John Nolan Many times during ISO 14001 implementations a client has asked me why they need an emergency response procedure, and how they should go about writing it. The very words “emergency response procedure” can sound daunting, but they needn’t be.
Clause 4.4.7 of the ISO 14001:2004 standard states the requirement for an organization to have an “emergency preparedness and response” process. This is designed to ensure that organizations can identify potential situations and incidents that may have a negative effect on the environment, and have a stated methodology to deal with them. The standard then mentions that an organization must review and improve these, as we know that continual improvement is an integral part of the standard, but it is left to the individual organization to decide how all of the above is achieved. So, what key components do we have to take into consideration when developing these policies and procedures?
Emergency Procedure: What and who to consider
As we know, the ISO 14001 standard is designed to protect the environment. In order to achieve that goal, an organization has various legal, external, and internal considerations to make, in addition to developing a procedure that can measure, assess, and mitigate risk as well as deal with any potential accidents or incidents. We will look at how to do this later in this article, but firstly we must consider what other parties need to be considered when we create this process and the accompanying procedure:
- Legal Considerations: Does your country or region have legislation that you need to be aware of and consider when writing your emergency procedure? Has your organization constructed a legal register to track updates on legislation that may affect you? If not, you need to do so.
- Internal Company Considerations: How is your staff involved in this process? Who is responsible for the coordination of company business in the event of an accident? Are all responsibilities clearly defined? Do the responsible persons have the resources and training to ensure that any emergency processes and procedures can be implemented in a timely and effective manner? Do you have an effective communication channel to ensure they know about this procedure and any updates that may be implemented? Does something in this procedure schedule testing and verification to ensure that the process is effective and the goals achievable? Is there a feedback loop for staff to ensure that suggestions for continual improvement can be made? Do you have a stated communication channel in the event of an accident or incident, given that it may be impossible to work from the office in those circumstances?
- External Stakeholder Considerations: Along with contractors and partners who have a vested interest in your ability to deal with an environmental emergency, you will almost certainly have to depend on other external agencies to execute this procedure after you develop it. If a fire department response is required, can they respond within your expected timescale? If hazardous chemical quarantine or removal is required, can this be achieved effectively and within a reasonable amount of time? What happens if there is a fire – is there a route for the water runoff to travel safely without land contamination occurring? Are all targets that require external assistance or intervention manageable, realistic, and achievable? It may be a good idea to share your emergency response procedure with these external parties for their approval, to ensure that in case of an incident or accident that your stated objectives can be met.
Structuring your environmental emergency procedure
Armed with the results of the considerations we have outlined above, and after carefully examining section A.4.7 of the 14001:2004 standard, we now know exactly what criteria we need to satisfy to have a workable environmental emergency response procedure. It is at this stage we can take the knowledge of the changes we know are coming in the forthcoming 14001:2015 standard regarding risk management (to learn more about changes in risk management, read the article Risk Management in ISO 14001:2015 – What, why and how?) and apply them to create an even more robust procedure. Therefore, we must ensure that our written procedure addresses the following:
- Assessing potential emergency situations – as per the forthcoming ISO 14001:2015 standard, why not involve your “top management” team to do this?
- Prevention of accidents and incidents, which ties in closely with point 1.
- Plans and processes that are defined to respond to incidents, including corrective actions.
- Testing of emergency procedures wherever possible.
- Review and improvement of emergency procedures.
- Contingency plans in the event of an accident or incident – how do we communicate, where do we meet, can we work from home, where do we dial in and discuss plans, and so on.
You may, of course, structure your environmental emergency procedure to suit your own business, but be aware that you will be required to demonstrate evidence of the aspects above at your audit, including evidence of testing, review, and improvement of your environmental management system in general, and your emergency response procedure specifically. Make it realistic and sensible, and involve the opinions of your staff and stakeholders. In that way the environment will benefit, and your organization and stakeholders will, too.
Use this free ISO 14001 Gap Analysis Tool to assess what gaps exist in your ISO 14001 system.
