Operational controls in an environmental management system

Operational controls in an environmental management system (EMS) reduce the risk that the organization will not achieve its environmental objectives. Operational controls are the processes that management implements to provide reasonable assurances that the organization will achieve its environmental objectives.

Operational controls include five components, consistent with the Internal Control – Integrated Framework (2013), from the Committee of Sponsoring Organization of the Treadway Commission (COSO). The following five components must operate harmoniously for operational controls and the EMS to function effectively:

1. Control environment is the combined culture, ethical values, and competence of the board and employees involved in EMS activities. See Operations and Marketing PolicyPro (OMPP), at OP 5.08 – Training and Other Supports and Chapter 5 – Environmental Management, generally.
2. Risk assessment includes the processes that identify and assess EMS risks. See Chapter 5 – Environmental Management, generally.
3. Control activities are the policies and procedures in place to ensure that the organization can meet its EMS objectives. Control activities may include engineering controls or administrative controls. See OMPP at OP 5.10 – Operational Controls.
4. Information and communication systems identify, capture, and communicate information externally and internally so that individuals and the organization can meet objectives. See OMPP at OP 5.07 – Document Control, OP 5.08 – Training and Other Supports, and OP 5.13 – Non-conformity and Corrective Actions, for example.
5. Monitoring includes routine or ongoing management and supervisory activities, and separate periodic evaluations (for example audits) that assess the effectiveness of operational controls. See OMPP at OP 5.11 – Monitoring and Control, OP 5.12 – Internal EMS Audits, and OP 5.14 – Continual Improvement.

Two broad types of operational controls exist in an EMS, namely, engineering controls and administrative controls, can address the five components above. An engineering control is a direct technical or frontline procedure, process, or practice that operates close to environmental aspects to manage environmental risks. Environmental aspects are the activities, products, or services that could impact the environment. A pressure relief valve on a piece of equipment is an engineering control. Emergency shutoff systems, wastewater or effluent treatment plants (ETPs), and containment walls are also engineering controls. Pigging technologies, which clean industrial pipes using projectiles instead of wasteful alternatives like water and solvents, is another example of an engineering control.

Administrative controls are less direct and refer to the procedures, practices, and processes in the overarching framework that manages environmental risks. Administrative controls include written policies and procedures, training, and supervision.

Operational controls may be preventive or detective. Preventive controls thwart or block negative environmental impacts, whereas detective controls highlight negative impacts as they happen or after. An emergency shutoff system is one example of a preventive operational control. A smoke alarm and a leak detection system are examples of detective controls.

Meeting your duty of care

Implement effective operational controls to reduce the risk that the organization fails to meet its EMS objectives. Review Clause 8.1 – Operational Planning and Control in International Organization for Standardization (ISO) 14001:2015.

Log in to Operations and Marketing PolicyPro, which includes a new policy, OP 5.10 – Operational Controls, for the policies and other tools to help you implement and sustain effective environmental management programs based on ISO and other standards.

Read more on operational controls in non-EMS contexts in Not-for-Profit PolicyPro at  SPP NP 1.17 – Internal Controls or in Volume II of Finance and Accounting PolicyPro at Chapter 6 – Internal Controls.

Policies and procedures are essential, but the work required to create and maintain them can seem daunting. Finance and Accounting PolicyPro, Operations and Marketing PolicyPro, Not-for-Profit PolicyPro, and Information Technology PolicyPro, co-marketed by First Reference and Chartered Professional Accountants Canada (CPA Canada), contain sample policies, procedures, checklists and other tools, plus authoritative commentary to save you time and effort in establishing and updating your internal controls and policies. Not a subscriber? Request free 30–day trials of Finance and Accounting PolicyPro, Operations and Marketing PolicyPro, Not-for-Profit PolicyPro, and Information Technology PolicyPro, here.

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Apolone Gentles, JD, CPA,CGA, FCCA, Bsc (Hons)

Apolone Gentles is a CPA, CGA and Ontario lawyer and editor with over 20 years of business experience. Apolone is leveraging 20 years of business and accounting experience to build a commercial litigation practice with an emphasis on construction law. She has held senior leadership roles in non-profit organizations, leading finance, human resources, information technology and facilities teams. She has also held senior roles in audit and assurance services at a “Big Four” audit firm. Apolone has also lectured in Auditing, Economics and Business at post-secondary schools.

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