790 Environmental Management Systems (EMS)

Step 16: Implement Operational Controls

The organization should implement the operational controls identified under Step 10 to minimize environmental impacts. They should document which operational controls are in place for each aspect, especially the significant environmental aspects (SEAs). These operations must be carried out in a way that ensures consistency, safety, and environmental responsibility. This step builds directly on the significant environmental aspects (SEAs) identified earlier, particularly in Step 10.

Key Actions to Take:

1. Identify Activities Requiring Control: Review the company's SEAs and identify which activities or operations could lead to significant environmental harm if not properly managed. These may include:

• Handling and storage of hazardous materials
• Waste disposal processes
• Equipment maintenance that may release pollutants
• Use of energy-intensive machinery

2. Develop Written Procedures: Create documented procedures for each activity identified. These procedures should clearly outline:

• The correct steps to perform the activity
• Who is responsible for the task
• What equipment or PPE is required
• What to do in case of deviations or emergencies

3. Involve the Employees Doing the Work: Procedures should be written with direct input from the workers who perform the tasks. This helps ensure accuracy, relevance, and employee buy-in. Consider:

• Holding a workshop to draft procedures collaboratively
• Testing procedures in real scenarios before finalizing

4. Use a Consistent Format: To make procedures easy to follow, maintain a uniform layout across all documents. A consistent format should include:

• Title and procedure number
• Purpose and scope
• Definitions (if necessary)
• Step-by-step instructions
• Responsibilities
• Recordkeeping requirements

5. Train and Communicate: Make sure all affected employees are trained on the procedures. This may include:

• On-the-job training
• Safety meetings or toolbox talks
• Visual aids and posted instructions in the work area

6. Document the Operational Controls: Maintain records of all operational controls, especially those related to SEAs. Documentation should include:

• Procedure documents and version control
• Training records
• Inspection and monitoring results

7. Monitor and Update Procedures: Operational controls are not "set it and forget it." Regularly review and update procedures as needed, especially when:

• Equipment or processes change
• New regulations or best practices emerge
• Issues or nonconformities are identified during audits

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