The release of ISO 14001:2004 has introduced the term “all persons working for or on behalf of the organization”, and as a result expanded the scope of environmental management systems to more closely account for the actions of people other than the organization’s own employees.
Specifically, this new term arises in the following sections:
4.2 Environmental Policy, where it states that the policy is communicated to them
4.4.2 Competency, Training and Awareness, where it states that they need to be competent if they perform tasks that have the potential to cause significant environmental impacts
4.4.2 Competency, Training and Awareness, where it states that they need to be aware of the policy, environmental management system (EMS), significant environmental aspects, their roles and responsibilities, and so forth.
As organizations work to update their management systems, it is timely to discuss these requirements in greater detail. QMI included the following clarification in its document describing the changes to the standard, but a fuller discussion is valuable.
Organizations should ask themselves “Who works on our behalf?” Some of the people who come to mind are: contractors, visitors, suppliers, suppliers for outsourced operations, temporary personnel and agents.
Which of these truly work on the organization’s behalf and now need to fall under the scope of the 4.2 and 4.4.2 requirements of the standard?
This is a varied group, often managed by different personnel in the organization and managed through different means. The most effective method will need to be used to ensure that these individuals are competent, aware and trained, and appropriate records retained. In some cases you may choose to deal with the person directly, and in other cases the organization may be more appropriate to deal with the organization that employs the person.
- q Contractors most likely. They tend to come on-site to perform specific services upon request.
- q Visitors probably not, but it depends on the definition of visitor. In reality, they are often considered belonging in another one of these categories if they are working on the organization’s behalf.
- q Suppliers (other than contractors) will often not be considered working on the organization’s behalf. In most situations, suppliers will be manufacturing product for the market, not specifically for the organization. Situations where there is a more direct relationship, such as through a specific contract for a particular product or service, such as when suppliers are stationed permanently on-site, could be considered working on the organization’s behalf. Note that there are other controls required as per 4.4.6c (Operational Control relating to suppliers, including contractors).
- Outsourcing is a variation on the above, and the supplier will generally be considered working on the organization’s behalf. In this case, the organization has contracted another firm to conduct specific work for them, work that they would have done otherwise.
- Temporary workers may not be direct employees, but the organization has brought them onsite to conduct work, and they are working on its behalf.
- Agents represent the organization in the marketplace. The organization has contracted them to work on its behalf.