One step at a time

Implementing an environmental management system does not need to be a daunting task for small and medium enterprises. A phased approach is possible.

Small and medium-sized enterprises (SMEs) contribute a significant part of many countries’ economic output. Consequently, their individual and cumulative activities result in an estimated 70% of all environmental impact of businesses both in the UK and globally. 

Under pressure from various groups of stakeholders such as customers, governments and local communities, SMEs are increasingly acknowledging the responsibility they have to improve their environmental performance. Some are recognising that the environment is a management issue and not just a matter of compliance.

However, many see this as a burden, which is exacerbated by the fact that environmental management is often delegated to the health and safety representatives as an add on to their core roles. This leads to a significant pressure on them to juggle the legal requirements of health, safety and environmental management and more voluntary schemes and initiatives that would reduce costs and improve the organisations’ wider environmental footprint.

To make matters more acute, many suppliers are now asking environmental and sustainability questions in tender documents that SMEs often struggle to answer due to a lack of structured approach to environmental management.

Simple steps like recycling only require a will to be done. Photograph: Monkey business images

Many SMEs opt to try and implement ISO 14001:2015 from the outset and this can be a daunting task. Barriers to implementation include lack of resources, both human and financial, knowledge and a perception that environmental impact is small small or insignificant for an SME.

However, any company can implement a system to help manage their responsibilities. To recognise and assist companies that wish to do so, the British Standards Institution has developed guidance.

Like any business programme breaking down the implementation of any management system should be done in a phased stage. The path to implementing ISO 14001 is set out in a British Guidance Standard called BS 8555:2016, which helps organisations, and especially SMEs, build an environmental management system (EMS) in five phases.

This guidance standard, updated from the 2003 version in 2016 to align with ISO 14001:2015, is now used worldwide to help SMEs implement a structured environmental management system in more manageable chunks.

Achievement of all phases is equivalent to ISO 14001:2015. Moreover, the same approach can be utilised for those organisations wishing to implement or transit to ISO 45001:2017 because of the high-level structure relationship between all ISO management systems.

Phase 1 – Leadership, context and commitment

Consists of seven stages and is centred around getting started on the road to an EMS. This phase is underpinned by top management involvement from the outset. They will need to demonstrate that they actively engage in, and undertake, key EMS management system activities.

Individual and organisational impact on the environment is not just a question of compliance. Photograph: Greenpeace

It is not sufficient for them to simply ensure these activities occur; they must get actively involved in the operation and make sure that the EMS is not a separate and discrete activity.

The establishment of a signed environmental policy is key at this stage, setting out the general direction and showing commitment, compatible with the context and strategic direction of the organisation.

The EMS should eventually integrate into the organisation’s business process and be aligned with any growth of the company. At this first phase it is important to communicate the importance of the EMS and its requirements through engaging, directing and supporting people by developing awareness and identifying competency needs.

We also need to identify what data is needed, for example, in energy, waste, water and other raw material use, depending on the organisation’s activities and its key impacts and spend.

Phase 2 – Ensure compliance

Phase two consists of three stages and involves identifying all applicable compliance obligations. ISO 14001:2015 defines compliance obligations as “legal requirements that an organisation has to comply with and other requirements that an organisation has to or chooses to comply with”. In the note it further states: “Compliance obligations can arise from mandatory requirements, such as applicable laws and regulations, or voluntary commitments, such as organisational and industry standards, contractual relationships, codes of practice and agreements with community groups or non-governmental organisations.”

Once identified, the organisation needs to evaluate and manage compliance obligations defined by mandatory and/or voluntary requirements.

Phase 3 – Plan and develop the EMS

Phase three consists of seven stages but mainly involves determining significant environmental aspects, identifying key risks and opportunities and setting SMART objectives and targets.

To make sure these are ultimately achieved, the organisation will have to put in place a system to monitor, measure, analyse and evaluate environmental performance. Again, depending on the size and nature of the organisation, any system can be simple or much more complex. But ultimately, the ethos of continual improvement means that it must be able to show this in a structured manner. During this phase roles and responsibilities are also further defined to align with the above and the environmental policy finalised.

Phase 4 – Implement the EMS

Phase four consists of seven stages and is akin to the doing stage of a management system. Operational controls are identified and accompanying procedures written as well as value chain controls. The latter relate to any control that different organisations in the supply chain can exert over the activities of the chain, including suppliers and clients, for example. Emergency preparedness and response plans are written, dependent on the type and nature of the organisation but also in relation to health and safety and business continuity.

During this phase it is important that any staff and outsourced operations undergo some form of awareness activities, as part of a wider communication programme. In other words: what, when and why we are communicating environmental information and to whom. All documented information should be managed, stored and retrievable under a document control system.

Phase Five – Check and update

Phase five consists of four stages and centres around the checking part of the management cycle. We need to establish internal audit programmes so that we can assess how the system is operating and be able to raise and to correct any non-conformities. During this phase it is necessary to carry out a management review on how the system has performed and any changes needed. This will allow the business to show how the EMS has improved and show its environmental performance.

When all five phases are complete the organisation has a system that is compatible to ISO 14001:2015 and is ready for an assessment of certification should the organisation wish to have external accreditation. However, there is no requirement for this.

In conclusion, if your organisation wants to implement a structured management system but feel it is a daunting task, then it is recommended to consider this phased approach.