Three specific points shall be addressed under the Operational Control section of the regulation:
- Identify the operations and activities that are directly associated with the significant environmental aspects
- Develop procedures and operational criteria for these operations and activities
- Communicate the procedures and operational criteria to suppliers of products and services that might interact with these operations and activities
A procedure may be verbal, a simple pictogram, or an exhaustive statement of specifications for your supplier. Documented procedures are only required where their absence could lead to deviations from the environmental policy, objectives and targets. Use the format that works best in your organisation.
Where do you need written procedures?
The aim of establishing operational control is not to end up with thousands of pages of procedures which detail how every activity should be carried out. The aim is to ensure that environmentally relevant activities are carried out in compliance with the policy and objectives. By implementing standard procedures and practices you will be able to plan, implement and control all environmentally relevant activities.
But remember that there are other possibilities to ensure operational control: operating criteria give margins within which your operation must remain, but do not prescribe the activities. Whether you prefer procedures or operating criteria, will depend on the culture of your organisation, the qualification of staff, etc. In deciding how to proceed, consider the following: written procedures or work instructions tell people how to do a job. Training teaches people how to do a job. Adequate training (with training records) is another way to operational control.
Identify activities and processes related with your significant environmental aspects and relevant to your environmental policy and objectives. Identify procedures that have already been developed for these areas or processes. Decide which procedures still need to be developed. (Remember: pay particular attention to areas where the absence of procedures means there is a danger that environmental policy or objectives are not complied with.)
When developing procedures you must take legal requirements and internal policy and objectives into consideration.
In order to make sure that you develop procedures that are relevant, based on reality and which will be accepted, it is essential to get input from the people whom they concern. Establishing operational control of environmental performance also generally leads to greater efficiency in overall business performance.
Three types of procedures should be considered:
- management procedures, e.g. developing objectives and policies, revising objectives and programmes, reviewing the EMS, and ensuring continuous improvement of performance
- procedures relating to environmentally aware production
- complementary procedures, e.g. product development, purchasing, sales and marketing, delivery and logistics, external communication, personnel organisation.
You should develop procedures that ensure that activities and processes are carried out in compliance with policy and objectives. Pay particular attention to:
- documented procedures, whether the activity is done by your employees or by others acting on your behalf
- procedures to ensure that your suppliers and contractors comply with your environmental policy and objectives as far as is relevant.
Some activities that may cause a significant impact are not directly in your control (consider leftover material from contracted work as an example). However you are still in a position of considerable influence, e.g. through considering these items in the contracts.
- monitoring and control of relevant environmental effects
Move on to next section for details.