountability

& Title
A-1. Index  None assigned
A-2. Introduction  Maintain Section: EMS Representative
A-3. EMS Scope  Define Scope & Applicability: Core team
 Maintain Section: EMS Representative
A-4. EMS Manual Distribution  Maintain Section & Distribute Manual: EMS
Representative
A-5. EMS Manual Record of  Maintain Section & Review Manual: EMS
Revisions Representative
Environmental Policy B-1. Corporate Sustainable  Approve/Issue Env. Policy: Chairman, CEO
Energy Development Policy  Comply with Policy: all staff
and Principles  Maintain Section: EMS Representative
B-1. Environmental Policy  Approve/Issue Env. Policy: Executive VP
2
EMS GUIDANCE MANUAL
 Comply with Policy: all staff

Environmental Aspects B-2. Identifying Environmental  Establish/Maintain/Implement process at
Aspects Director Environmental Affairs
B-2. Determining Significant  Maintain/Apply Process & Develop/Maintain
Environmental Aspects EMS Aspects database: Director Environmental
Affairs, EMS Representative
 Division Input to EMS Aspects database: EMS
Reps, Divisions
Legal and Other B-3. Interpreting Legal  Implement & Maintain Process: VP, Regulatory
Requirements Requirements Affairs
B-3. Interpreting other  Implement & Maintain Process: VP, Regulatory
Requirements Affairs
 Maintain this Section: EMS Representative
Objectives and Targets B-4. Developing Objectives  Develop Objectives & Targets, Division
and Targets Directors and EMS Core Team, Director
Environmental Affairs
 Approve Objectives & Targets: VP Operations
 Meet Objectives & Targets: Directors
Environmental B-5. Environmental Programs  Approve Programs: Division Directors
Management Programs  Develop and Maintain Programs: Director
Environmental Affairs
 Maintain this Section: EMS Representative
4.4.1.3 Management representative

To implement the EMS, top management should give their commitment, play their
roles, take responsibility and confer authority. They need to appoint their
representative from a senior position with unambiguous job specifications. The
motivations of the contractors in seeking to implement the EMS, the problems and
costs to be faced and the lessons to be learned can be easily more explicit.
What to do:
a) Identify the persons in the top and other management levels

responsible for managing the implementation of the EMS. This
could be the project manager.
b) Define the EMS roles, responsibilities and authority of the top
management;
c) Nominate the EMR and the Deputy EMR from the managerial
level and those that are well trained in construction related
environmental issues;
3
EMS GUIDANCE MANUAL
Example of responsibility matrix
Project EHS HR Purchasing Site EMS Mg’t

Maintenance Engineering Finance Employees
M’gr M’gr M’gr /Materials Supervisor Rep.
Communicate importance
of environmental L S S
management
Coordinate auditing efforts L S S
Track / analyze new
regulations (and maintain L
library)
Obtain permits & develop
L S
compliance plans
Prepare construction
progress and environemtnal
monitoring and audit L
reports required by
regulations
Coordinate communications
L
with interested parties
Train employees S L
Integrate environmental into
L
recruiting practices
Integrate environmental into
the construction
L
performance appraisal
process
Communicate with
contractors on L
environmental expectations
Comply with applicable
L L S S S S S S S S
regulatory requirements
Conform with
organization's EMS L L S S S S S S S S
requirements
Maintain equipment / tools
to control environmental L
impact
Monitor key processes S L
Coordinate emergency
L S
response efforts
Identify environmental
aspects of products, S L S S S S S S S
activities or services
Establish environmental
L S S
objectives & targets
Develop budget for
S L
environmental management
Maintain EMS records
L
(training etc.)
Coordinate EMS document
S L
control efforts
Legend:
L = Lead Role
S = Supporting Role
The following questions will need to be answered in order to determine whether the
Structure and Responsibility Section meets the intent of ISO 14001:
4
EMS GUIDANCE MANUAL
• Have you defined the roles, responsibilities, and authorities of your

employees with respect to the environmental management system?
• Have the above been documented and communicated on the project site as
well as the main office?
• Have the following resources been provided to implement and maintain the
system, especially at the project site?
 human resources (manpower),
 special skills,
 technology, and
 financial resources.
• Has a management representative been appointed?
• Does the management representative have the following defined role:
 establishing the EMS requirements,
 determining whether EMS requirements have been implemented,
 determining whether the EMS conformance is maintained,
 reporting to top management on conformance and continual
improvement.
5
EMS GUIDANCE MANUAL
4.4.2 Competence, training and awareness
Significant activities: who is responsible / should be competent / trained
Identify competent individuals: eg civil engineer (silt trap design)
Top management should commit to train their personnel, such as the site supervisor,
site engineer or the environmental, health and safety issue so tha they are
competent in the environmental issues. Competent in determining the aspects
and impacts, competent in environmental monitoring and design of the mitigating
measures such as silt traps, prevention of soil erosion, minimizing the noise level.
The ultimate goal for training is to inculcate and the importance of EMS to
personnel, and to explain their responsibilities for the EMS operations.
Workers, personnel and project consultants (examples are bull dozer drivers, civil
engineers, architects, project designers, etc) whose work may have significant
impact on the environment should be competent on the basis of appropriate
education, training and/or experience on environmental issues.
The contractors and subcontrators must determine overall training needs required
for competence with respect to the environmental management system.
4.4.2.1 Determining competency requirements

Training needs associated with environmental aspects and EMS should be identified,
and training programmes developed to ensure awareness and competence at each
relevant function and level.
6
EMS GUIDANCE MANUAL
What are essential?
a) The roles and responsibilities in achieving conformance to

environmental policies and procedures;
b) The importance of conformance to the environmental policy, the
procedures and the requirements of the structured EMS;
c) The significant environmental aspects – actual or potential – from
their work activities, and the importance of control over such
aspects
d) The potential consequences of departure from specified operating
procedures, e.g in land clearing on slopes and the importance of
emergency preparedness, in case of soil erosion, flash flood or
mud slide.
e) Avoid resistance of field supervisors, site engineers and general
4.4.2.2 Training and awareness

Procedures should be established and maintained to identify the personnel’s training
needs. Their awareness at each level and function should be enhanced.
The 2- step approach below is one example that can assist in identifying training
needs.
Step 1 : Identify training needs and requirements

• Review existing training programs. Other training (e.g. safety) may also satisfy
the EMS requirements.
• Consider both general and specific needs
• Develop an EMS training package for new employee orientation
• Review the qualifications and training needs of trainers
Step 2 : Training Staff

• Identify training needs and prepare training plan according to the training
procedure.
7
EMS GUIDANCE MANUAL
• Develop your EMS training materials.
• Train EMS core team members on EMS requirements.
• Conduct EMS awareness training with all staff to ensure them to be aware of
environmental policy, objectives, relevant significant environmental aspects, EMS
responsibilities and emergency procedures, etc. as appropriate.
Key Steps in Developing a Training Program
Step 1
Conduct training needs &
requirements
Step 2
Define training objectives
Step 3
Select suitable methods and
materials
Step 4
Prepare training plan
(who, what, when, where, how)
Step 5
Conduct training
8
EMS GUIDANCE MANUAL
4.4.2.3 List of recommended training

The following is a list of trainings that can be considered
CEMS Training Plan

Training Type( Target Staff Length Target Date Responsible
examples ) ( examples ) Personnel
　　　　　
Raising awareness All staff
of the importance Site manager,
of environmental EMR, etc
management
(examples)
　　　　　
Implementation Departmental
training Managers　
　　　　　
Emergency Relevant
response training construction
sites staff
　　　　
Environmental best All staff at
practice for construction
construction site site
　　　　　
Internal Auditor Departmental 　
training Managers,
Project
Managers,
EMR & DEMR
　　　　　
Examples of training in construction environmental best practices include soil

erosion and its prevention, silting of water bodies and its mitigative measures, dust
and noise impacts and how to reduce them. Air emission and noise sources,
characteristics and regulatory requirements can form part of the training package.
Proper training in handling chemicals is crucial that include its sources,
characteristics, handling and disposal can avoid any encumbrances with the
regulatory bodies such as the Department of Environment. Relevant disposal
9
EMS GUIDANCE MANUAL
licenses and regulatory requirements should be part of the training. Training can
also be determined in the identification of major types of solid wastes, generation
quantity and disposal. The personnel that require these trainings comprehend the
general employees on site, the site supervisor, the project manager, site engineer
and even the management at the main office.
Example of a Training Log
Training Topic Attendees* Frequency Course Course Comments Date

Length Method Completed
EMS Awareness
Supervisor EHS Training
Hazardous Waste
Management
Hazardous Waste
Operations
Spill Prevention &
Response
Chemical and waste
chemical Management
Emergency Response
Accident Investigation
Hazardous Materials
Transport
Hazard Communication
Personal Protective
Equipment
Fire Safety
Dust and air emission
control
Hearing Conservation
Confined Space Entry
Bloodborne Pathogens
( mosquitoes)
Job-Specific Training
(list)
Attendees Code
1: All Employees
2: Project Manager
3: Operators
10
EMS GUIDANCE MANUAL
4: Maintenance
5: Site engineer
6. Site supervisor
Training, Awareness and Competence Section meet the intent of EMS
11
EMS GUIDANCE MANUAL
• Have training needs been identified?

• Are all employees, whose work can cause significant environmental impacts,
competent on the basis of education, training and or experience?
• Have procedures been established to assure all employees are aware of the
Environmental Policy, actual and potential impacts and their responsibilities?
• Has the organization ensured that employees performing environmental specific
tasks have the required knowledge (e.g. education, training experience)?
• Does the communication process ensure that business partners, suppliers and
contractors are aware of the relevant requirements of your CEMS?
• Do the contractors working on site have the requisite knowledge and skills or
have been trained to perform the work in an environmental responsible manner?
• Are training records, certificates and licenses available to demonstrate the
competence?
• Have training needs been defined.
• Have baseline training related to the following been provided?
o importance of the CEMS,
o roles within organization related to the CEMS, and
o consequences of deviating from the CEMS.
• Are trainings for those positions that could have a significant impact on the
environment based upon education and experience required?
• Are trainings with respect to emergency preparedness and response been
identified?
• Have the employees developed competency standards?
12
EMS GUIDANCE MANUAL
4.4.3 Communication
Those working for, or on behalf of the organization should know what to do and how
to do it, if an environmental management system is going to work.
It is important that the means for communicating information exists and that
communications are regular. Getting feedback is also very important, so provision for
two way dialogue will be necessary.
Effective internal communication requires method for information to flow top-down,

bottom-up and across functional lines. Since employees are on the “front lines,” they
can be an excellent source of information, issues, concerns and ideas.
External communication can provide a good opportunity to promote the

organization's achievements and environmental performance and consult with
customers and other external interested parties.
4.4.3 Communication
It is important that the means for communicating information exists and that
communications are regular. Getting feedback is also very important, so provision for
two way dialogue will be necessary.
Effective internal communication requires method for information to flow top-down,

bottom-up and across functional lines. Since employees are on the “front lines,” they
13
EMS GUIDANCE MANUAL
can be an excellent source of information, issues, concerns and ideas. Internal

communications such as from the general employees at site to the site supervisor, to
the site manager and site engineer. The site manager can relay to the manager at
the main office or even the directors of the contracting company. In any event of
environmental problems on site , communication between those on site with those at
the main office is crucial since allocation of budget to address any issue normally
come from the main office. Correct and real time data and information during the
regular scheduled meeting, should be recorded and submitted to the main
management for review or action. Other internal communications that are deemed
crucial is between the environmental consultant to other consultants and the project
manager.
External communication can provide a good opportunity to promote the

organization's achievements and environmental performance and consult with
customers and other external interested parties. External communications can be
with the local authorities and the regulatory bodies such as the Department of
Environment, Department of Irrigation and Drainage.
14
EMS GUIDANCE MANUAL
Why communication is needed?
The purposes and benefits of communication can include:
a) Demonstrating the organisation’s commitment and efforts to

improve environmental performance, as well as the results of such
efforts;
b) Raising awareness and encouraging dialogue about organisation’s
environmental policy, environmental performance and
achievements;
c) Receiving, considering and responding to questions, concerns or
other inputs; and
d) Promoting continual improvement of environmental performance,
for problem solving, for co-ordination of activities, for follow-up on
action plans and for further development of the environmental
management system serves to motivate them and encourage
acceptance of the organisation’s efforts to improve its
environmental performance.
e) Assist employees to fulfil their responsibilities and the organisation
to meet its environmental objectives and targets.
Effective communication should be practised:
a) To avoid untoward environmental events as a result of the

construction activities such as land clearing, earthworks or the
construction work itself
b) To motivate personnel to abide to all regulations that are closely
linked to the construction industry, such as noise level, dust
generation, or inland water pollution;
c) To inform the employees what actions should be taken for the sake
4.4.3.1 Determining the need to communicate

The contractor, the project proponent and /or the developer should establish,
implement and maintain procedures for communicating – internally and externally –
on its environmental policy, performance or other information, based on its own
needs and the needs of interested parties.
Interested parties can include, for example, neighbours, non-government

organisations, customers, contractors, suppliers, investors, emergency services and
regulators.
15
EMS GUIDANCE MANUAL
Basic Steps to Communicate
Begin early in the process
Let people know what type of construction is going to take place. In most cases, the
cooperation of several people within the organization is needed to gather information
and develop a environmental management system that will work. In small and large
construction companies alike, early communication will pay off in greater acceptance
of the environmental management system.
Set communication objectives
Decide what needs to be achieved through communication regarding the construction

project.
(Setting this goal will help get the right message across without overloading people
with too much information, spending too much time, or missing the mark)
It is helpful to create an EMS communication policy.
How to report environmental incidents, such as spills, accidents and “near misses”.
The procedure should include who reports what, to whom, and when.
Communicate regularly and integrate EMS communication
To build support for the EMS, try to communicate on a regular basis.

– bulletin board posting, email messages, or articles in the organization newsletter.
– direct word-of-mouth communication, particularly in smaller organizations.
– talking directly with key individuals at intervals
16
EMS GUIDANCE MANUAL
Examples of information to be communicated include: (REVIEW THIS

PART)
a) General information about the construction that is going to be

conducted;
b) Management statement of the possible impacts and measures the
contractor or developer is going to undertake to minimize the
construction impacts.
c) Environmental policy, objectives and targets;
d) Environmental management processes (including employee and
interested party involvement);
e) The organisation’s commitment to minimize changes to the
environment as a result of the construction ;
f) Information related to environmental aspects of the construction,
g) The contractor’s motivation and commitment to have a proper
EMS in place
h) Problems that the contractor anticipated and measures to be
taken.
i) The attitudes, values and beliefs of the contractor towards the
safeguarding of the environment
j) The organisation’s compliance with legal and other requirements to
which the organisation subscribes, and corrective actions taken in
response to identified instances of non-compliance;
k) Supplementary information in reports, such as glossaries;
l) Sources for further information, such as contact person(s) or
websites.
For both internal and external environmental communication, it is

important to remember that:
4.4.1.1 Internal communication

Communication between and among the levels and functions within an organisation
is crucial to the effectiveness of the environmental management system. ( multiple
level – developer, managers, consultants, site supervisors and employees).
Issues to communicate can include, licensing, disposal and handling of wastes,

noise and air emission, public complaints, soil erosion, requirement to comply to
certain environmental impact approval conditions, environmental monitoring and
reporting to DOE.
17
EMS GUIDANCE MANUAL
In cases, where impacts have taken place, such as heavy silting of river due to
eroded soil surfaces on site, immediate communication to the top management
needs to be carried out so that appropriate actions be taken and budget identified.
Budget need to be allocated to implement or improve the mitigation measures.
If the local authorities takes action against the construction due to severe impacts,
then frequent and more intense communication between the top management on the
organization structure with the local authorities needs to be takes place.
Information regarding the EMS – such as the policy, objectives, targets

and the environmental management programmes – and environmental
performance should be made readily available to employees on notice
board, or be published on the intranet or newsletters.
Employees with enquiries or complaints regarding the EMS and/or

environmental issues should inform their site manager, project
manager or site engineer ( refer to the organizational structure)
Records to demonstrate the response and corrective actions that are

taken should also be maintained.
Information to pass down to employees:
a) Activities, aspects and impacts of the construction

b) Types of mitigating measures implemented
c) Maintenance of the measures
d) Compliance to environmental regulatory requirements
e) Possible implications that might arise from non compliance
f) Materials usage and control
g) Materials storage and handling
4.4.1.2 External communication

Communication with external interested parties can be an important and effective
tool for environmental management. Proactive methods can increase the
effectiveness of external communication. Authority reporting – EIA, monitoring,
EMP
18
EMS GUIDANCE MANUAL
External Methods:
• open houses
• focus or advisory groups
• web site or e-mail list
• press releases
• annual reports
• advertising
• informal discussions
• attending community
19
EMS GUIDANCE MANUAL
Example of External Communication Procedure
Communication Section meets the intent of ISO 14001:
• Do you have an internal communication process for the environmental

management system?
• Do you have a process in place for receiving and responding to "relevant"
external communications?
• Have you decided whether it will communicate to external parties’ information
with respect to its significant environmental aspects?
• If you decided not to communicate information to external parties with respect
to its significant environmental aspects, has it established a record of that
decision?
Structure of communication ( external) local authorities, public
20
EMS GUIDANCE MANUAL
Effective communications will help you:

• motivate your workforce;
• gain acceptance for your plans and efforts;
• explain your environmental policy and CEMS and how they relate to the
overall organizational vision;
• ensure understanding of roles and expectations;
• demonstrate management commitment;
• improve your relationship with the community;
• monitor and evaluate performance; and
• identify potential system improvements.
4.4.4 Documentation and control of documents
There are a number of documents that are commonly linked to construction and
these are environmental impact assessment (EIA), environmental management
program (EMP), environmental monitoring, documents of aspects and impacts and
the EMS manual. Many of these documents that are required under the regulation
can positively provide great input into the documentation of the EMS documents,
while maintaining its own identity.
To ensure that its environmental management system is understood and operating

effectively, an organisation should develop and maintain adequate documentation of
the EIA, EIA approval conditions, EMP and environmental monitoring and auditing.
Other documents include method statement, such as method statement for land
clearing, dredging, soil erosion prevention, chemical waste handling, biomass
handling and design of mitigating measures, for example silt trap and prevention
21
EMS GUIDANCE MANUAL
of slope failure. The purpose of such documentation is to provide necessary

information to employees and other interested parties as appropriate.
The EMS documentation comprises four levels:
CEMS
Manual:
Top Level Overview

of CEMS
Operating Procedures:
Relevant to
Locations/Functions
Work Instructions
Relevant to Departments/Tasks
Environmental Records
Environmental management system documentation pyramid
22
EMS GUIDANCE MANUAL
Documentation should be collected and maintained in a way that

reflects the culture and needs of an organisation, building onto and
improving its existing information system. The extent of the
documentation can differ from one organisation to another but it should
describe the environmental management system (see Practical help –
Documentation below).
For effective management of its key processes – i.e. those related to its
identified significant environmental aspects – an organisation should
establish (a) procedure(s) that describe, in appropriate detail, a
specified way of carrying out each process. If an organisation decides
not to document a procedure, appropriate employees need to be
informed, through communication or training, of the requirements to be
satisfied.
Records, which provide information on results achieved or evidence or

activities performed, are part of an organisation’s documentation, but
are generally controlled through different management processes.
4.4.4.1 Development of environmental manual
• Each document should have the following information:

∗Title (subject)
∗Document number
∗Revision & Copy number
∗Issue/Revision/Effective Date
∗Document originator
∗Approval (signature)
∗Cross-references
• EMS documents can be maintained electronically for easy access and reference.
However it must be controlled and ensured that only the administrative
department and EMR are able to change the documents on the server.
• Hard copies of these documents must be labeled Controlled Copy, Master Copy
and Uncontrolled Copy.
23
EMS GUIDANCE MANUAL
• Keep the procedure simple. Start with a few copies, and then add more if the
need arises.
• Maintain a master list of documents. This list would show all the EMS documents
and a history of its revision. Also maintain a distribution list, showing who has
each copy. This would ensure ease in tracing the documents.
Document EMS
Requirements Documentation Procedures Policy Others…
Linkages among
EMS Document
Control Preparation Issuance Revision Disposition
documentation,
Requirements
document control
and records
Records
Requirements Identification Retention Storage Disposition
24
EMS GUIDANCE MANUAL
4.4.4.2 Content of environmental manual

An organisation may choose to summarise information in the form of a manual,
which constitutes an overview or summary of the environmental management
system and can provide direction to related documentation.
What Constitutes EMS Documentation?
Your environmental policy

Your organizational structure and key responsibilities
A description or summary of how your organization
satisfies EMS requirements (e.g., “How do we
identify environmental aspects?”. “How do we
control documents?” How do we comply with legal
requirements?”)
System-level procedures (e.g., procedure for corrective
action)
Activity- or process-specific procedures / work
instructions
Other EMS-related documents (such as emergency
response plans, training plans, etc.)
The structure of any such environmental management system manual need not
follow the clause structure of ISO 14001 or any other standard.
4.4.4.3 Control of document

The essences of EMS documentation controls are:
a)They should be periodically reviewed, revised as necessary and approved for
adequacy by authorised personnel;
b)The current version of relevant documents should be available at all locations
where operations essential to the effective functioning of the EMS are
performed;
c)Obsolete documents should be promptly removed from all points of issue and
use or otherwise assured against unintended use; and
d)Any obsolete documents retained for legal and/or knowledge preservation
purposes should be suitably identified.
25
EMS GUIDANCE MANUAL
Why need to control of environmental management system documents
a) Documents can be identified with the appropriate organisation,

division, function, activity or contact person;
b) Documents (other than records) are regularly reviewed, revised as
necessary and approved by authorised personnel prior to issue;
c) The current versions of relevant documents are available at all
locations where operations essential to the effective functioning of
the system are performed; and
d) Obsolete documents can be promptly removed from all points of
issue and points of use.
How documents can be effectively controlled :
a) Developing an appropriate document format that includes unique

titles, numbers, dates, revisions, revision history and authority;
b) Assigning the review and approval of documents to individual with
sufficient technical capability and organisational authority; and
c) Maintaining an effective document distribution system.
Documents can be managed in any medium (paper, electronic, photos, posters)

that is useful, legible, easily understood and accessible to those needing the
information contained therein.
26
EMS GUIDANCE MANUAL
TIPS
Keep the documentation simple.

Use results from baseline assessment as a
foundation or starting point.
Include organization’s mission statement,
vision, guiding principles and annual objectives
to emphasis importance of CEMS in overall
business goals.
Continually reevaluate whenever changes
occur.
EMS Documentation Section meets the intent of ISO 14001:
• Do you have existing documentation of your EMS? How is this EMS

documentation maintained (electronically? In paper form?)
• Who is responsible for maintaining EMS documentation within your
organization?
• Do you have a EMS manual or other summary document that describes
the key elements of the EMS? If so, does this document describe the
linkages among system elements?
• What does your EMS documentation consist of? (List components such as
environmental policy, EMS manual, activity-level procedures or work
instructions, emergency plans, etc.)
• Is your EMS documentation integrated with other organizational
documentation (such as human resource plans or DEFINITIONS
quality procedures)? If
Controlled copy-documents
so, how do you ensure proper coordination between environmental
posted on the companyand
server
these other functions? for read-only access or the hard
copy. Subjected to automatic
• update when a new revision is
How will you keep your EMS documentation up-to-date?
released.
Uncontrolled Copy - Not
subjected to automatic update
when a new revision is released.
It is for reference only.
Master Copy – original hard copy
27 of the document that shall be
approved and signed by
authorized employees.
EMS GUIDANCE MANUAL
What EMS Documents should be controlled? Consider the

following:
Environmental policy
Objectives and targets
Roles, responsibilities and authorities
EMS description document (“manual”)
System-level procedures
Process-or activity-level procedures / work instructions
Related plans (such as emergency response plans
Top management
approve and sign all EMS
Documents
Environmental ASK:
Management Representative
Is everyone working
prepare and revise all EMS documents. with the same set of
documents?
Administration Department
responsible for the EMS document control
system
ensure that only controlled and current copies of
documents are used, & distribute controlled EMS
documents to relevant employees whenever updated
versions are available
maintain and update Master List of EMS Documents.
Functional or Department Manager
review relevant EMS documents and procedures, ensure subordinates

are familiar with updated EMS documents related to them, and report
any proposed changes to EMS documents and forms to EMS
Committee.
Chain of responsibility and authority of various employees
Basic Steps to Document Control
28
EMS GUIDANCE MANUAL
New documents are Authorized personnel review

Control of written. documents and approve
Documents them for adequacy. They
Procedure also review, update and re-
MY-QE-42-P01
approve documents.
Procedure
Changes and the current

revision status are identified
External Documents are
External identified and their
Document
distribution is controlled
Up-to-date documents are available
at work locations
Obsolete documents are Documents remain legible and readily
identified and discarded identifiable
Obsolete or archived
Document
Document Control Section meets the intent of ISO 14001:
• Do you have an existing process for controlling EMS documents? If yes, does
that process need to be revised? In what way?
• Who needs to be involved in this process within your organization?
• Who needs access to controlled copies of EMS documents? How do you
ensure that they have access?
• How do you ensure that EMS documents are periodically reviewed and
updated as necessary?
• Who has authority to generate new documents or modify existing ones? How
is this process managed?
29
EMS GUIDANCE MANUAL
• How are users alerted to the existence of new EMS documents or revisions to
existing ones?
• How do you ensure that obsolete documents are not used?
• Is your EMS document control process integrated with other organizational
functions (such as quality)? If so, how do you ensure proper coordination
between environmental and other functions?
30
EMS GUIDANCE MANUAL
4.4.5 Operational control
31
EMS GUIDANCE MANUAL
Operation control procedures should be established and maintained to manage

significant environmental aspects. All operations and activities that are associated
with significant environmental aspects, carried out by employee or contractor, should
be properly controlled.
Operations that can and should be controlled are those that can spawn impacts and
in construction industry these are associated with the construction activities. Control
is applied to pre construction planning for the most effective environmental outcome
and should be continuously applied during the construction phase. However,
precautions and measures to prevent environmental problems are preferred to
structural control that either reduces or controls impacts.
Large construction projects that involve extensive land disturbance and removing of
vegetation and reshaping topography will spawn land disturbance that need t be
controlled. Measures to address the impact of land disturbance on the
environmental should be included in the planning and design phase of the
construction project before land is cleared.
4.4.5.1 Identifying need for operational control
Operational controls are one of the means through which the EMS can control the
SEA’s. (The other is setting the objectives and targets and the Environmental
Programmes).
Control needs of identified impacts such as erosion has to be preventative rather

than treatment. An example of control is keeping land clearance to a minimum.
Control of activities that generate noise and vibration include fitting and maintaining
appropriate mufflers on earth moving vehicles and or enclosing the equipment or
provide noise attenuation screen. Other control needs are on the generation of air
emission and dust, emergency situations and waste generations.
32
EMS GUIDANCE MANUAL
Why operational controls are necessary
a) Manage identified significant environmental aspects;

b) Ensure compliance with legal requirements and other requirements
to which the organisation subscribes;
c) Achieve objectives and targets and ensure consistency wit hits
environmental policy, including the commitment to prevention and
continual improvement; and
When identifying needs for operational controls, an organisation should

consider all of its operations, including those related to management
functions such as purchasing, sales, marketing, maintenance,
laboratory analysis and product storage; and external processes such
as delivery of products and services.
An organisation should also consider how contractors or suppliers might
affect its ability to manage environmental aspects, achieve objectives
and targets, and otherwise comply with applicable legal requirements
and other requirements to which the organisation subscribes. An
organisation should establish operational controls that are needed,
4.4.5.2 Development of operational control
Operational controls can take various forms, such as procedures, work instructions,
physical controls, use of trained personnel or any combination of these. The choice
of the specific control methods depends on a number of factors, such as the skills
and experience of people carrying out the operation and the complexity and
environmental significance of the operation itself.
There are several strategies that can be employed to control construction activities
and reduce impacts. As an example, working in sequential and smaller sections of
the project site at any one time. If rehabilitation is commenced immediately after
works have been completed, the impacts of erosion, contaminated run off and dust
is reduced. Keeping haul roads to a minimum and routing them to avoid erodible
areas such as sloping terrain will also control dust and erosion problems. It is
33
EMS GUIDANCE MANUAL
important to have accurate information about on site drainage for each micro
catchment so that control device are adequately designed for expected flow and
load. Specifications for diversion drains and temporary stormwater controls to
redcue on site volumes should be included in the plan.
Plans should identify the position and design specification of structures taken to
control :
a) sediment run off
b) dirt on roads
c) noise and vibration
d) dust
A common approach to establishing operational controls includes:
a) Choosing a method of control;

b) Selecting acceptable operating criteria;
c) Establishing procedures, as needed, that define how identified
operations are to be planned, carried out and controlled; and
d) Documenting these procedures, as needed, in the form of
instructions, signs, forms, videos, photos, etc.
In addition to procedures, work instructions, and other control

mechanisms, operational controls can include provisions for
measurement and evaluation and for determining whether operating
criteria are being met.
An organisation may choose to establish procedures to enhance its

ability to implement controls in a consistent manner. Operational
controls should be addressed in training those persons involved in
4.4.5.3 List of operational control procedures
Prepare list of operational control procedures. Follow these steps:
a)Identify operations and other activities that are related to SEA’s and/or legal
requirements;
34
EMS GUIDANCE MANUAL
b)Define controls implemented at each operation or activity;
c)Draft the instructions and review them with people who are responsible for
their implementation to ensure these instructions are appropriate, realistic and
practical.
Other control measures that can be developed include:

a) Increase inspection and surveillance and monitoring frequency so that new or
underestimated impacts are quickly identified and managed
b) implement a preventative maintenance program for pollution control
installations to reduce impacts from equipment failure
c) Implement contingency plans such as ensuring that corrective actions on a
failing control measure is prompt. Such a contingency plan will reduce the
environmental impact of a hazard.
d) When work I is done near an environmental sensitive area, then special
precautions should be identified in the control plan
Activities that might

require operational controls:
 Land clearing
 Management of biomass
 Storage & handling of
chemicals and construction
wastes
 Piling
 Wastewater treatment
 Earthworks
 Movement of heavy vehicles
35
EMS GUIDANCE MANUAL
How to develop environmental procedures
•Review the environmental aspects and potentially significant impacts which have
been identified earlier.
•Identify operations and other activities that are related to Significant Environmental
Aspects
•Develop procedures for controlling each operation / activity, keeping it simple. Use
flow charts whenever possible.
•Draft the instructions and review them with the people who are responsible for their
implementation to ensure these instructions are appropriate, realistic and practical
Hints on Writing Procedure

Understand the existing process. Start with a Factors that could affect
flow chart. Build on informal procedures the need for documented
where possible. procedures
Focus on steps needed for consistent
complementation.
Use a consistent format and approach.
risk of activity
Review draft procedures with employees that complexity of activity or
will have to implement them. (Better yet, method
enlist employees to help write them.) degree of supervision
Keep procedures simple and concise. skills/training of
Excessive detail does not provide better workforce
control and can confuse the user.
Remember to consider maintenance and calibration of equipment as these

tasks might also have a significant impact.
Operational Control Section meets the intent of ISO 14001:
36
EMS GUIDANCE MANUAL
• Have you identified operations and activities associated with significant

environmental aspects, legal requirements and environmental objectives? If
not how will these be accomplished? Who should be involved?
• What operations and activities are associated with significant environmental
aspects?
• What operations and activities are associated with legal requirements?
• What operations and activities are associated with environmental objectives
and targets?
• How are the above operations and activities controlled? (list methods)
• How do you know whether these controls are adequate i.e., to manage
significant aspects, to ensure compliance, to achieve objectives, carried out
under specific conditions?
• How do you train employees and contractors on relevant operating controls?
• If new controls are needed (or existing ones need to be revised), what is your
process for doing so? Who needs to be involved in this process?
4.4.6 Emergency Preparedness
Sufficient personnel awareness on emergency preparedness should be maintained.

To respond to emergency situations – in order to mitigate, reduce and/or eliminate
the environmental health and safety impacts – emergency preparation and
procedures should be implemented.
This element requires the organization to establish and maintain procedures to:
• identify potential for and respond to accidents and emergency situations
• prevent and mitigate these situations and the environmental impacts that may
be associated with them with emergency plans/procedures
37
EMS GUIDANCE MANUAL
• review and revise these procedures where necessary, particularly after the
occurrence of accidents or emergency situations. This will determine if more
training is needed or if the emergency plans / procedures should be revised.
An organisation should establish, implement and maintain (a)

procedures(s) detailing how to identify potential emergency and
potential accidents that can have an adverse environmental impact(s),
and the appropriate mitigation and response actions if such situations
occur. The procedure(s) and associated controls should include, where
4.4.6.1 Potential emergency situation and potential accident in construction sector

A procedure should be established and maintained to identify potential emergency
situations, and to respond to such situations.
Examples of Potential Emergency Situations:

Fire/Explosion
Rainstorms or other unexpected weather conditions
Major chemical spillage or leakage
Accidents as a result of equipment failure
Slope failure
Flash floods
Landslides
4.4.6.2 Development of relevant emergency preparedness and response

procedures
An organisation should establish (an) emergency preparedness and response
procedure(s) that suits its own particular needs.
38
EMS GUIDANCE MANUAL
In establishing its procedure(s), the organisation should include

consideration of:
a)The nature of on-site hazards (e.g. flammable liquid, storage
tanks, compressed gases and measures to be taken in the event of
spillages or accidental releases);
b)The most likely type and scale of an emergency situation or
accident;
c)The potential for (an) emergency situation(s) or accident(s) at a
nearby facility (e.g. plant, road, railway line);
d)The most appropriate method(s) for responding to an accident or
emergency situation;
e)The actions required to minimise environmental damage;
f)Training of emergency response personnel;
g)Emergency organisation and responsibilities;
h)Evacuation routes and assembly points;
i)A list of key personnel and aid agencies, including contact details
(e.g. fire department, spillage clean-up services);
j)The possibility of mutual assistance from neighbouring
organisations;
k)Internal and external communication plans;
l)Mitigation and response action(s); to be taken for different types
of accident(s) or emergency situation(s);
m)Need for process(es) for a post-accident evaluation to establish
and implement corrective and preventive actions;
n)Periodic testing of emergency response procedure(s);
39
EMS GUIDANCE MANUAL
These procedures need to be tested out for practicality, suitability, effectiveness and
efficiency. Below are information typically found in an Emergency Response Plan:
General Information
• Overview of operations and potential emergency scenarios

• List of applicable regulations
• Maintenance and distribution of plan
• Designated employees (i.e., names and phone numbers of persons authorized to
act as emergency coordinators)
Emergency Notification Information/Procedures
• Information or procedures to effectively notify persons listed in the plan, including

facility coordinators and community emergency employees
• Emergency hotline numbers
•List of names and numbers of regulatory agency or other governmental contacts
Reportable Information
• Name and telephone number of person reporting incident

• Name and address of facility
• Time and place of incident
• Name and quantity of material involved
• Extent of injuries
• Possible hazards to human health and/or the environment
• Potential impact outside the facility
• Occurrence of or need for evacuation of local areas
Available Resources Listings
• Spill equipment list, with locations identified

• List of nearby medical facilities, with addresses and phone numbers
• List of nearby fire stations, with addresses and phone numbers
• Poison control center phone number
Emergency-Specific Information/Procedures
• Weather emergencies
• Utility emergencies
• Fire and explosion emergencies
• Chemical release emergencies
Evacuation procedures
Site Map
40
EMS GUIDANCE MANUAL
• Identification of evacuation routes

• Identification of safety showers and eye-wash stations
• Identification of fire extinguishers
• Identification of chemical-spill supply carts
Training and Awareness
• Legal/regulatory training requirements

• List of employees who require training
• List of qualified training instructors
Checklist for Emergency Preparedness and Response Plans
Does your plan describe the following:

♦ potential emergency situations (such as fires, explosions, spills or releases
of hazardous materials, and natural disasters)?
♦ hazardous materials used on-site (and their locations)?
♦ key organizational responsibilities (including emergency coordinator)?
♦ arrangements with local emergency support providers?
♦ emergency response procedures, including emergency communication
procedures?
♦ locations and types of emergency response equipment?
♦ maintenance of emergency response equipment?
♦ training / testing of employees, including the on-site emergency response
team (if
applicable)?
♦ testing of alarm / public address systems?
How to Develop Emergency Procedures
• Identify emergency procedures already developed and implemented. Start with

the environmental and health and safety regulatory programs.
• Identify whether any emergency or accident scenarios with major environmental
impacts have not yet been covered. Most potential emergencies can be identified
by asking a series of “what if” questions related to hazardous materials, activities,
and processes employed at the site. Consider start-up and shutdown of
equipment, and other abnormal operating conditions.
41
EMS GUIDANCE MANUAL
• Develop and implement emergency procedures for these scenarios.

Communicate these procedures with all the employees on site and also local
officials (fire department, police, hospitals etc.) to determine how they can offer
assistance and support.
• Ensure that training needs and competencies have been assessed for those
working for, or on behalf of the organization involved with emergency procedures.
• Establish processes to check that emergency preparations are implemented and
maintained (e.g. test drills).Post copies of evacuation plans around the site and at
potentially high risk areas. Include numbers for your on-site emergency
coordinator, local fire department, local police, hospital, rescue squad, and others
as appropriate.
• Develop a process for identifying requirements for emergency procedures for
existing or new operations or areas.
• Develop a process for recording, reporting and investigating incidents and near
misses, to assist in reducing future risks.
Planning for emergencies should include:

- an emergency assessment process
- preventive measures
- organizational responsibilities
- listing of key employees
- defining emergency services & their capabilities
- communication plans
- actions to take in the event of emergencies
42
EMS GUIDANCE MANUAL
Emergency Preparedness & Response Section meets the intent of ISO 14001:
• Have you reviewed your operations and activities for potential emergency
situations? If not how will these be accomplished? Who should be involved?
• Do your existing emergency plans describe how you will prevent incidents and
associated environmental impacts? If not how will these be accomplished?
Who should be involved?
• Have you trained employees on their roles and responsibilities during
emergencies?
• What emergency equipment do you maintain? How do you know that this
equipment is adequate for your needs?
• How do contractors and other visitors know what to do in an emergency
situation?
• When was your last emergency drill? Is there a plan/schedule for conducting
future drills?
• Have you established a feedback loop so you can learn from your
experiences?
43
EMS GUIDANCE MANUAL
4.5 CHECKING AND CORRECTIVE ACTIONS
Key characteristics of EMS operations and activities should be monitored and

measured on a regular basis. The results should be recorded together with non-
conformances, and with the corrective and preventive actions.
As part of the checking process, a periodic EMS audit should be carried out; its
result should serve as a basis for management review.
Checking is the series of processes used to measure and monitor the effectiveness
of environmental policy, objectives, targets, legal and other requirements, and report
the results to interested parties.
Checking involves measurement, monitoring and evaluation of an

organisation’s environmental performance. Preventive action should be
used to identify and prevent possible problems before they occur. A
corrective action consists of identifying and correcting problems in the
environmental management system.
4.5.1 Monitoring and measurement

measured on a regular basis. Procedures should be established and maintained to
track performance, relevant operational controls, and conformance with the
organisation’s environmental objectives and targets, as well as for the calibration and
maintenance of monitoring equipment.
Measuring and monitoring is required to ensure that the EMS objectives and targets
are being achieved.
Monitoring of environmental parameters are essential to ensure compliance to the

regulation as well as maintaining the effectiveness of mitifating measures taken up.
Ther following are some examples of the issues that need to be monitored taken
from an EMP of a road construction:
44
EMS GUIDANCE MANUAL
i. Water quality ( all affected rivers - 10 m upstream and downstream; ). Monitor the
quality of water at all river crossings prior to construction to determine the baseline water
quality and subsequently monitor the water quality by taking and analysing water
samples for the following parameters: Dissolved oxygen, electrical conductivity,
temperature, pH, biological oxygen demand, chemical oxygen demand, ammonia ( NH3-
N), nitrate NO3-N, PO4-P, oil and grease, turbidity, total suspended solids, total dissolved
solids, total solids). For subsequent sampling parameters : pH, temperature, DO, BOD,
COD, TSS, AN, and oil and grease
ii. Air quality (dust, air particulate at residential areas and at project site boundaries)
iii. Noise (residential areas and forest reserves and at project site boundaries)
iv. Erosion risks ( erosion sensitive areas; temporary cover to control erosion and
permanent erosion control – drainage, surface protection, gabions, rip rap)
v. Slope stability /protection ( erosion sensitive areas; immediate revegetation, protect
slope from concentrated surface runoff, hard plugs)
vi. Solid and hazardous waste handling and disposal
vii. Archaeological heritage sites
viii. Waterway crossings ( waterways must not be hindered; crossings shall be adequate
to permit heavy storm water flow, embankments stability/protection)
ix. River bank protection ( riprap, gabion)
x. Flora and fauna
xi. Health and safety
xii. Sediment/silt trap ( location, trap size, embankment, excavation, trap clean out, outlet,
clearing, fill material, sedimentation, Inspection after each rain and repairs, construction
operations to minimize water pollution)
xiii. Conservation of agricultural land - protected from any deterioration and impact ( every
month)
xiv. Hydrology –drainage system- maintenance, drainage channels, flumes ( pipes to
channel water across the right of way, berms and berm spacing and conditions)
xv. Compliance with government regulations - permits
45
EMS GUIDANCE MANUAL
Monitoring and measurements can serve many purposes in an

environmental management system, such as:
a) Tracking progress on meeting policy, achieving objectives and

target, and continual improvement;
b) Developing information to identify significant environmental
aspects;
c) Monitoring emissions and discharges to meet applicable legal
requirements or other requirements to which the organisation
subscribes;
d) Monitoring consumption of water , energy or raw materials to meet
objectives and targets;
e) Providing data to support or evaluate operational controls;
f) Providing data to evaluate the organisation’s environmental
performance; and\
g) Providing data to evaluate the performance of the environmental
management system.
• evaluate environmental performance;
• analyze root causes of problems;
The contractor should develop procedures to:

♦monitor key characteristics of operations and activities that can have significant
environmental impacts and/or compliance consequences;
♦track performance (including your progress in achieving objectives and targets);
♦calibrate and maintain monitoring equipment;
♦through internal audits, periodically evaluate your compliance with applicable
laws and regulations.
46
EMS GUIDANCE MANUAL
How to achieve the above

To achieve these purposes, the contractor should plan what will be
measured, where and when it should be measured, and what methods
should be used. To focus resources on the most important
measurements, the organisation should identify the key characteristics
of processes and activities that can be measured and that provide the
En example of a summary of monitoring requirements for a road construction
Environmental Person Parameters Frequency

issue responsible
Air quality and Environmental TSP Construction
noise officer phase: once a
week during land
clearing and
earthworks
Once a fortnight
during other
construction works
Operational phase:
none required:
Solid particles – all Construction

fuel burning phase: Standard C:
equipment and 0.4 g/Nm3
asphalt plant
Noise – border of Construction

construction area phase: once a
fortnight
Soil erosion Project Engineer Sedimentation Construction

rates – silt traps phase: twice a
week during land
clearing and
earthworks. Once
a fortnight during
other construction
works.
Operational phase:
none required.
Slope stability Construction
47
EMS GUIDANCE MANUAL
phase: once a
week Operational
phase: Once a
fortnight.
Water quality Environmental Identified Construction

officer locations phase: Twice a
week during land
clearing and
As per EQA earthworks
between month 1-
20. Once a week
during month 21 –
30
Operational phase:
once fortnight
Construction
phases: BOD,
E.coli at sewage
discharge.
All parameters to
comply with Std A
continuously
throughout
construction and
operational phases.
Wildlife Department of No of locations – Construction

Wildlife every kilometer: phase: once a
Physical surveys week during land
and observations. clearing and
earthworks to
Ground mammals. detect and relocate
displaced animals.
Post construction
phase: patrol area
once a month.
Solid waste Environmental Base camp and Construction

officer along kilometer phase: once a
stretch of the week.
construction site. Post construction
phase: once a
month.
48
EMS GUIDANCE MANUAL
How to conduct measurement

Measurements should be conducted under controlled conditions with
appropriate processes for assuring the validity of results, such as
adequate calibration or verification of monitoring and measurement
equipment, use of qualified personnel, and use of suitable quality
control methods.
When necessary to ensure valid results, measuring equipment should
be calibrated or verified at specific intervals, or prior to use, against
standards traceable to international or national measurement
standards. If no such standards exist, the basis used for calibration
should be recorded. Written procedures for conducting measurement
and monitoring can help to provide consistency in measurements and
Example of measurement methodology and instrument for water quality analysis:
Index Method or Instrument

1. Bio-Chemical Oxygen Demand (BOD) Standard method
2. Chemical Oxygen Demand (COD) Spectrophotometer (HACH) DR/2010
3. Dissolved Oxygen (DO) DO meter
Before sampling for chemical analysis, sample bottles were cleaned by soaking in detergent
for 24 hour followed by rinsing several times with tap water until free of detergent, rinsed
with 5% nitric acid and then thoroughly with distilled-demonized water.
4.5.1.1 Identifying activities, product and services
49
EMS GUIDANCE MANUAL
Waste
Wastewater Generation Groundwater
Discharges Impacts
Water Air
Use Emissions
Monitoring and
Measurement
Chemical Corrective
Use Action
Energy Recycling
Use Unplanned Activities
Releases
Examples of activities to include in a monitoring and measurement program.
4.5.1.2 Development of appropriate monitoring and measurement mechanism
Attributes of effective
measurement programs
 simple
 flexible
 consistent
 ongoing
 produce reliable data
 communicate results
Monitoring emphasis on:
50
EMS GUIDANCE MANUAL
a. Soil erosion risks: Estimate of potential soil erosion and soil loss to
receiving waters.
b. Flood risks: Estimates of flood flows and indication of areas subject to

floods.
c. Water pollution: Predict changes to water quality.
d. Air pollution: Estimates of air pollution generation and predict changes

to air quality.
e. Noise Pollution: Traffic noise along selected positions based on

projected traffic increase. Machinery noise projection if types of
activities are known in the road construction.
f. Ecological Impacts: Habitat loss and possible effects on species of

fauna and flora.
g. Roads and Traffics impacts: Projected traffic generation and

distribution, safety and congestion.
h. Socio economics impacts: Size of population affected and issues that

may rise.
Key Methods to track performance and operational control
51
EMS GUIDANCE MANUAL
Characteristics
Air Emissions Periodic sampling; emissions trending; measurement of exhaust

rates; frequent calibration of monitoring equipment; balancing of
duct flows
Treatment Emissions trending; comparison to or use of documented
efficiencies efficiency factors; waste generation from process(es); frequent
calibration of monitoring equipment
Recycling Percentage of waste recycled; comparison of revenue generated
activities and cost avoided
Unplanned Trend of unplanned releases, trend of severity of unplanned
releases releases; cost or potential costs of cleanup versus
Energy use Tracking of energy usage; cost of installing energy-efficient
equipment; ensure energy conservation measures are deployed
Chemical Use Chemical use trend; review of purchasing records to determine
what areas are using most chemicals; reduction of targeted
chemicals such as toxic or hazardous chemicals
Water use Water use trend; cost of water conservation equipment versus
savings over time; ensure water conservation measures are
deployed
Wastewater Effluent sampling to ensure permit parameters are being met;
discharges emissions trending; frequent calibration of monitoring equipment
Waste Waste generation trend; disposal and treatment costs; number of
generation incorrectly shipped waste drums or packages, including errors in
shipping papers
Storm water Effluent sampling to ensure permit parameters are being met;
discharges emissions trending; visual inspection runoff; frequent calibration
of monitoring equipment
How to Develop Monitoring Procedures
•Identify your needs. Define what kind of information is meaningful and should be
collected. For instance :
 key process characteristics
 regulatory compliance
 operational performance (effectiveness of operational controls of Significant
Environmental Aspects)
 progress on meeting objectives
52
EMS GUIDANCE MANUAL
•Review existing monitoring systems. Determine if current systems are sufficient,

and identify any additional monitoring or measurement if needed.
•Develop measurement programs. Ensure your programs are simple, flexible,
consistent and ongoing, produce reliable data and communicate results.
•Monitoring and Checking. Establish environmental management plan. Identify time,
place and persons performing the measurements. Carry out monitoring to ensure
legal compliance, achievement of
objectives and effective operational Which operations and activities can have
significant environmental impacts?
control. Implement corrective and
preventive actions when non-
conformances are identified during
What are the key characteristics of these
monitoring or operation. Procedures
operations and activities?
for calibration and routine maintenance
of equipment utilized should be
documented.
•Communicating performance. Provide How do we
measure
relevant monitoring results to staff will these
raise their awareness on your
company’s environmental
performance.
TIPS
♦Keep monitoring requirements limited to KEY process characteristics.
♦Make sure equipment is maintained and calibrated routinely.
♦Ensure that regulatory compliance is included in the measuring and monitoring.
♦Ensure monitoring and measuring will verify conformance with policy, targets and
objectives of EMS.
♦Focus on things that can be controlled
♦Ensure adequate resources to implement the program
♦Monitoring and measurement reports must be applicable to operational staff and
meaningful for management
53
EMS GUIDANCE MANUAL
♦Consider economic studies to determine cost of effort versus economic return on

investment
Monitoring & Measurement Section meets the intent of ISO 14001:
• How do you identify operations and activities associated with significant

environmental aspects, legal requirements and environmental objectives?
• What type(s) of monitoring and measurement do you need to ensure that
operational controls are being implemented correctly?
• What type(s) of monitoring and measurement do you need to ensure that you
are complying with applicable legal requirements?
• What type(s) of monitoring and measurement do you need to ensure that you
are achieving your environmental objectives & targets?
• How do you identify the equipment used for any of the monitoring or
measurement listed above?
• How will you ensure that monitoring and measurement equipment is properly
calibrated and maintained?
• What process do you have to periodically evaluate compliance with legal
requirements? How effective is this process?
4.6 4.5.2 Evaluation of compliance
To meet compliance to applicable legal and other environmental requirements, its

status should be regularly monitored and evaluated.
An organisation should establish, implement and maintain a procedure for

periodically evaluating its compliance with the legal requirements and other
54
EMS GUIDANCE MANUAL
requirements that applicable to its environmental aspects, as part of its commitment

to compliance. The organisation should record the results of this evaluation.
The scope of a compliance evaluation can encompass multiple legal

requirements or a single requirement. A variety of methods can be used
to assess compliance, including processes such as:
e) Audits;
f) Document and/or records reviews;
g) Facility inspections;
h) Interviews;
i) Project or work reviews;
j) Routine sample analyses or test results; and
k) Facility tours and/or direct observations.
An organisation should establish a frequency and methodology for

evaluation of compliance that suits its size, type and complexity.
Frequency can be affected by factors such as past compliance
performance or specific legal requirements. It can be beneficial to have
an independent review conducted periodically.
4.5.2.1 Demonstration of compliance
Compliance can be demonstrated with respect to laws, regulations, guidelines and

other pertinent instructions.
An example of commitment to compliance for the construction of a marina:
The CONTRACTOR shall comply with all applicable laws, regulations, standards, guidelines
and terms and conditions of approvals issued by Malaysian Environmental Authorities. In
particular the CONTRACTOR shall comply with the Environmental Quality Act 1974(Act
127) and all subsidiary legislations made there under. The CONTRACTOR shall take
cognisance of all environmental issues and comply with all laws, by-laws, rules and
regulations relating to the environment. This shall include but not limited to avoiding
unnecessary felling or damaging of trees, restoration of the affected areas, proper discharge of
effluent, dust control, emission of noise, fumes and handling of waste, toxic or otherwise
including the construction of receptacles, incinerators, silt traps, filters and other appropriate
methods of disposal or discharge.
55
EMS GUIDANCE MANUAL
4.5.2.2 Evaluation of compliance to legal requirements
List of some examples of regulations that a contrcution project need to be aware

of:
The purpose of this list of regulations is to direct project initiator and assessors to existing
regulations issued under the EQA 1974 and other related legislation in Malaysia.
There is a list of regulations made under ENVIRONMENTAL QUALITY ACT 1974 and
other environmental related legislation.
i. The Environmental Quality Act 1974 Laws of Malaysia, His Majesty’s gazette 14th
March 1974
ii. Destruction of Disease bearing insects Act, 1975.Act 1564 Laws of Malaysia
iii. Land Conservation Act 196- (No 3. of 1060)
iv. Local Government Act 1976 Act 171/76, Laws of Malaysia
v. National Land Code 1965
vi. Municipal and Town Boards (Amendment) Act 1972)
vii. The Waters Enactment 1929
viii. Drainage Works Ordinance 1954
ix. Fisheries Act 1963
x. Factories and Machinery Act 1967
xi. The Road Ordinance Traffic 1958
xii. Poisons Ordinance 1952
xiii. Explosives Ordinance 1957
xiv. Malaria Eradication Act 52 laws of Malaysia
xv. Street, Drainage and Building Act 1974 (Act 133)
xvi. Occupational, Safety and Health Act 1994 ( Act 514) and regulations Safety and Health
Officer regulations 1997 and Order 1997
56
EMS GUIDANCE MANUAL
Elements That Might Be Reviewed When Performing a legal Compliance

Evaluation
• Environmental permit limits and corresponding data demonstrating
compliance with these limits
• Procedures identifying training requirements that are based on
legislation/regulation and evidence that the training has taken place
• reporting requirements and evidence that the proper reports have been
submitted
• inspection requirements and evidence that the inspections have taken
place
• labeling requirements and evidence that proper labeling is being
executed
• records retention requirements and evidence that the records are
maintained according to legal specification
• waste-handling requirements and evidence that these requirements are
being met
• corrective action requirements and evidence that the corrective action is
being managed properly
4.5.2.3 Evaluation of compliance to other requirements
An organisation should periodically evaluate its compliance with other

requirements to which it subscribes. An organisation may wish to
establish a separate process for conducting such evaluations or it may
choose to combine these evaluations with its evaluations of compliance
with legal requirements, its management review process or other
evaluation processes. Records of these periodic evaluations should be
maintained.
A compliance evaluation programme can be integrated with other
assessments activities. These can include management system audits,
57
EMS GUIDANCE MANUAL
4.7 4.5.3 Non-conformity, corrective action and preventive action

conformances, and the corrective and preventive actions. As part of the checking
process, a periodic EMS audit should be carried out; its result should serve as a
basis for management review.
The result of monitoring and measurements, evaluation of compliance, audit findings

and other systematic reviews should be documented and reviewed, and must lead to
corrective actins which are intended to fix and avoid EMS problems in the future.
Examples of non conformity:
a) exceeding noise level and vibration level
b) emission of excessive fumes and dust
c) soil erosion and surface runoffs that cause heavy siltation of the water bodies,
thus increase in water turbidity and shallowing of the water bodies
d) mismanagement of handling and disposal of chemical hazardous waste
e) do not comply to EIA approval conditions such as no open burning,

requirements of monitoring and development of EMP
f) solid waste mismanagement
58
EMS GUIDANCE MANUAL
Non-conformity is non-fulfilment of a requirement. A requirement may be

stated in relation to the management system or in terms of environmental
performance. Situations may occur where part of the system may not
function as intended or environmental performance requirements are not
met.
A process for identifying non-conformity in the environmental system

and taking corrective or preventive action helps an organisation operate
and maintain the environmental management system as it intends.
Keeping records and managing them effectively gives the organisation a
reliable source of information on the operation and results of the
environmental management system. Periodic audits of the
environmental management system help the organisation verify that
the system is designed and operating according to plan. All of these
For an environmental management system to be effective on an on-

going basis, an organisation should have a systematic method for
identifying actual and potential non-conformity (-ies), making
corrections and taking corrective and preventive action, preferably
Examples of such situations can include:
a) System performance:
i. Failure to establish environmental objectives and targets;

ii. Failure to define responsibilities required by an environmental
management system, such as responsibilities for achieving
objectives and targets or for emergency preparedness and
response; and
iii.Failure to periodically evaluate compliance with legal
requirements;
b) Environmental performance:
i. Energy reduction targets are not achieved;

ii. Maintenance requirements are not performed as scheduled; and
iii.Operating criteria (e.g. permitted limits) are not met.
59
EMS GUIDANCE MANUAL
4.5.3.1 Non-conformity, corrective actions and preventive actions
Any non conformity must be recorded and corrective actions taken. Excessive
exposure of soil that leads to soil erosion and surface runoffs can be abated by
having immediate turfing. Prevention of surface runoff laden with silt from entering
the water courses can be achieved by improving the silt ponds. Prevention of
impacts and risks are worth considering in the planning stage rather than having to
pursue treatment measures.
Preventive measures on air quality degradation begins with recognizing the main
sources of emission which are exhaust gases from machinery and heavy vehicles,
followed by implementation of measures such as fitting vehicles and machinery with
appropriate emission control and proper maintenance. Storage of chemicals and
fuels on site is inevitable, however, reducing the quantities of these hazardous
substances on site to a minimum practicable level is desirable.
Management should ensure that corrective actins have been

implemented, and that there is systematic follow-up to ensure their
effectiveness.
If potential problem is identified but no actual non-conformity exists,
preventive action should be taken using a similar approach.
Establishing procedures for addressing actual and potential non-

conformities and for tracking corrective and preventive actions helps to
ensure consistency in this process. Such procedures should define
responsibilities, authority and steps to be taken in planning and carrying
out corrective and preventive actions. When the actions taken result in
changes to the environmental management system, the process should
ensure: that all related documentation, training and records are updated
60
EMS GUIDANCE MANUAL
4.5.3.2 Evaluating actual non-conformity to corrective actions
Once non-conformity is identified, it should be investigated to determine the cause,

so that corrective actions can be focused on the appropriate part of the system. In
developing a plan for addressing non-conformity, an organisation should consider
what actions need to be taken to address (mitigate) the problems, what changes
need to be made to correct the situation (to restore normal operations(s)). The
character and timing of such actions should be appropriate to the nature and scale of
the non-conformity and the environmental impacts.
Non conformity can be checked against compliance list or regulations. An example

taken from the construction of a dam for water quality is given below:
The Department of Environment Compliance Checklist includes the followings

1. Any wastewater must be treated before releasing into the inland waters and
must meet the Standard A, Third schedule Environmental quality
Regulations (Sewage and Industrial effluent) 1979.
2. Silt trap and proper drainage system that is effective in draining the surface
runoff must be built before any earthwork is carried out. Any water released
from the silt trap cannot exceed 50 mg/L.
3. A report on the total suspended solids must be submitted to the state DOE as
well as the Federal DOE.
4. The design of the silt trap
5. Spent oil cannot be allowed to be disposed into any river. Used oil will be
kept in covered drums for recovery or disposed at an approved site.
Non conformity was also judged from site surveillance carried out for visual
evaluation of river conditions, identify probable source of siltation of rivers, and
evaluate implementation of mitigating measures including steps to reduce
surface runoffs as well as the silt pond conditions.
61
EMS GUIDANCE MANUAL
Aside from site surveillance, monthly monitoring were carried out to ascertain
non-compliance so that immediate remedial actions can be taken.
Corrective and preventive measures for water quality during dam construction:
a) Frequent and regular monitoring of the dam’s water quality is recommended

especially during raining season.
b) One of the goals for water quality management in the reservoir is to maintain
a water quality that is suitable for survival of aquatic fish and which will not
lead to eutrophication. To retard the eutrophication sharply, it will be
necessary to impose effective controls on land runoff the contain phosphate
and nitrate as well as point sources.
c) To reduce the levels of total suspended solids in the dam, which in turn will
reduce the siltation of the dam and subsequently reduces its water carrying
capacity. The controls for suspended solids in the dam area, largely
dependent on the measures established for soil erosion control as well as
rehabilitation of the surrounding forests.
d) Frequent and regular monitoring of the dam’s water quality is recommended to

ensure that water quality problems which do not arise can be detected early
and appropriate intervention measures are taken before the problem reached
unmanageable stage.
62
EMS GUIDANCE MANUAL
Example of the evaluation of non conformity to EIA approval conditions for the
construction of a marina as gathered from site surveillance and auditing
63
Mitigating Measures
Impact Suggested Mitigating Measures
Taken by contractor
Noise Pollution
- Noise levels shall not exceed 65
EMS GUIDANCE
dB (A) atMANUAL
all times around the
Managing Your Environmental Responsibilities - No preventative measure was
boundaries of the project area. undertaken.
- If noise level is high, the general
workers at the site must be
provided with ear mufflers to
reduce impacts on them.
- Reduce noise level by decreasing
operating level during quiescent
periods in the local community.
- The equipment used or the modes
of operation can be changed to
produce less noise, such as fitting
with silencers.
- Construction hours must be limited
to the day to avoid disturbance to
the residents nearby.
Solid Waste Generation - The wastes must be separated
into categories for easy disposal - Construction wastes generated
o segregation of wastes were disposed at the
( recyclable from no designated dumpsite.
recyclable)
o segregation of hazardous
from non hazardous
wastes.
- The wastes are loaded onto tip off
truck, should not be overfilled and
must be covered with tarpaulin
material so that no accidental fly
rock or fly debris might take place
while transporting.
- No open burning is allowed
- No disposal into the sea is
permitted. Any accidental falling of
solid wastes into the water must
be immediately retrieved.
- Construction wastes which are too
large or heavy are placed
temporarily in an area big enough
to accommodate them without
interfering with internal traffic or
cause hazards to workers
- For smaller wastes, a proper
waste storage containers and
drums must be provided.
- Storage and collection of solid
wastes must be done in a way that
will not cause fire, health or safety
hazards or provide food and
breeding grounds 64 for vectors of
diseases
Schedule Waste - Disposal of hazardous waste using
EMS GUIDANCE MANUAL
4.5.3.3 Evaluating potential non-conformity of preventive actions
The internal audit process of an environmental management system, described in

4.5.5, is one way of periodically identifying non-conformities. Identification of non-
conformities can also be made a part of routine responsibilities, with individuals
closest to the work noting potential or actual problems.
Potential problem can be identified using methods such as corrective

action of actual non-conformities to other applicable areas where similar
activities occur, trend analyses, or hazard operability studies.
Why do EMS problems

occur?
Typical causes include:
 poor
communication
faulty or missing
procedures
equipment
malfunction
(or lack of
maintenance)
lack or training
lack of understanding
(of requirements)
failure to enforce rules
corrective actions fail
to address root causes
Examples of potential problems identifed for the dam constrcution
Drainage
Landslides can occur due to poor drainage of slopes. Careful examination of existing drainage lines
and potential change of drainage routes to sloping areas should be made. Such drainage may
appear on the surface or may go underground and reappear as seepage water that may cause
damage to slopes.
Operational phase
There are two primary erosion management tasks in the operational phase. One is slope stability
monitoring and the other is the rehabilitation of scarred land to a semblance of its original form. The
65
EMS GUIDANCE MANUAL
effort at this stage will depend entirely on how effectively erosion control measures were applied
during the construction phase.
However, for slope stability, continuous monitoring of all slopes that face into the reservoir is
encouraged. Critical slope areas should be revisited every 2 weeks while the other slopes can be
inspected once a month. The frequency needs to increase to once a week during the rainy season for
vulnerable slopes.
The frequent wetting and drying of the slopes around the waterline can weaken the natural cohesively
of the soil causing the slope to slump. Slopes where the top soil integrity has been compromised by
logging or land clearing are of particular concern.
To deal with system deficiencies, the contractor needs a process to ensure that:
• problems (including nonconformities) are identified and investigated;
• root causes are identified;
• corrective and preventive actions are identified and implemented;
• actions are tracked and their effectiveness is verified.
This procedure applies to the handling of:

a) enquiries (both internal and external) regarding contractor’s EMS or
environmental performance;
b) complaints (both internal and external) regarding contractor’s EMS or
environmental performance;
c) non-conformances related to contractor EMS requirements, shall include but not
be limited to below :
• internal procedure non-compliance identified during regular monitoring /
review
• non-conformances identified in internal EMS audits
• non-conformances caused by suppliers / contractors / service providers
Nonconformities should be analyzed to detect or identify trends, which can be used

to further anticipate and prevent future reoccurrences. Preventing problems are
usually cheaper than fixing them after they occur. This procedure also addresses
non-conformance through corrective and preventive actions so as to minimize
impacts to the environment and the potential for reoccurrence.
66
EMS GUIDANCE MANUAL
How to develop corrective & preventive measures
•Identify the problem

•Determine the root cause of the problem.
•Identify possible solutions and decide the best action to be taken.
•Implement the solution to lower risks to acceptable levels and to further prevent
reoccurrences.
•Document the measures taken to correct the nonconformance.
•Communicate the nonconformance and the corrective and preventive measures
taken to other employees to increase environmental awareness.
•Review non-conformances and agreed corrective/preventative actions for
completion against target timescales and also for effectiveness.
67
EMS GUIDANCE MANUAL
Rule of thumb:
Corrective actions should
(1) resolve the immediate problem
(2) consider whether the same or similar problems exist
elsewhere in the organization, and
(3) prevent the problem from recurring.
(4) define the responsibilities and schedules
TIPS
♦Combine some elements of their management review and corrective action
processes.
♦Planning and documentation vary with the severity of the problem and its potential
environmental impacts. Try to use simple methods.
♦Resolve the identified problem in a timely manner. Specify responsibilities and
schedules for completion and review the progress regularly.
♦In the long run, problems may be identified by people doing the work. This should
be encouraged. Develop ways to get employees involved in the system
improvement process.
Nonconformance and Corrective and Preventive Action Section meet the intent of
ISO 14001:
• Do you have an existing process for corrective and preventive action? If yes,
does that process need to be revised? In what way?
• Who needs to be involved in this process within your organization?
• How are nonconformities and other potential system deficiencies identified?
68
EMS GUIDANCE MANUAL
(List methods such as audits, employee suggestions, ongoing monitoring,

etc.)
• How do you determine the causes of nonconformities and other system
deficiencies? How is this information used?
• How do you track the status of our corrective and preventive actions?
• Can information on nonconformities and corrective actions be used within the
EMS (for example, in management review meetings, in employee training
sessions, in review of procedures, etc.)
• How do you ensure the effectiveness of your corrective and preventive
actions?
4.8 4.5.4 Control of records
Environmental records are required to demonstrate compliance with the EMS and
show that it is functioning properly. Key characteristics of EMS operations and
activities should be monitored and measured on a regular basis. The results should
be recorded together with non-conformances, and the corrective and preventive
actions.
Why records are needed

Records provide evidence of the on-going operation and results of the
environmental management system. A key characteristic of records is
that they are permanent and are, typically, not revised. An organisation
should determine which records are required to manage its
environmental matters effectively.
69
EMS GUIDANCE MANUAL
4.5.4.1 Identifying environmental records
Records are different from documents. Records are evidence that something has
been accomplished (i.e., inspections, equipment calibration and training). This
element requires the organization to establish and maintain procedures for the
identification, maintenance and disposition of records. Environmental records need
to be:
• legible
• identifiable and traceable to the activity involved
• easily retrievable
• can be in hard copy or electronically kept
• protected against damage, deterioration or loss
• retained per established and recorded retention times
• Identify what EMS records are required.

• Focus on records that add value. The records you choose to keep should be
accurate and complete.
• A master list of stored records that includes: name of record, why stored, where
stored, format of storage, retention time, and final disposal determination and
decision matrix. A record of those records destroyed, under whose authority and
the date of destruction should also be kept. Hard copy records need to be
protected from fire, flood and the like.
• Determine the person responsible for collecting and checking the records and
collection methods shall be specified.
70
EMS GUIDANCE MANUAL
What should be in the records

Records should include: (LIST OUT EG LICENSE, APPROVAL PERMITS, EIA
ETC)
a) Information on compliance with applicable legal requirements and

other requirements to which the organisation subscribes;
b) Details of non-conformities and preventive actions;
c) Results of environmental management system audits an
management reviews;
d) Information on environmental attributes (e.g. chemical composition
and properties);
e) Evidence of fulfilment of objectives/targets;
f) Information on participation in training;
g) Permits, licences or other forms of legal authorisation;
4.5.4.2 Management of environmental records
The effective control of these records is essential to the successful implementation of

an environmental management system. The key features of environmental record
control include means of identification, collection, indexing, filing, storage, retrieval
and retention.
71
EMS GUIDANCE MANUAL
Examples of Environmental Records

•Applicable governmental regulations
•List of significant environmental aspects
•Reports of progress towards meeting objectives and targets
•Environmental permits, licenses and other approvals
•Job descriptions and performance evaluations
•Training records
•Process hazard assessments
•Emissions modeling records
•External environmental reports
•Inspection, maintenance and calibration records
•Records of sub-contractor activities on premises
•Communications with customers, suppliers, contractors and
other external parties
•Incident and corrective action reports
•Records of testing of emergency procedures
•Sampling and monitoring data
•Records of compliance and EMS audit results
Records Section meets the intent of ISO 14001:
• Have you identified what records need to be maintained and disposed?

Where is this defined? Include training records, results of audits and reviews.
72
EMS GUIDANCE MANUAL
• Are the records legible, identifiable and traceable to the activities?

• Are the records maintained in a way that they are easily retrievable and
protected against damage, deterioration or loss?
• Have you determined records retention times? Where is this defined?
• Have you established an effective storage and retrieval system?
4.6 4.5.5 Internal audit

conformances, and the corrective and preventive actions. As part of the checking
process, a periodic EMS audit should be carried out; its result should serve as a
basis for management review.
Internal audit should determine compliance with the ISO 14001 EMS.
73
EMS GUIDANCE MANUAL
Why conduct internal audits ( auditors must be trained; audit planning,

frequency)
1. to determine and provide information to management on whether
the system conforms to planned arrangements and has been
properly implemented and maintained.
2. to identify opportunities for improvement in an organisation’s
environmental management system.
How to conduct internal audit environmental management system

1. at planned intervals
2. should establish an audit programme to direct the planning and
conduct of audits and to identify the audits needed to meet the
programme objectives.
3. audit programme should be based on the nature of an organisation’s
operations, in terms of its environmental aspects and potential
impacts, the results of past audits, and other relevant factors.
4. Each internal audit need not cover the entire system, so long as the
audit programme ensures that all organisational units and functions,
systems elements and the full scope of the environmental
management system are audited periodically.
5. The audits should be planned and conducted by an objective and
impartial auditor(s), aided by technical experts, where appropriate,
4.5.5.1 Determining internal audit objectives
Internal audits of an organisation’s environmental management system should be

conducted at planned intervals to determine and provide information to management
on whether the system conforms to planned arrangements and has been properly
implemented and maintained. They can also be performed to identify opportunities
for improvement in an organisation’s environmental management system.
4.5.5.2 Development of internal audit programme
74
EMS GUIDANCE MANUAL
An organisation should establish an audit programme to direct the planning and

conduct of audits and to identify the audits needed to meet the programme
objectives. The programme should be based on the nature of an organisation’s
operations, in terms of its environmental aspects and potential impacts, the results of
past audits, and other relevant factors.
Examples of suggested audit for the construction of a marina:
The types of audit that can be carried out include compliance audit, green audit or
specifically on the environmental management of the industry. Specific audit such
as on the marine water quality, maritime audit and solid waste management audits
can all be carried out.
Audit frequency will depend on the activity. The first year in operation is a starting
point and subsequently once in two years, unless there is a drastic deviation from
everyday operations.
This element requires the contractor to establish and maintain procedures and
programs for EMS auditing. The EMS audit program must cover the following:
• audit scope
• audit frequency
• audit methodology
• selecting and training of auditors
• responsibilities and requirements for conducting audits and reporting results
Scope
75
EMS GUIDANCE MANUAL
• Applicable to all types of environmental audits
Definitions
•Defines key terms pertaining to environmental auditing including audit

conclusion, audit criteria, audit evidence and audit findings
Requirements for an Environmental Audit
• There is sufficient and appropriate information about the subject matter of the
audit
• There are adequate resources to support the audit process
• There is adequate cooperation from the client (auditee)
General Principles
• Objectives and scope-the audit should be based on the objectives defined by

the client
• Objectivity, independence and competence-the members of the audit team
should be independent and should possess an appropriate combination of
knowledge, skills and experience to carry out the audit
•Due professional care-auditor should use care, diligence, skill and judgment
• Systematic procedures-documented and well-defined methodologies should be
used to enhance consistency and reliability
• Audit criteria, evidence and findings-criteria should be agreed upon between
the lead auditor and the client; appropriate information should be collected,
analyzed, interpreted and recorded; audit evidence should be of such quality
and quantity that competent environmental auditors working independently of
each other will reach similar audit findings
• Reliability of audit findings and conclusions-the desired level of confidence and
reliability in audit findings and conclusions should be provided
• Audit report-a copy should be given to the client and should include items
agreed upon by the client and the lead auditor
4.5.5.3 Selection and appointment of auditor
The audits should be planned and conducted by an objective and impartial

auditor(s), aided by technical experts, where appropriate, selected from within the
organisation or from external sources. Their collective competence should be
sufficient to meet the objectives and scope of the particular audit and provide
confidence as to the degree of reliability that can be placed on the results.
76
EMS GUIDANCE MANUAL
4.5.5.4 Implementation of internal audit
•Determine what should be audited to provide a comprehensive review of the

environmental management system (e.g. procedures, training, documents, and
records).
•Determine where these elements should be audited (e.g. by site, department, team,
individuals, activity, product or service).
•Determine when these elements are to be audited (frequency should be based on
environmental importance, the nature of your operations and activities, your
significant environmental aspects / impacts (which you identified earlier), the results
of your monitoring processes, and previous audit findings).
•Determine how all elements and areas will be audited (e.g. by procedure, by
department) considering the audit time requirement.
•Develop audit procedures and communicate these as necessary.
•Determine who will conduct the audits (e.g. internal or external auditors).CEMS
Auditors need to be selected and trained. Training requirements need to be identified
and are both initial and ongoing. Auditors should be trained in auditing techniques
and management system concepts. Familiarity with environmental regulations,
industry regulations and operations will be of tremendous help.
•From the above, compile an audit schedule and circulate as necessary.
•Conduct audits and report results. Audit results can be used to detect trends and
patterns in EMS deficiencies.
77
EMS GUIDANCE MANUAL
•Review results of audits and follow up corrective actions.
TIPS
♦Focus on objective evidence of conformance.
♦Review identified deficiencies with relevant employees
♦Train at least two people as internal auditors.
♦Before you starting, communicate audit scope, criteria, schedule, and other
pertinent information to the people in the affected area(s).
♦A EMS audit is not an assessment of how well employees do their jobs.
4.5.5.5 Internal audit finding and reporting
Each internal audit need not cover the entire system, so long as the audit
programme ensures that all organisational units and functions, systems elements
and the full scope of the environmental management system are audited periodically.
The results of an internal environmental management system audit can be provided

in the form of a report and used to correct or prevent specific non-conformities, fulfil
one or more objectives of the audit programme, and provide input to the conduct of
the management review.
EMS Audit Section meets the intent of ISO 14001:
• Have you developed a EMS audit program? If not, how will this be
accomplished? Who need to be involved in the audit process? What will the
audit cover?
• Is there another audit program with which your EMS audits could be linked
(for example, your quality or health & safety management system audits)?
78
EMS GUIDANCE MANUAL
• Have you determined an appropriate audit frequency? What is the basis for
the existing frequency? Should the frequency of audits be modified?
• Have you selected EMS auditors? What are the qualifications of our auditors?
• What training has been conducted or is planned for your EMS auditors?
• Have you conducted EMS audits as described in the audit program? Where
are the results of such audits described?
• How are the results of EMS audits communicated to top management?
• How are the records of these audits maintained?
79
4.6 MANAGEMENT REVIEW
Top management should periodically act, and review the EMS to ensure its
suitability, adequacy and effectiveness. The review should be an essential portion of
the continual improvement of the EMS.
An organisation should periodically review and continually improve its

environmental management system, with the objective of improving its
overall environmental performance.
4.6.1 Roles of top management
An organisation’s top management should, at intervals that it determines, conduct a

review of its environmental management system to evaluate the system’s continuing
suitability, adequacy and effectiveness. This review should cover the environmental
aspects of activities and serves that are within the scope of the environmental
management system.
4.6.2 Objectives of management review
An organisation should periodically review and continually improve its environmental

management system, with the objective of improving its overall environmental
performance.
How to conduct management review
•Organization must identify the required frequency of the CEMS reviews.
80
•Organization must identify who should be involved in the reviews. The committee
should consist of the Management Representative, CEO, Director of EH&S and
other senior management representatives.
•Organization must determine what should be covered during the review. The
agenda should include review of instances of nonconformance, Corrective Actions,
continuous improvements associated with the EMS, results of compliance and EMS
Audits, complaints, results of any pollution prevention programs, waste minimization
programs and a summation of Measurement and Monitoring results.
•Organization must develop a schedule for reviews.
•The schedule is then communicated to all relevant parties
•The organization must also determine what type of information will be needed by
the committee for the review process. Information providers will need to be informed
in advance.
•During the review, the agreed actions should be assigned appropriately and given a
timescale for implementation. A follow-up should be conducted at a later date to
verify that the EMS modifications were effective.
•Minutes of the review need to be circulated and recorded.
4.6.3 Input to the management review
Inputs to the management review may include:
a) Results of internal audits and evaluations of compliance with applicable legal

requirements and with other requirements to which the organisation subscribes;
b) Communication from external interested parties, including complaints;
c) The environmental performance of the organisation;
d) The extent to which objectives and targets have been met;
e) Status of corrective and preventive actions;
f) Follow-up actions from previous management reviews;
81
g) Changing circumstances, including:
i. Changes in the organisation’s products, activities and services;
ii. Results of the evaluation of environmental aspects from planned or new

developments;
iii. Changes in applicable legal requirements and other requirements to which

the organisation subscribes;
iv. The view of interested parties;
v. Advances in science and technology; and
vi. Lessons learnt from emergency situations and accidents;
h) Recommendations for improvement.
4.6.4 Output from management review
Outputs from the review of the environmental management system may include
decisions on:
a) The system’s suitability, adequacy and effectiveness;
b) Changes to physical, human and financial resources; and
c) Actions related to possible changes to environmental policy, objectives, targets

and other elements of the environmental management system;
82
Information
During the review:sources to consider:
 • Audit Assess
resultsextent of compliance or non
conformance to the Standard

• Internal suggestions
Assess effectiveness of Corrective Action
 • External communications
Suggest corrective measures to solve
• Progress on objectives
problems identified in EMS design,
and intent or scope
targets
• Other environmental
Management reviews can be
performance measures
used to demonstrate top
• Reports of emergencies,
management’s ongoing
spills, other incidents
support for the environment
• New or modified legislation
and regulations
• New scientific / technical
Examples of Changes to the
CEMS That Might Demonstrate
data on materials andCommitment
processesto Continual
used by the organization Improvement
 Changes to the environmental
policy to reflect additional
Management Review: Questions to commitments
Ponder
 Identification of additional
· Did we achieve our objectives and targets? significant environmental
If not, why
not? Should we modify our objectives? aspects
 Changes to objectives and
· Is our environmental policy still relevant totargets
whatwhich
we do?will lead to
improved environmental
· Are roles and responsibilities clear, do they make
performance
sense and are they communicated effectively?
 Technology upgrades
· Are we applying resources appropriately?  Enhance training program
 Enhanced external
· Are our procedures clear and adequate? Do we need
communications
other controls? Should we eliminate some of them?and measurement of
 Monitoring
additional parameters
· Are we fixing problems when we find them?  More frequent tests of
· Are we monitoring our EMS (e.g., via system emergency preparedness and
audits)?
What do the results of those audits tell us? response procedures
 Enhanced document control
· What effects have changes in materials,products, or
Enhanced operational control
services had on our EMS and its effectiveness?
 Enhanced preventive
maintenance program
· Do changes in laws or regulations require us to change
some of our approaches?
· What other changes are coming in the near term? What
impacts (if any) will these have on our EMS?
· What stakeholder concerns have been raised since our
last review? How are concerns being addressed?
· Is there a better way? What can we do to improve?
83
Management Review Section meets the intent of ISO 14001:
• Do you have an existing process for conducting management reviews? If yes,

does that process need to be revised? In what way? If no, describe your
management review process.
• Who needs to be involved in this process within our organization? What are
their roles in this process?
• When is the best time for you to implement this process? Can this effort be
linked to an existing organization process (such as your budget, annual
planning or auditing cycles?)
• How frequently are management reviews? What is the basis for this
frequency? Should you conduct reviews more or less frequently?
• Who is responsible for gathering the information needed to conduct
management reviews? Who is responsible for presenting this information?
• How do you ensure that changing circumstances (both internal and external to
the organization) are considered in this process?
• How do you ensure that the recommendations of management reviews are
tracked and acted upon? Who will document the review meetings?
• What changes have been made to the EMS as a result of the last review?
84
CEMS GUIDANCE
MANUAL

Cems Guidance Manual: Managing Your Environmental Responsibilities

Uploaded by

Document Information

Original Description:

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Cems Guidance Manual: Managing Your Environmental Responsibilities

Uploaded by

Copyright:

Available Formats

CEMS GUIDANCE MANUAL

Managing Your Environmental Responsibilities

4.4 IMPLEMENTATION AND OPERATION

4.4.1 Resources, roles, responsibilities and authorities

Construction enterprises should harmoniously utilize resources to minimize

Proper organizational structure of the construction company is needed to identify

4.4.1.1 Resources required to manage system

4.4.1.2 Roles, responsibility and authority

Example of roles and responsibilities

EMS Reference Title EMS Manual Section Number Accountability

 Comply with Policy: all staff

4.4.1.3 Management representative

a) Identify the persons in the top and other management levels

Example of responsibility matrix

Project EHS HR Purchasing Site EMS Mg’t

• Have you defined the roles, responsibilities, and authorities of your

4.4.2 Competence, training and awareness

Significant activities: who is responsible / should be competent / trained

Identify competent individuals: eg civil engineer (silt trap design)

4.4.2.1 Determining competency requirements

What are essential?

a) The roles and responsibilities in achieving conformance to

4.4.2.2 Training and awareness

Step 1 : Identify training needs and requirements

• Consider both general and specific needs

• Develop an EMS training package for new employee orientation

• Review the qualifications and training needs of trainers

Step 2 : Training Staff

• Develop your EMS training materials.

• Train EMS core team members on EMS requirements.

Key Steps in Developing a Training Program

4.4.2.3 List of recommended training

CEMS Training Plan

Examples of training in construction environmental best practices include soil

Example of a Training Log

Training Topic Attendees* Frequency Course Course Comments Date

Supervisor EHS Training

• Have training needs been identified?

Effective internal communication requires method for information to flow top-down,

External communication can provide a good opportunity to promote the

Effective internal communication requires method for information to flow top-down,

can be an excellent source of information, issues, concerns and ideas. Internal

External communication can provide a good opportunity to promote the

Why communication is needed?

The purposes and benefits of communication can include:

a) Demonstrating the organisation’s commitment and efforts to

Effective communication should be practised:

a) To avoid untoward environmental events as a result of the

4.4.3.1 Determining the need to communicate

Interested parties can include, for example, neighbours, non-government

Basic Steps to Communicate

Begin early in the process

Set communication objectives

Decide what needs to be achieved through communication regarding the construction

Communicate regularly and integrate EMS communication

To build support for the EMS, try to communicate on a regular basis.

Examples of information to be communicated include: (REVIEW THIS

a) General information about the construction that is going to be

For both internal and external environmental communication, it is

4.4.1.1 Internal communication

Issues to communicate can include, licensing, disposal and handling of wastes,

Information regarding the EMS – such as the policy, objectives, targets