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Since introduction of ISO 14001 Standard for Environmental Management Systems the market has developed numerous practical models of Environmental Manuals for organizations with single sites. At the same time, formats for management system structures for multi-facility businesses are limited at best in technical publications. This paper discusses a model for structuring a top-level documentation that allows an organization with multiple sites to use common ISO 14001 Environmental Management System Manual. Discussed approach noticeably improves consistency of the organization’s Environmental policies.

Working as an Environmental Lead Auditor for numerous international ISO registrars, I assessed dozens of big multi-facility, multi-national organizations that had difficulties with synchronizing their home office ISO 14001 Environmental Manuals with the corresponding documents controlled by their sites. Designing Environmental Manuals for companies with multiple sites, some organizations develop their sites’ Environmental Manuals as copies of the corporate Environmental Manual; other enterprises create facility-specific Manuals that are totally autonomous and do not correlate with corporate ISO 14001 Manuals.

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

In the case of companies choosing their facilities to develop their own ISO 14001 Manuals, discrepancies in numerous Environmental Manuals result in visible differences between the home office and facilities’ Environmental Manuals and therefore commitments to environmental issues.

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

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

Summarizing my EMS auditing and consulting experiences, I am convinced that these approaches to design of the corporate Environmental Manual and sites’ Manuals do not provide a solid consistent way to document organization’s Environmental Management System and Manuals.

Fortunately, there is a solution. Let’s review an example of ISO 14001 2008 Environmental Manual model that references supporting documents within the text of the Manual. For example, element 4.3.2, Legal and other requirements, may read: EMS Associates, LLP has established, implemented and maintains Legal Requirements Procedure to identify and have access to the applicable legal requirements related to the organization’s environmental aspects per the Environmental Aspects Procedure,

The same method will also work for a multi-site organization for those documents that are used at all locations. For example, such processes as Hazard Material Handling, Management Review, Non-Conformity Procedure and others may be the same for all locations and therefore be referenced in the Environmental Manual as shown above.

However, what if our locations need to use different environmental aspects, programs and other site-specific Environmental Management System processes? If we use the model above and want to keep a common ISO 14001 Environmental Manual, we have to reference in the Manual corresponding documents for all locations which may not be practical. Below we will explore how a corporate Environmental Manual can practically reference location-specific documents to support commitments of the company’s common ISO 14001 Environmental Manual.

The same document reference structure as for a single-location company that we discussed above, can be used if the number of locations is small, let’s say two or three. In this case, clause 4.3.1, Environmental aspects may read: Environmental Consultants Inc. has established, implemented and maintains Environmental Aspect Procedure to identify the environmental aspects of its activities, products and services and Significant Environmental Aspect Matrix HO and Significant Environmental Aspect Matrix WA to determine and document those aspects that have or can have significant impacts on the environment. This example shows references to the common Environmental Aspect Procedure and site-specific Significant Environmental Aspect Matrixes for the Home Office (HO) and the Washington (WA) locations. While this model works well for a limited number of facilities, it becomes impractical when the number of locations is significant.

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

Corporate ISO 14001 Environmental Manual section

Manual Reference Matrix Table of Contents (ToC)

Facility Manual Reference Matrix

Location procedure

The Manual Reference Matrix is simply a list of all facilities and their Manual Reference Matrixes, as shown in the example below:

Manual Reference Matrix Table of Contents

Home Office (San Francisco, California, USA)

Miami, Florida (USA)

St. Petersburg (Russia)

Aspen, Colorado (USA)

Tokyo (Japan)

etc,

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

Finding the location of interest in the Matrix ToC and locating, we will find, let’s say, St. Petersburg’s Matrix. In the matrix, in the given element, we will identify a site-specific Key Characteristics Matrix SP.

Our experience shows that a Manual Reference Matrix works well as a 3-column form with the 1st column titled Corp. Manual Section, the 2nd column Corp. References, and the 3rd column called Site References. For the element 4.5.1, for example, the St. Petersburg’s Matrix indicates that Manual references Key Characteristics Matrix HO for the home office and Key Characteristics Matrix SP for the St. Petersburg site.

If you are developing an ISO 14001 Environmental Manual for a large corporation with multiple sites, check the links below for samples of Reference Matrix.

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