When an organization starts considering certification of its environmental or occupational health and safety management systems, the question often arises, â€œWhat kind of training program do we need to have in place to be certified?"
Most often, this question is asked when pursuing third-party certification to the environmental management system (EMS) standard developed by the International Organization for Standardization â€” ISO 14001:2004, Environmental Management Systems â€“ Specification with guidance for use. 1
The short answer is that ISO 14001 does not require training. What is required is a procedure (i.e. a process) to ensure that individuals are aware of the environmental issues associated with their work and competent to perform tasks with environmental impacts. The focus of ISO 14001 is on the results that must be accomplished, awareness and competency, not a particular method for accomplishing them, e.g. training.
The word â€œtraining" is instead used as a shorthand way of referring to the requirements of section 4.4.2 of the ISO 14001 standard.
In some ways, this change in focus makes establishing a training program easier. If you are competent, you do not have to sit through repetitive or marginally useful training programs. Yet in other ways, this makes establishing a training program more difficult. How do you ensure awareness or competency? How do you prove it in the context of a third-party audit situation?
One thing is certain: simply producing training class sign-in sheets with illegible signatures is not sufficient to show conformance to the ISO 14001 standard.
ISO 14001:2004 requirementsSection 4.4.2 of ISO 14001:2004 sets out three main training requirements that must be met for an organization to become certified:
- Individuals who perform tasks that have the potential to cause a significant environment impact need to be "competent on the basis of appropriate education, training or experience."
- The organization must identify its training needs and provide â€œtraining or take other action to meet these needs." (emphasis added)
- The organization must establish a procedure to make individuals working for it aware of the environmental management system (EMS), the environmental policy, the significant environmental aspects and impacts associated with their work, their roles and responsibilities associated with the EMS and the potential consequences of departure from specified procedures.
Ensuring competenceCreating awareness is often relatively straightforward. What is often more difficult is ensuring competency. Competency relates to what you can do rather than simply what you know â€” hands-on skills as opposed to book knowledge. It is the fit between an individualâ€™s abilities and the job to be performed. The competency requirements that must be addressed in an EMS relate specifically to the environmental aspects and significant environmental impacts that have been identified by the organization. You must identify your environmental aspect and impacts in order to identify your competency requirements.
Identify training needsThis is where the second training requirement of ISO 14001:2004 comes into play â€” the need to identify training needs. There are four different types of training needs that must be identified:
- training to ensure competency to perform tasks with potential environmental impacts;
- training to meet ISO 14001 awareness requirements;
- training that is required to be in compliance with legal requirements; and
- training needed to carry out the responsibilities assigned within the management system.
Just as you canâ€™t ensure individuals are competent unless you have identified your competency needs, you cannot establish â€œawareness" procedures without first identifying your awareness requirements. Similarly, it is difficult to be in compliance with legal requirements unless you have specifically identified what those requirements are. In addition, you canâ€™t identify your management system training needs unless you have clearly identified who is responsible for what tasks.
Once you have identified what your requirements are, you can then determine the best way of demonstrating individual competency. As set out in the ISO 14001 standard, this may be through training or it may be through appropriate education or experience. An individual may be determined to be competent because they are licensed or certified by an appropriate third-party. For example, outside contractors performing work on HVAC systems often demonstrate their competency for working with ozone-depleting chemicals by providing a copy of their state license.
Implement your training programISO 14001 not only requires that procedures and processes be established, but also that they are implemented and maintained. It is not enough to identify training needs, develop training materials and hope for the best. Your training procedures need to ensure the competency and awareness of not just your employees but also of temporary workers, outside contractors and their employees â€” anyone working for or on behalf of the organization. As anyone who has managed a training program can attest, ensuring that each individual has the requisite competency and awareness can be a difficult logistical task. It typically requires that some sort of tracking and follow-up system be put in place, and that any records which are generated are controlled in accordance with your record control procedures.
Finally, as part of the internal audit program, an evaluation must be done periodically to determine whether the training procedures have been implemented and maintained. This internal evaluation is one of the inputs used by top management to determine the continued suitability, adequacy and effectiveness of the overall environmental management system.
Sidebar: Beware of â€œgrandfathering in"One method sometimes used to qualify individuals in quality management systems is the so-called â€œgrandfathering in" of employees. This approach, however, does not necessarily ensure competency for purposes of an environmental management system. In this approach, employees are deemed to be competent simply because they have held a certain job for a certain period of time. Unfortunately, having performed a job for a certain length of time does not necessarily equate to having the required knowledge and skills to ensure that the environmental impacts of the job are minimized.
1 Although this article focuses on the requirements of ISO 14001:2004, the principles and the focus on competency and awareness as the measures of the adequacy of a training program are similar for OHSAS 18001 and ANSI/AIHA Z10.