Operational planning and control is where the EMS meets daily operations. Clause 8.1 requires organizations to establish, implement, control, and maintain processes needed to meet EMS requirements and implement actions identified in planning (Clause 6). This includes establishing operating criteria for processes and implementing control of those processes in accordance with the criteria.
Key Requirements
Organizations must establish operating criteria for processes where their absence could lead to deviation from the environmental policy, objectives, or compliance obligations. Controls must address significant environmental aspects, including those associated with the product and service lifecycle.
Types of Operational Controls
Control Methods
- Engineering controls: Physical measures such as containment systems, pollution control equipment, process modifications
- Administrative controls: Standard operating procedures, work instructions, permits-to-work, inspection checklists
- Monitoring controls: Continuous monitoring systems, alarm thresholds, automated shutdown triggers
- Behavioral controls: Training, awareness programs, supervision, performance feedback
Outsourced Processes
The 2015 revision strengthened requirements for outsourced processes. Organizations must determine the type and extent of control or influence to be applied, considering lifecycle perspective, the degree of control the organization can exercise, and the potential for the outsourced process to affect the ability to fulfill compliance obligations. This may involve contractual requirements, supplier qualification, inspections, and auditing.
Procurement and Supply Chain
Consistent with the lifecycle perspective, organizations must establish environmental requirements for procurement of products and services, communicate relevant requirements to external providers (including contractors), and consider the need to provide information about potential significant environmental impacts during transportation, delivery, use, and end-of-life treatment.
Managing Change
Planned changes must be controlled, and unintended changes must be reviewed to mitigate adverse effects. This includes changes to processes, equipment, raw materials, organizational structure, and external providers. Change management should evaluate potential impacts on environmental aspects, compliance, and operational controls before implementation.
Common Pitfalls
- Operational controls not linked to specific significant aspects
- Outsourced processes not controlled or monitored
- Procurement lacking environmental criteria
- Change management not evaluating environmental impacts
- Operating criteria too vague to be implemented consistently
