Sunday, August 30, 2009

What is ISO 14000?

ISO 14000 is a series of international standards that have been developed to incorporate environmental aspects into business operations and product standards. ISO 14001 is a specific standard in the series for a management system that incorporates a set of interrelated elements designed to minimize an organization’s impact on the environment. Similar to the ISO 9001 Quality Management System (QMS), ISO 14001 defines the implementation of an Environmental Management System (EMS). In addition, ISO14001 incorporates the QMS ISO 9001 management system philosophy, terminology, and requirement structure, providing system compatibility.
What Does ISO 14001 Require?
Originally issued in 1996 and later revised in 2004, the ISO 14001 EMS standard is intended to address the identification, evaluation, and continual improvement of an organization’s activities, products, or services that interact with the environment. The ISO 14001 methodology is a systematic approach for continually improving environmental management through identification and evaluation of aspects and impacts, development of objectives and measurable targets, implementation of programs, and on-going monitoring and review.

Understanding the ISO 14001 Standard

ISO 14001 is an international voluntary standard that specifies the minimum elements for an environmental management system. It was published in 1996 by the International Organization for Standardization and is being taken up by organizations throughout the world at varying speeds.
The above is accepted as true by most people who are aware of the standard. Beyond these simple facts, however, there are many misconceptions about ISO 14001. For instance:
ISO 14001 will be a requirement for all companies.As with ISO 9000, conformance to ISO 14001 may become a condition of doing business in certain countries, regions or markets. This process already has begun in some industrial sectors, such as the automotive and electronics markets. However, there are still a tremendous number of companies in business today that do not conform to ISO 9000, even though that standard is now 13 years old. Thus it is too early to tell how widely ISO 14001 will be required in the future.
Implementing ISO 14001 means getting a registration.Many suppliers choose to demonstrate conformance to ISO 14001 through third-party certification. Some customers may require this. However, the standard itself considers a company’s self-declaration of conformance as an acceptable alternative. Further, some companies simply use the ISO 14001 model for internal purposes as a means to enhance their environmental performance.
ISO 14001 is just paperwork and won’t really help my company.ISO 14001 is like many things in life – you get out of it what you put into it. The way a company implements the standard determines what benefits it receives. Many companies that have implemented ISO 14001 report a variety of benefits, including improved environmental performance, greater operating efficiency, cost reduction, improved employee awareness and enhanced public image, among others.
Implementing ISO 14001 means throwing out our current environmental programs.ISO 14001 criteria specify “what to do,” not “how to do it.” Implementation approaches vary widely. There is no reason to think that your existing approach to environmental management must be put aside to satisfy ISO 14001.

ISO 14001:2004 Document Control System

Documents required by the environmental management system and by this international standard shall be controlled. Records are a special type of document and shall be controlled in accordance with the requirements given in 4.5.4 (Control of Records).
The organization shall establish, implement, and maintain a procedure(s) to
a) approve documents for adequacy prior to issue;
b) review and update as necessary and re-approve documents;
c) ensure that changes and the current revision status of documents are identified;
d) ensure that relevant versions of applicable documents are available at points of use;
e) ensure that documents remain legible and readily identifiable;
f) ensure that documents of external origin determined by the organization to be necessary for the planning and operation of the environmental management system are identified and their distribution controlled; and
g) prevent the unintended use of obsolete documents and apply suitable identification to them if they are retained for any purpose. [ISO 14001, 4.4.5]
http://www.iso-consults.com
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Saturday, August 29, 2009

Conducting An Initial Environmental Review For EMS

Conducting An Initial Environmental Review in ISO 14001 EMS

An initial environmental review covers all the aspects of an EMS. As a result of this review the organization knows its strengths and weaknesses, risks and opportunities regarding the current status of its EMS. The gap between the requirements of the EMS standard and the actual status of the organization shows which aspects the organization should focus its efforts on to improve the system. This leads directly to the development of an environmental management program that should fill the gaps.The Environmental review should focus on three key areas:- Examination of existing environmental management practices and procedures- Identification of significant environmental impacts and their priority- Identification of legal and regulatory requirements1. Examination of Existing Environmental Management Practices andProceduresThe methodology for assessing existing environmental management practices and procedures is proposed here using a questionnaire. The review team fills out this questionnaire by interviewing appropriate people, by analyzing existing documents and procedures dealing with environmental issues and by collecting information about environmental aspects of the organization’s operations, products and services.By conducting the initial environmental review, an organization-specific profile of strengths and weaknesses can be drawn up. Because the score in each EMS area shows the effort needed in terms of financial and human resources,the organization knows where to focus its efforts when building up an EMS and where the largest effort is needed.
2. Identification of Significant Environmental Aspects and their PriorityAn environmental policy requires top management to set priorities regarding environmental aspects. An initial review clearly shows where to set priorities regarding the EMS itself. But, it does not help to set priorities among different environmental problems. Many top managers feel pressure to do something for the environment and thus embark on some form of ?Eenvironmental activism?E often containing many isolated activities, but no clear direction. One way to solve this problem is to develop a so called ?Environmental exposure portfolio?EThe first step of this portfolio analysis is to assess the exposure and therefore the importance of different environmental aspects for an organization’s overall performance.The appropriate perspective and priorities of the environmental policy will differ depending on this preliminary analysis. The analysis should be conducted from the perspective of the stakeholders of the organization, their needs and their importance for the success of the organization. The degree of exposure to different environmental aspects should guide the involvement and perspective of an organization when implementing an EMS. Evaluating exposure to environmental aspects is important, because this exposure is likely to influence the organization’s success sooner or later, either through new legislation, public or consumer perception and behavior or otherwise.The analysis of the expected exposure of an organization to different environmental problems and the weight given to these aspects by various stakeholders enables management to focus on environmental issues that are a high priority to the organization. This is represented in the quadrant in the upper right corner of the environmental exposure portfolio. However, the two quadrants on the left must also be observed, although less vigorously. Issues with low public priority, to which the firm contributes heavily become a problem as soon as the perception of the stakeholders and the public environmental policy changes (the quadrant in the upper left corner of the portfolio). That this can happen very rapidly is obvious, for example from Shell`s ?Brent Spar?Edumping case (detailed information about this case is available from Shell or Greenpeace at their respective WWW-sites). Investments in new production technology, products and services can increase the environmental impact of the organization when not anticipated early enough. In this case, a problem ranked in the lower right corner of the portfolio would shift to the field with the highest priority. Problems ranked in the lower left corner are of no priority. No measures should be taken here.
3. Identification of Legal and Regulatory RequirementsThe identification of legal and regulatory requirements assesses two levels of an organization:- production-related environmental regulations- product- and service-related environmental regulationsThe former addresses the production department while the latter addresses the marketingand R&D departments. Basically, three questions must be answered:- Which are the relevant environmental regulations? (= target)- Is the current situation in the organization known? (= actual)- Does the organization comply with relevant regulations? (=gap)The methodology used here is a questionnaire. To obtain information about environmental regulations the following information sources can be used:- governmental authorities- industry associations- daily newspaper- university publications (law departments)

Friday, August 28, 2009

Evaluation Of Compliance Of ISO 14001 EMS

The requirement to establish a procedure for periodically evaluating compliance with applicable legal and other requirements falls short of specifically requiring regulatory compliance audits but, in fact, a system of regular regulatory compliance audits may be the most practical means for meeting this requirement of the standard. In the U.S., determination of whether to conduct a compliance audit will be governed in part by the particular jurisdiction’s approach to allowing a legal privilege for the self-assessment audit.
Evaluation vs. Audit – The difference between an evaluation and audit can only be determined by looking outside of ISO 14001. Consulting a dictionary reveals that an evaluation involves a determination of value or worth and that an audit is an examination of accounts done by persons appointed for the purpose. A better definition `is the more specific ISO 19011:2002, Guidelines for Quality and/or Environmental Management Systems Auditing, which defines an audit as a “systematic, independent, and documented process for obtaining audit evidence and evaluating it objectively to determine the extent to which the audit criteria are fulfilled.” Many organizations do not have a system for evaluating regulatory compliance other than their own records and the inspections of regulatory officials. This lack of a verification system can be a risky way to operate. Reports of enforcement actions and consent agreements show that many organizations are blindsided by rogue employees who violate rules and falsify documents to cover up environmental misdeeds. Although ISO 14001 does not prescribe a specific approach to evaluation of regulatory compliance, organizations should consider methods for going beyond verification of records by collecting and evaluating physical evidence.

Evaluation Of Compliance Of ISO 14001 EMS

Evaluation Of Compliance Of ISO 14001 EMS

The requirement to establish a procedure for periodically evaluating compliance with applicable legal and other requirements falls short of specifically requiring regulatory compliance audits but, in fact, a system of regular regulatory compliance audits may be the most practical means for meeting this requirement of the standard. In the U.S., determination of whether to conduct a compliance audit will be governed in part by the particular jurisdiction’s approach to allowing a legal privilege for the self-assessment audit.
Evaluation vs. Audit – The difference between an evaluation and audit can only be determined by looking outside of ISO 14001. Consulting a dictionary reveals that an evaluation involves a determination of value or worth and that an audit is an examination of accounts done by persons appointed for the purpose. A better definition `is the more specific ISO 19011:2002, Guidelines for Quality and/or Environmental Management Systems Auditing, which defines an audit as a “systematic, independent, and documented process for obtaining audit evidence and evaluating it objectively to determine the extent to which the audit criteria are fulfilled.” Many organizations do not have a system for evaluating regulatory compliance other than their own records and the inspections of regulatory officials. This lack of a verification system can be a risky way to operate. Reports of enforcement actions and consent agreements show that many organizations are blindsided by rogue employees who violate rules and falsify documents to cover up environmental misdeeds. Although ISO 14001 does not prescribe a specific approach to evaluation of regulatory compliance, organizations should consider methods for going beyond verification of records by collecting and evaluating physical evidence.

Wednesday, August 26, 2009

Understanding the ISO 14001 Standard

ISO 14001 is an international voluntary standard that specifies the minimum elements for an environmental management system. It was published in 1996 by the International Organization for Standardization and is being taken up by organizations throughout the world at varying speeds.

The above is accepted as true by most people who are aware of the standard. Beyond these simple facts, however, there are many misconceptions about ISO 14001. For instance:

ISO 14001 will be a requirement for all companies.
As with ISO 9000, conformance to ISO 14001 may become a condition of doing business in certain countries, regions or markets. This process already has begun in some industrial sectors, such as the automotive and electronics markets. However, there are still a tremendous number of companies in business today that do not conform to ISO 9000, even though that standard is now 13 years old. Thus it is too early to tell how widely ISO 14001 will be required in the future.

Implementing ISO 14001 means getting a registration.
Many suppliers choose to demonstrate conformance to ISO 14001 through third-party certification. Some customers may require this. However, the standard itself considers a company’s self-declaration of conformance as an acceptable alternative. Further, some companies simply use the ISO 14001 model for internal purposes as a means to enhance their environmental performance.

ISO 14001 is just paperwork and won’t really help my company.
ISO 14001 is like many things in life – you get out of it what you put into it. The way a company implements the standard determines what benefits it receives. Many companies that have implemented ISO 14001 report a variety of benefits, including improved environmental performance, greater operating efficiency, cost reduction, improved employee awareness and enhanced public image, among others.

Implementing ISO 14001 means throwing out our current environmental programs.
ISO 14001 criteria specify “what to do,” not “how to do it.” Implementation approaches vary widely. There is no reason to think that your existing approach to environmental management must be put aside to satisfy ISO 14001.

Monday, August 24, 2009

Commitment and Environmental Policy

An environmental policy is a statement of the organization’s overall aims and principles ofaction with respect to the environment, including compliance with all relevant stakeholders. As such, it should be written clearly and concisely to enable a
regulatory requirements. It is a key tool in communicating the environmental priorities of your organization to employees at all levels, as well as to external layperson to understand it, and should be made publicly available. It is up to the organization to decide on environmental priorities based on an initial environmental review, but these choices should be justified in the policy. To be truly effective the policy should regularly be reviewed and revised and incorporated into the organization’s overall corporate policy. The policy statement should set in writing a few achievable quantifiable priorities related to the environmental management system and the significant environmental effects found at the work-site. Furthermore, EMAS requires that the most signifcant environmental effects be mitigated within three years. Some form of improvement must also be accomplished from year-to-year by the organization and must be shown in the annual reports.

Although the formulation of policies and clear priorities is the most important step of
environmental management, this step is often neglected. Many top managers feel pressure to do something for the environment and thus embark on some form of ?Environmental activism?E often containing many isolated activities but no clear direction. For an organization to be a credible and efficient environmental performer and to reap the benefits of being an environmental leader in its markets, the rationale for investing in environmental management must be very clear.

To ensure an organization’s commitment towards a formulated environmental policy, it is
essential that top management is involved in the process of formulating the policy and of setting priorities. Therefore the first step is to get the commitment from the highest level of management. Based on this commitment the organization should then conduct an initial environmental review and draft an environmental policy. This draft should be discussed and approved by the board of directors. Finally, the approved environmental policy statement must be communicated internally and made available to the public.

As the environmental policy establishes an overall sense of direction and sets the principles
of action for an organization, it requires commitment from the highest level of management. Top management should be involved in the development and adoption of an environmental policy.

Getting the commitment from the highest level should be argued on the basis of costs and the implementation of an EMS increases shareholder value it is easier for top
benefits and their impact on shareholder value. If management to commit themselves to approving an environmental policy and to implementing an environmental management system. This commitment includes three basic policy statements:
Continuous improvement in environmental performance
Compliance with environmental regulations



Maintaining public relations regarding environmental issues of the organization, its activities, products and services.

The central focus of the policy should be a commitment to continuous improvement. This

means improvement in the EMS itself and a decrease in environmental impacts caused by an organization’s activities, products and services. It is important for businesses to show improvement over time, both in environmental performance and in organizational commitment to this path.

A commitment to comply with at least local environmental regulations is a minimum
requirement for all of the environmental standards. However, multinationals operating in various environments and facing different laws in each, should think about which laws to abide by and if it is feasible to adopt the same standard worldwide. Generally, laws in newly industrializing countries are lax as compared to industrialized countries. However, given the increase in interest in environmental issues in these industrializing countries and the possible impact of the ISO 14000 series, it may be sound practice to adopt the more stringent laws in worldwide operations, where it is feasible to do so. In addition, the adoption of high standards worldwide can yield other benefits, such as an improved public image or easier technology transfer between different sites.

Companies should guard against going overboard in fulfilling environmental policies. Limits
are in fact set on how far a company has to go to reduce its environmental impacts. Reductions do not have to exceed levels which can be achieved by economically viable application of the best available technology (BAT).

Saturday, August 22, 2009

ISO 14000 – Environmental Program Management

The ISO 14000 series of standards has
received widespread attention, and, like ISO 9000, it is becoming a requirementfor domestic and global organizations.
This document is intended to provide a
baseline understanding of the ISO 14000 standards and to discuss the current status of this important standard.
The International Organization for Geneva, Switzerland, is composed of 92 European Union (EU) to establish universal quality standards. Over time, ISO
Standardization (IOS), headquartered in member countries. Adherance to standards developed by the IOS is voluntary. However, countries and industries may adopt the IOS standards. Until approximately 15 years ago, IOS focused on traditional standards-setting activities. In 1987, IOS published the ISO 9000 series standards that were used with the 9000 became recognized as a positive indicator of quality and a prerequisite to establishing/maintaining business relationships within and outside the European Union.
In the United States, both the American
National Standards Institute and the American Society of Quality Control are privately funded organizations that have adopted ISO 9000, Quality Management, and the ISO 14000 standards.
ISO 14000 is the generic title given to 14040, ISO 14041, and ISO14050 have
the 14000 series of standards. ISO 14001, ISO 14004, ISO 14010, ISO 14011, ISO 14012, ISO 14020, ISO been published as international standards. The ISO 14000 series of standards consists of the following 18 subjects that can be grouped under two major headings:
14001 Specification with Guidance for Use
14004 General Guidelines on Principles,
14010 General Principles of Environmental Auditing
14011 Audit Procedures
14012 Environmental Auditing ? Qualification Criteria
14015 Environmental Site Assessments
14031 Evaluation of Environmental Performance ? Guidelines
14032 Evaluation of Environmental Performance ? Case Studies
14020 Goals and Principles of All Environmental Labeling
14021 Environmental Labels and Declarations ? Terms and Definitions
14024 Environmental Labels and
14025 Type III Labeling
14040 Life Cycle Assessment ? Principles and Framework
14041 Life Cycle Assessment ? Inventory Analysis
14042 Life Cycle Assessment ? ImpactAssessment
14043 Life Cycle Assessment ? Interpretation
14048 Life Cycle Indicator Format
14050 Guide on the Principles of Terminology Work

At the current time, the ISO 14000 as International Standards are referred to
Standards that have not been published as Draft International Standards (DIS). Most DIS are in the final review period before publication. If a particular standard is of interest and is not final, a copy of the DIS may be available for review.

Thursday, August 13, 2009

Environmental Aspects (ISO 14001:2004, 4.3.1)

The requirement of ?4.3.1 of ISO 14001 is to establish and maintain procedures 1) for identifying the environmental aspects of the organization’s activities, products, and services that it can control and those that it can influence and 2) for determining which of those aspects have or can have a significant impact on the environment. Understanding the requirement of this element of ISO 14001 is central to understanding the concept of an environmental management system.
1 .A single manufacturing facility has potentially hundreds of environmental aspects. How far must it go in identifying its environmental aspects to satisfy the terms of the requirement? ISO 14001 specifies that the organization is to identify those aspects that it can control and those that it can influence and that it must also take into account planned or new developments and new or modified activities, products, and services. These stipulations in the requirements, without actually drawing boundaries on how far the organization must go in identifying environmental aspects, at least establish some categories of aspect that must be considered. Beyond this principle, each organization must identify its aspects comprehensively enough so as to not fail to identify a significant aspect or a legal requirement. An objection to comprehensive identification of aspects is that the organization may become so immersed in aspects identification that it loses sight of the end objective of the procedure, which is to determine significance.
2. Significant impact is not a stand-alone term in ?4.3.1.
It is accompanied by the phrase impact on the environment_ and environment_ is a defined term (see definition of environment, ?3.5). Significant aspects, then, are those environmental aspects that have or can have significant impacts on air, water, land, natural resources, flora, fauna, and humans. The organization determines, using its own criteria, what magnitude of impact on these seven environmental receptors constitutes a significant impact. Whether an aspect is regulated is not intended to be a factor in determining significance.
3. Proper execution of the environmental aspects procedure is important, in part, because it lifts environmental management out of the regulatory compliance mode and into the mode of systematically identifying environmental aspects and impacts and considering their consequences for the environment, irrespective of regulation. The organization that rigorously applies the environmental aspects procedure discovers many opportunities to improve environmental performance that regulation does not address, including:
• Use of energy
• Consumption of materials
• Environmental impacts of employee activities
•Environmental impacts of products and by-products post-manufacture, including distribution, use, reuse, and disposal
• Environmental impacts of services
• Unregulated waste streams such as carbon dioxide
Aspects vs. Impacts – Environmental aspects and environmental impacts differ by definition from one another in that an aspect is an element of an organization’s activities, products or services that can interact (emphasis added) with the environment_ while an impact is any change (emphasis added) to the environment_ resulting from an organization’s environmental aspects._ An aspect, then, is a precursor to an impact and an impact occurs when the aspect interacts with and changes the environment.
When identifying its aspects and impacts, the organization may find that there are more than one potential impacts associated with any given aspect. For example, an environmental aspect of a coal-fired power generation facility is stack emissions containing sulfur dioxide, nitrogen oxides, mercury, and carbon. These emissions change the environment and become impacts by contaminating plants, soil, and surface waters; contributing to the formation of ground-level ozone; causing or exacerbating heart and lung disease in humans; entering the aquatic food chain and impairing reproductive, immune, and endocrine systems; and contributing to the increase in atmospheric carbon dioxide leading to global warming. One aspect, stack emissions, then can generate at least five impacts.
Other organizations, applying benefit/cost analyses to their corrective actions, may discover that creation of a beneficial impact provides a greater environmental benefit than elimination of an adverse impact.
The introduction of the beneficial environmental impact concept into the ISO 14001 Terms and Definitions suggests that it was considered by some of the ISO 14001:1996 drafters as a placeholder for the future possibility of offsetting adverse impacts with beneficial and, on balance, achieving an environmentally neutral organization.
Control and Influence – The environmental aspects procedure requires the organization to identify those environmental aspects that it can control and those that it can influence._ Circumstances where control and influence are considered separately can occur where the environmental aspects of products or services are concerned. Some examples illustrate the case:
1. No control, no influence – When an organization manufactures a product, such as lumber, and sells it to a customer that can use the product in any way that it wishes, the organization has no control over the environmental aspects of the product’s use. The customer could use the product benignly as in the manufacture of a table or to damage the environment by burning the lumber and releasing its carbon into the atmosphere. In this case, the organization would not be expected to have either control or influence over the environmental aspects of the product.
2. Control, no influence – When an organization’s environmental aspect is the use of electric power generated from coal, it may be able to control its use of electric power by using less, by buying from a different, less environmentally damaging source, or by generating its own power. Rarely, however, does the organization have influence over the power generator to an extent that it could influence it to reduce the environmental impacts of power production.
3. Influence, no control – When an organization manufactures a product, such as an automobile, which is sold to the customer without restrictions on its use, the organization may be said to have no control over the environmental aspects of the product’s use. The organization may, however, be able to assert influence with the inclusion of owner’s manuals containing instructions for low impact use of the product.
4. Control and influence – When an organization buys a product built to its specifications, it has control over the products’ environmental aspects in the sense that it can determine the environmental aspects of the product. In this case, control also includes influence.
Significant Impacts – ISO 14001 does not provide guidance as to what constitutes a significant impact on the environment_, leaving that determination to the organization.
Many organizations ignore the qualifying phrase, impact on the environment_, and add additional criteria to what they determine to be significant impacts. For example, many organizations decide that aspects that are the subject of regulation, irrespective of impact to the environment, or that can cause damage to business reputation, are significant. Legal requirements, however, are identified in ?4.3.2 and legal requirements and business requirements are specifically considered when the organization establishes its objectives and targets (?4.3.3). Adding criteria that are not relevant to impact on the environment in the determination of significance distorts the outcome of procedures for environmental aspects and objectives and targets by giving these criteria undue weight in the determination of significance. For example, an environmental aspect that is significant only because its disclosure might affect the organization’s reputation is best dealt with in the Public Relations Department rather than as an environmental aspect.
Determination of significance is a yes or no question, not a determination of relative value. It is possible, therefore, that the execution of the environmental aspects procedure will result in the determination that the organization has no significant aspects. While the organization may elect to rank its aspects from most significant to least significant, that does not necessarily mean that any rise to the level of significant impact on the environment.
Where the impact occurs can be material to determination of significance. For example, a coal-fired power plant’s air emissions can interact with the environment; these emissions are clearly environmental aspects. Whether they significantly impact the environment may depend upon where the interaction with the environment occurs.
Part of the importance of establishing significance lies in the fact that the potentially significant environmental impacts become a focus of Objectives and Targets (?4.3.3), Competence (?4.4.2), Operational Controls (?4.4.6), and Monitoring and Measurement (?4.5.1) requirements.
An organization that determines that aspects are significant because of regulation or business reputation increases the amount of work it must do in these areas.
ISO 14001 does not require the organization to establish objectives and targets for each significant environmental aspect. On the one hand, the absence of a requirement to set objectives and targets for all significant aspects gives organizations latitude to conform to the requirements of ISO 14001 while not presently dealing, for example, with the significant environmental aspects of products. On the other, a requirement to establish objectives and targets for all identified significant aspects could easily overwhelm an organization having many significant aspects. Without this latitude, organizations might choose to ignore the existence of significant aspects that they believe are insurmountable or even decide not to implement ISO 14001. As it is, many organizations choose to deny the existence of significant aspects about which they feel they can do nothing.

EMS Documentation

ISO 14001 Section 4.4.4, EMS Documentation, requires that organizations “. . . establish and maintain information, in paper or electronic form, to: 1. describe the core elements of the management system and their interaction; 2. provide direction to related documentation.”
ISO 14001 Section 4.4.5, Document Control, requires that organizations establish and maintain procedures to control all documents required by ISO 14001. The purpose of these document control procedures is to ensure that organizations create and maintain documents sufficient to implementing an EMS.
The procedure must ensure that:
EMS documents can be located
EMS documents are legible, dated (with dates of revisions) and readily identifiable
• EMS documents are maintained in an orderly manner and retained for a specified period
• EMS documents are periodically reviewed, revised as necessary, and approved for adequacy by authorized personnel
• The current versions of relevant documents are available at all locations where they are necessary
• Obsolete documents are promptly removed from all distribution points
• Any obsolete documents retained for legal and/or knowledge preservation purposes must be identified as such.
ISO 14001 Section 4.3.5 also requires that organizations establish procedures and designate responsibilities and
authority regarding the creation and modification of EMS documents.