How to define the ‘Scope’ of your environmental management system

19 February 2015

The scope of your Environmental Management System (EMS) is a short paragraph in your environmental policy and possibly your manual, but one that your entire management system is pinned on. It’s really important that you get it right, that every word is carefully selected and that it sets out the boundaries of which activities and locations your EMS applies to.

ISO 14001:2004 guidance A.1 is clear when it states: “Defining the scope is intended to clarify the boundaries of the organization to which the environmental management system will apply. When setting the scope, it should be noted that the credibility of the environmental management system will depend upon the choice of the organizational boundaries. If a part of an organisation is excluded from the scope of its environmental management system, the organisation should be able to explain the exclusion.”

I sometimes come across manufacturing companies whose scope starts something like ‘The design, manufacture and distribution of components to...’. When questioned, it’s apparent that the design part of their process is carried out by a third party, which they have limited influence. Therefore, to keep the word ‘design’ in their scope, the EMS must cover all elements of that third party’s activities. This is an example of a company’s mission statement being used as the scope without realising the implications. In that instance it may be best to remove the word ‘design’ from the scope.

Conversely excluding activities from scope must also be justified, as the guidance explains. You should be able to explain any exclusions, especially if it’s from an auditors perspective, so it appears to them as if that element of the business is key to its operation. That is not to say that you can’t exclude elements from scope. It may be that certain activities are carried out by a different legal entity on your site, or that part of your operations are carried out by a different group of companies over which you have no influence (transport and logistics is a common example).

Try also not to fall into the trap of simply writing: ‘Applies to all activities within the company’. This is a very vague statement and is difficult to audit as there are no clear boundaries as to what is included. It may be that for a single site company it does include all activities on that site, but if that’s the case, then a precise scope detailing those activities would be best.

You may also need to consider third party activities over which you do have some influence. Where that’s the case, it can be included in the scope.

Remember that the decision about your scope must be made within the contact of your environmental impacts, so it may be best drafting a scope first, and then revisiting it once you have identified your organisation’s aspects, impacts, and legal requirements.

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