Mark Hammar All companies keep records of the many facets of their business, but when implementing ISO 14001, two questions are often asked: What records are needed for the environmental management system, and what are the specific requirements for maintaining these records? The requirement in ISO 14001 is not very long or complicated, but there are a few things to keep in mind when making sure your company processes conform to these requirements.
What needs to be recorded?
The requirements of ISO 14001 quite simply state that you need to maintain records to show that you conform to the requirements of the environmental management system and ISO 14001, but what is meant by this? There is a list of records mandated by ISO 14001, and along with these should be any other records that you as a company have identified to prove that your system is working.
The mandatory records of ISO 14001 include:
- Records of competence, awareness, and training – these recordsshow what you have done to ensure that your employees and other parties can perform the activities required in such a way as to reduce your environmental impact.
- Records of evaluation of compliance – the records of these evaluations demonstrate that you have met all the legal and other requirements for your company (or have addressed any noncompliance).
- Records of Operational Controls – Your environmental aspects are documented items of the ways that your business processes interact with the environment (such as air emissions or waste disposal). The records of the controls you have put in place to control these aspects are critical to prove the efficiency of the EMS.
- Finally, records of nonconformity, corrective and preventive action, along with internal auditand management review demonstrate that all EMS processes are in place and functioning properly.
Additionally, the standard requires that you maintain records of the results achieved by the EMS, which will demonstrate whether you have met your goals, or are on track to meet those goals that are ongoing. Some examples of these would be records of air emissions to demonstrate compliance to target emissions or records of waste disposal to show that waste reduction targets are being met.
For a complete listing of the mandatory records for ISO 14001, see Checklist of Mandatory Documentation Required by ISO 14001:2004.
How to maintain the records?
There are nine characteristics of a record that need to be safeguarded for the records you have identified to show that your environmental management system is working:
Identification – Have you identified where you need records, both for the mandatory records and all others you need? How do the people using the processes know a record is needed? If you have a target to reduce waste, then you will need to maintain records of waste disposal in order to track this.
Storage – How will you store the records? How will you ensure no damage is done to the records, either as a paper copy or electronic? If you are keeping paper records, store in a location where they will not be damaged by water or mold; if the records are electronic, properly back up the records so that they are not permanently lost due to a computer problem.
Protection – How are the records protected not only against damage, but also against unintended use? Who has access to records, and who does not? For instance, records that are sensitive should be kept on a controlled access computer drive so that they can only be seen by those with the proper approval.
Retrieval – When you need to look at a record that is in storage, how do you access it? Are the records freely accessible, or is there a record keeper who needs to grant permission? How quickly do you need to find a record if it is needed, and can you retrieve it in this time?
Retention – How long will you keep records? This will vary by record, and by the legal requirements that may or may not apply to that record. For instance, records of corrective actions against legal non-compliances may have a specified length of time to be kept in order to satisfy the law.
Disposal – When the time comes to get rid of the records, how will you do so? Whose job is it to monitor when records should be destroyed? If you are required to maintain records of waste disposal for seven years, you need to make sure they are kept for this long before you destroy them.
Legibility – How do you make sure that a record can be read, both when written and throughout storage? For electronic records the ability to read the medium the record is stored on falls under this requirement; if you have records from years ago on floppy drive, do you still have the ability to read them?
Identifiable – Can you identify what the record is for and when it is relevant? If this is a record of calibration for a piece of monitoring and measurement equipment, can you trace what equipment it is for and when the calibration was done?
Traceable – Do you know where each record is stored for easy retrieval? If records are related, is it possible to trace the relationship between them and find a second record from the first?
Importance of records
When it comes down to it, you need to be able to show that any claims you make in your environmental management system have been addressed. If you say that you monitor the air emissions from a chemical process, you need to show that the monitoring was not only done (records of emissions), but also that they were done correctly (records of monitoring equipment calibration). While records are not the only way to prove that you have done what you claimed, if you are dealing with a process that has a requirement to do something, you need to ask yourself how you would be able to prove this activity took place in the correct way so that the environment was not affected. If you find that you could not prove this, then maybe you are missing a record. Find a way to correct this before the need for proof arises for an emergency situation.
To get familiar with the requirements visit ISO 14001:2015 Foundations online course.
