The environmental management programme is your 'action plan' but it is only one day-to-day aspect of your environmental management system.
The others are the 'routine procedures' that are already in place. These routine procedures must also be covered by the EMS. They are the Implementation and operation steps of the ISO 14001 environmental management standard.
Relating the P-D-C-A cycle to environmental management, we find that this section of the regulation is the 'do' step of P-D-C-A.
DO: relevant ISO 14001 sections
Implementation and operation
4.1 Structure and responsibility
4.2 Training, awareness and competence
4.4 Environmental management system documentation
4.5 Document control
4.6 Operational control
4.7 Emergency preparedness and response
To ensure that your organisation meets the operating requirements of EMAS means that you need an adequate structure and responsibilities. This includes the assignment of an environmental manager responsible for the creation and implementation of the EMS itself and the assignment of clear responsibilities and accountability for all activities that affect the environment. Management has the responsibility for providing necessary resources.
The training, awareness and competence section is about the knowledge and skills employees need to perform their tasks. Employees, and particularly those with a key environmental role, must be competent and the organisation must be able to demonstrate this. Training needs must be identified, training must be given and records of training kept.
Communication concerns the flow of relevant information among people inside the organisation and with communications from outside the organisation. Remember that EMAS focuses on strong employee involvement and participation.
EMAS requires an environmental management system documentation that describes the 'core elements of the management system and their interactions'. The most common way of meeting this requirement is to write a management manual. Another section related to documents is document control. Briefly, document control means developing a procedure to authorise and regularly review important documents, to ensure that these are distributed to the right people, and that obsolete documents are removed from circulation.
Operational control is a key part of operating an EMS. You are required to control your significant environmental aspects and commit yourself to compliance with relevant legislation. This probably calls for writing Operating Procedures or including the environmental dimension into existing Operating Procedures or Work Instructions. Procedures and/or Instructions should consider accidental releases and responses to emergency situation as well, ensuring emergency preparedness and response.
Let us now take a closer look at Structure and responsibility.