What is operational control?
There are certain activities within an organisation that from an environmental perspective require some control. This is usually as a result of them posing a significant risk to the environment. The term ‘operational control’ comes from the ISO 14001:2105 standard, but organisations in practice implement operational control in many ways with vastly differing names. For example, safe systems of work, work instructions, method statements and check sheets are all names that I have come across over the years.
What significant impacts require control will vary between organisations, but common activities include the management of waste, purchasing and maintenance. Not necessarily every activity needs formal control. But some most definitely do if they could either directly or indirectly significantly cause harm to the environment.
How to determine what requires control
A good systematic structure to adopt when looking at what requires control is to consider the significant aspects and impacts of the organisation. You could argued that if an aspect is significant it needs some form of control. To determine operational controls in a systematic way we firstly need to complete an environmental aspects and impacts assessment.
Other parts of the EMS will also inform about issues that require control. In your environmental policy for example, you might mention specific commitments such as reducing waste or minimising greenhouse gas emissions. If so, these issues will require operational control.
Compliance obligations will also often need operational control. For example, there are many laws surrounding the management of waste and to increase the chance of compliance there will often need to be a suite of operational controls, such as a documented waste procedure. Compliance obligations will often state in a great amount of detail what should be included in an operational control to cover a certain workplace activity.
Guidance on control
If we are thinking about operational control from an ISO 14001 point of view, the standard gives us some ideas about what is needed. Firstly, the standard states that control can be procedural or engineering. For example, they may be a documented approach to control (procedural) or might involve procuring equipment (engineering). The standard also states that the following hierarchy might be used (bear in mind a mix of these categories of control are often needed):
- Elimination – the control(s) will total remove the risk
- Substitution – the control(s) will use a mechanism to reduce the risk by using an alternative.
- Administrative – there is a set way of carrying out a task that is usually documented such as a procedure.
This tells us that operational control does not necessarily have to be a document of some kind. It could be physical or technical control such as a pollution abatement device. The standard also states that controls should be ‘consistent with a lifecycle perspective’. So there is some need, at least for ISO 14001, for controls that cover actions such as development of processes, products or services, procurement, and some form of communication of relevant environmental information to contractors.
When determining what specifically should be controlled, we need to think about the parameters that require control. For example, the key process steps that present a significant environmental risk. Then we need to consider what needs to be done to control these parameters. Finally, we need to think about checks, tests or measurements surrounding the controls that are needed so it can be determined whether the control is effective. Remember operational controls do not necessarily have to be procedures. They can be technical or take the form of worksheets, flowcharts, instructional videos, or posters.
The need for operational control is clear; we must ensure that environmental risks do not lead to significant harm. Key areas that require controls include activities associated with significant impacts, policy commitments and compliance obligations. There is much guidance in the ISO 14001:2015 standard as to what op. controls should cover.
John Binns BSc (Hons), MSc, MIEMA
With over 19 years’ experience working in environment management, John Binns BSc (Hons) MSc MIEMA is an experienced environmental tutor and consultant with knowledge of health and safety management.