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Initial Review Of Gap Analysis In ISO 14001

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A fundamental concept of the ISO 14001 EMS Standard is continual improvement of environmental performance. Before you can plan for improvement, you must first determine the current state of the organization s environmental programs.

The initial review or gap analysis is, in itself, a microcosm of a well-organized approach to the entire ISO 14001 EMS development process. Each specification of the standard must be reviewed, including policy, legal requirements, training, objectives and targets, operational control systems, document control, auditing, management review, and corrective action.

The review should take into account the culture, products, marketing strategies, and other specifics of the organization. In all cases, consideration should be given to the full range of operating conditions, including possible incidents and emergency situations that may be encountered.

The ability of suppliers and subcontractors to comply with the Organization s EMS program and applicable regulatory requirements should also be evaluated. It is strongly recommended that the initial review consider energy use, financial accounting, and information systems so that these issues may be integrated into the EMS program.

To effectively begin the Initial Review, several things must happen. First, Management should issue a company-wide announcement of intent and endorsement. This should include estimates of the time required to complete the Initial Review, and time required to complete the entire project. Second, the project leader should be identified and vested with ample authority for completion of the project.

The Initial Review is a review of all pertinent documents, from which an accurate plan is designed for the EMS Gap Analysis.

All information from the review, including deviation from regulatory requirements and adverse impacts on the environment, should be identified along with policies, programs, procedures, training and work instructions, and operational controls.

A portion of the project team should begin to assemble a registry of appropriate regulations identified during the Initial Review. All pertinent national, state, local and self-subscribed requirements should be assembled. They should be compared with identified environmental impacts.

An Initial Review is also important in ensuring that EMS design is compatible with all current organizational management structures and operations wherever possible. This is especially important where the EMS interfaces with the site s existing health and safety, accounting, computer systems, purchasing, energy utilization and other management programs. The focus will be to achieve operational efficiencies that ensure environmental improvements and maximize cost reductions.

Initial Review outputs will be:

An EMS Gap Analysis Design that details where existing environmental management procedures must be further investigated to determine conformance with the Standard.

A review of the site s overall environmental management strengths/weaknesses.

A schedule of events for the Gap Analysis.

The gap analysis allows for a quick but comprehensive assessment of the facility s existing environmental management practices and procedures, and compares them

with the requirements of the Standard. To perform the Gap Analysis, a standard template tailored for that specific purpose is used. The template is a questionnaire with a three way scoring system, which develops a final rating of the current programs of the site as they compare with the sections of the Standard. The score from this questionnaire and investigative template identifies which areas of the EMS might be enhanced to improve environmental performance and comply with the Standard.

Based on the results of the Gap Analysis, the project schedule and design may require modifications. Modification should precede further systems development. Using the results of the Gap Analysis, the EMS developmental process can now begin.

This may involve modifying existing procedures, adapting other business procedures such as those designed for health and safety, accounting, or risk management to environmental utilization. At certain points, new procedures will be required.

Prior to embarking on EMS development, always remember that the more flexible your EMS is, the easier it will be to implement and the more flexible it will be in the future.

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ISO 14001 Standard

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