An EMS as a portfolio of projects

 Because you make art you become an artist not the other way around.

While implementing an environmental management system (EMS) it is very easy for me to remember ISO 9000:2015 definition of management system and think about an EMS as a portfolio of projects aligned with the strategic orientation and with the purpose of improving the interaction of an organization with the environment.

So, instead of an EMS that also generates improvement projects you can have a set of improvement projects that constitute, that give body to an EMS. Let us see how:

You go into reality and you determine the environmental aspects and impacts (clause 6.1.2). 

You go into reality and you determine relevant interested parties and you determine their relevant needs and expectations (clause 4.2)

Based on the environmental aspects you determine the mandatory compliance obligations (clause 6.1.3).

Based on the relevant needs and expectations of relevant interested parties you determine the voluntary commitments that your organization will assume and treat as mandatory compliance obligations (clause 6.1.3).

Perform an evaluation of compliance (clause 9.1.2) to determine any situation of partial or total non-compliance.

Any situation of total or partial non-compliance, considering the environmental policy commitment to fulfill compliance obligations (clause 5.2 d)) can be part of an environmental objective (clause 6.2.1) to improve performance. Environmental objectives should be communicated (clause 7.4) and should be translated into an action plan (clause 6.2.2).

Some situations of total compliance, considering the environmental policy commitment to continual improvement (clause 5.2 e)) can be translated into an action plan (clause 6.1.4)

Each environmental action plan (clause 6.1.4 or clause 6.2.2):

• may need investments that must be approved and implemented
• may be victim of risks (clause 6.1.1) that may generate undesirable results or prevent the organization from meeting desired results. Emergency situations (clause 8.2) must be determined, prevented and a response tested and set in standby
• may give birth to new or improved practices (clause 8.1)
• may change people’s responsibilities and authorities (clause 5.3)
• may change the set of instructions and records needed (clause 7.5) and the competence requirements (clause 7.2) for those working in the environmental management system

Then, go again back to reality to check the effectiveness of all those actions: check the environmental performance.

• Monitor environmental performance (clause 9.1.1)
• Treat any non-conformity and evaluate the opportunity to develop a corrective action (clause 10.2)
• Evaluate performance at the management review (clause 9.3) and decide about continual improvement (clause 10.3).

So, just working with a set of projects allows an organization to work with almost all clauses of ISO 14001:2015:

• 4.1 - 4.2 - 4.3 - 4.4
• 5.1 - 5.2 - 5.3
• 6.1.1 - 6.1.2 - 6.1.3 - 6.1.4
• 6.2.1 - 6.2.2
• 7.1 - 7.2 - 7.3 - 7.4 - 7.5
• 8.1 - 8.2
• 9.1.1 - 9.1.2 - 9.2 - 9.3
• 10.1 - 10.2 - 10.3