A management system is only as effective as the people running it. Clauses 7.2 and 7.3 address the human capability foundations of the EMS — ensuring persons whose work affects environmental performance are competent through education, training, or experience, and that all workers are aware of the EMS and their role in its effectiveness.
Clause 7.2: Competence
Organizations must determine the necessary competence of persons whose work affects environmental performance or the ability to fulfill compliance obligations, ensure those persons are competent based on appropriate education, training, or experience, take actions to acquire necessary competence and evaluate their effectiveness, and retain documented evidence of competence.
Per Annex A, competency requirements apply to persons who determine and evaluate environmental impacts, contribute to achieving objectives, respond to emergencies, perform internal audits, and evaluate compliance. This includes employees, contractors, and external personnel.
Building a Competency Matrix
Competency Matrix Structure
- Roles: All positions with environmental responsibilities
- Required competencies: Specific knowledge, skills, and abilities for each role
- Evidence: Qualifications, certifications, training records, on-the-job sign-offs
- Gaps: Identified training or development needs
- Actions: Planned training, mentoring, or recruitment to close gaps
Evaluating Training Effectiveness
This is a frequent audit finding. Attendance alone does not demonstrate competence. Effective evaluation methods include post-training assessments and quizzes, on-the-job observation by supervisors, performance reviews incorporating environmental KPIs, follow-up audits of trained activities, and monitoring of environmental performance metrics after training.
Clause 7.3: Awareness
Awareness applies to all persons working under the organization’s control — broader than competence. All workers must be aware of the environmental policy, significant environmental aspects and impacts associated with their work, their contribution to EMS effectiveness including benefits of enhanced performance, and the implications of not conforming with EMS requirements, including noncompliance with compliance obligations.
Training Delivery Channels
- Classroom and instructor-led sessions for role-specific competencies
- E-learning modules for broad awareness training
- Toolbox talks for operational environmental topics
- On-the-job training and mentoring for practical skills
- Onboarding programs for new hires and contractors
- Regular refresher training on evolving topics
Common Pitfalls
- Equating attendance with competence
- Not evaluating training effectiveness
- Excluding contractors from awareness requirements
- Generic training not tailored to role-specific environmental impacts
- Missing documentation of competence evidence
