Env Fs Guidance

GUIDANCE FOR APPLICATION OF
THE UNILEVER SHE FRAMEWORK STANDARDS
ENVIRONMENTAL CARE
VERSION I
Written by Damien Williams, Bob Diprose and Roy Willey on behalf of the “Framework
Standards” Team
Team Members
Mike Bazley
Mike Curtis
Bob Diprose
John Fullard
Joao Senise
Roy Willey
Damien Williams
2
CONTENTS
1. Introduction
1.1 General Requirements

1.2 Application
1.3 Unilever Organisations
2. Environmental Policy
3. Planning
3.1 Significant Environmental Aspects
3.2 Legal and Other Requirements
3.3 Objectives and Targets
3.4 Environmental Management Programme
4. Implementation and operation

4.1 Structure and Responsibility
4.2 Training, Awareness and Competence
4.3 Communication
4.4 Documentation
4.5 Document and Data Control
4.6 Operational Control
4.7 Emergency Preparedness and Response
5. Checking and Corrective Action

5.1 Performance Measurement and Monitoring
5.2 Incidents, Non-conformances, Corrective and Preventive Actions
5.3 Records and Records Management
5.4 Environmental Management System Audits
6. Management Review
Structure of Sections
Sections 2-6 of the guidance are structured as follows:
(a) Framework Standard

(b) Guidance to Meet the Framework Standard
(c) Guidance for Certification to ISO 14001
(d) Reference to Specific Standards and Further Guidance
(e) Cross-references (within this guidance)
(f) Flow Chart of Requirements
Guidance for the application of SHE Framework Standards – Environmental Care Version I 20.6.2000
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1. INTRODUCTION
1.1 General Requirements
An environmental management system (EMS) is an organisational framework that should be

planned according to an established policy, implemented, continually monitored and
periodically reviewed. It should provide effective direction for an organisation’s
environmental activities both proactively and in responding to changing internal and external
factors.
It should be structured according to the Deming cycle: PLAN -> DO -> CHECK -> REVIEW
Key Elements
The key elements are summarised below and illustrated in Figure 1:
1 - Policy
The organisation should define its environmental policy and ensure commitment to its EMS.
2 - Planning (PLAN)
The organisation should formulate a plan, including objectives and targets, to fulfil its
environmental policy. A fundamental part of the planning stage is an identification and
evaluation of the organisation’s environmental aspects. This document mainly covers
environmental aspects associated with pollution or waste emissions from the organisation. A
separate guidance document on the environmental aspects of products and packaging is to
be developed.
3 - Implementation and Operation (DO)

For effective implementation, the organisation should develop the capabilities and support
mechanisms necessary to achieve its environmental policy, objectives and targets.
Implementation includes putting in place systems for operational control of the significant
environmental aspects identified at the planning stage.
4 - Checking and Corrective Action (CHECK)

The organisation should measure, monitor and evaluate its environmental performance and
management system. The organisation should take steps to correct deviations and non-
conformances.
5 - Management Review (REVIEW)

An organisation should review and continually improve its environmental management
system, with the objective of improving its overall environmental performance.
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Figure 1 Continual improvement cycle
Start
Management Environmantal
Review Policy
Continual
Improvement
Checking/
Corrective Action Planning
Implementation
and operation
1.2 Application
There are currently three sets of Unilever Safety Health and Environment (SHE) Framework
Standards: Occupational Health & Safety, Environmental Care, Consumer Safety. This
guidance document provides the top-level guidance in support of the Unilever SHE
Framework Standards which relate to environmental care. Guidance is also given for those
organisations who wish to obtain IS0 14001 certification.
The following points are important, and are quoted from the Environmental Care Framework
Standards:
 The Unilever SHE Framework Standards are applicable to all organisations (see
Section 1.3 below) within Unilever. Taken together they describe a complete SHE
Management System.
 Unilever SHE Standards which are more limited in scope, i.e. those which apply to a
particular type of organisation such as Foods or HPC, or deal with a specific business
risk, will be published separately as Unilever SHE Specific Standards, and separate
supporting guidance will be provided.
 Within Unilever, SHE Framework Standards and SHE Specific Standards have the same
status as Unilever “Enabling Instructions” i.e. they are mandatory.
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Each organisation will need to decide the extent of the environmental management system it
is to put into place, in particular
 to meet the requirements of the Unilever environmental care framework standards, and
over what timescale (this would normally be decided by consultation with the parent
organisation)
 whether in addition, to fulfil the additional requirements for certification to ISO 14001
For ISO 14001 certification, the scope of the environmental management system will need to
be agreed with the certifying body to indicate the management processes and activities that
are going to be included in the certification assessment.
Compliance with some of the Environmental Care Framework Standard requirements can be
achieved using TPM. See Appendix I for examples.
1.3 Unilever Organisations
This guidance document uses the word “organisation” in the same way as the Unilever SHE
Framework Standards, which are quoted as follows:
“The word “Organisation” as used within the Unilever SHE Framework Standards and in this
guidance document means e.g. all Unilever Head Offices, Business Groups, Operating
Companies, Head/Sales Offices, Marketing & Sales Organisations, Business Units, Sourcing
Units, Factories, Plantations, Research Laboratories, Regional Innovation Centres,
Warehouses and Distribution Centres.
The word “organisation” as used within the Unilever SHE Framework Standards does not
apply to non-Unilever operations e.g. third party manufacturers, co-packers etc. Unilever
SHE Standards which relate to non-Unilever operations will be published separately as
Unilever SHE Specific Standards.”
This guidance document has been produced to provide help to the wide range of Unilever
organisations, including:
 administration units, e.g. head offices, corporate centres and marketing/sales

organisations
 technical establishments, e.g. research laboratories, regional innovation centres
 manufacturing units, e.g. sourcing units, factories, warehouses and distribution centres
Where necessary, any differences or adaptations for implementation of the environmental

care framework standards for different types of "organisation" are indicated in the various
sections of this guidance.
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Flow chart of requirements
FRAMEWORK
S TANDARD MEETS FRAMEWORK S TANDARD MEETS IS O 14001
1.
Ge ne ral Enviro nme ntal Manag e me nt S ys te m to me e t the Enviro nme ntal Manag e me nt
Re quire me nts re quire me nts o f the S HE Frame wo rk S tandards - S ys te m to me e t the
Enviro nme ntal c are . re quire me nts o f IS O 14001
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2. ENVIRONMENTAL POLICY
All Unilever organisations must prepare and document an appropriate environmental policy1,
which is consistent with the Unilever environmental policy.
The policy must include:
 a clear statement of overall environmental objectives,

 a commitment to the prevention of pollution
 a commitment to continual improvement
 a commitment to compliance with all applicable legislation and internal Unilever
standards e.g. SHEACO, Business Group, Category and Operating Company.
The policy must be authorised and signed by the most senior person within the organisation.
The policy must be communicated across the whole organisation to ensure that all
individuals2 working for the organisation are aware of their individual and collective rights
and responsibilities.
The policy must be reviewed annually and where necessary revised to ensure that it remains
relevant and appropriate to the organisation.
It is anticipated that many organisations will simply choose to adapt the Unilever environmental policy statement or that of their parent
organisation e.g. Business Group
2
While the term “individuals working for the organisation” includes employees, temporary employees, contractors and sub contractors,
Unilever’s primary duty of care applies to its own staff. Arrangements for other individuals must be proportionate. Unilever organisations
must not take on responsibilities which primarily lie with other organisations or individuals
Key Elements
The key requirements for the organisation’s environmental policy are specified in the
Framework Standard above. These are:
 documented policy
 appropriate content (as specified in the Framework Standard)
 authorised / signed policy
 communication of the policy
 review system
Application
The key steps for the organisation for setting up their environmental policy are:
 obtain a copy of the Unilever environmental policy from the parent organisation (e.g.
Business Group) or from the SHEACO Web Site ( http://upn.unilever.com )
 obtain a copy of the parent organisation’s environmental policy;
 consult with parent organisation and agree whether the organisation needs to create its
own environmental policy statement separate from that of the parent organisation;
 if necessary, create the organisation’s own environmental policy, the contents of which
will need to then conform to the requirements of the framework standard;
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 If appropriate, adopt or adapt the Unilever environmental policy or that of the parent
organisation (see footnote 1), which will then need to itself be clear that it applies to the
subsidiary organisation;
 The organisation’s environmental policy should be appropriate to the nature and scale of
the organisation’s environmental aspects
 Have the policy authorised, as specified in the Framework Standard
Additionally the organisation will need to:

 decide how to communicate the policy to individuals working for the organisation, e.g. in
paper / booklet form, on notice boards, intranet website, in communication exercises
such as team briefings, in induction and training programmes;
 when communicating the policy to individuals, refer to the definition of the term
“individuals working for the organisation” above in 2(a) footnote number 2;
 review the policy annually, and where necessary revise it; this should be part of the
Management Review process as described in Section 6 of this guidance document.
Revisions to the policy should likewise be communicated as described above.
 review the policy after the evaluation of the organisation’s significant environmental
aspects in order to reflect the findings
An example of a model environmental policy can be seen in the Compendium of Good

practice on the SHEACO database included in the Unilever policy network(UPN) web site.
For the organisation to obtain certification of its environmental management systems to ISO
14001, the following will need to be in place in addition to (b) above:
Make the environmental policy available to the public

The environmental policy will need to be available to the public.
The following Specific Standards and additional guidance apply to this topic:
 Compendium of Unilever Policies for Safety, Health and Environment

 SHEACO Compendium of Good Practice
(e) Cross-references
The following sections of this guidance are strongly related to this topic, and should be
referred to:
Section 3.1 - Significant Environmental Aspects

Section 3.3 - Objectives and Targets
Section 6 - Management Review
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(f) Flow chart of requirements
FRAMEWORK
Pre pare and do c ume nt an

appro priate e nviro nme ntal
po lic y.
2. (s e e the s pe c ific re quire me nts
o f the Frame wo rk S tandard)
Enviro nme ntal
Po lic y
Po lic y to be autho ris e d and

s ig ne d by the mo s t s e nio r
pe rs o n within the o rg anis atio n
Co mmunic ate e nviro nme ntal po lic y Make e nviro nme ntal po lic y
ac ro s s the who le o rg anis atio n available to the public
Re vie w e nviro nme ntal po lic y annually,

and re vis e if ne c e s s ary
Plan
Review Do
Check
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3 PLANNING
3.1 SIGNIFICANT ENVIRONMENTAL ASPECTS
Each organisation must identify and evaluate the environmental aspects3 of its products,
operations, activities or services to determine those which have or which could have a
significant impact on the environment.
Each organisation must ensure that its significant environmental aspects4 are considered
when setting its environmental objectives.
Significant environmental aspects must be documented and then kept under periodic review.
The evaluation of significant environmental aspects must form an integral part of the
organisation’s development and management of change processes.
3
An environmental aspect is defined as an element of an organisation’s products, operations, activities or services that can interact with
the environment.
4
A significant environmental aspect is an environmental aspect that has or can have a significant environmental impact.
The identification and effective elimination, reduction and/or improved control of an

organisation’s significant environmental aspects is the primary function of an organisation’s
environmental management system (EMS),
The identification and evaluation of an organisation’s environmental aspects is essential if

the organisation is to achieve continual improvement in its overall environmental
performance.
Key Elements
The key elements are:
 A clear definition of the organisation and determination of the scope of the assessment
of environmental aspects
 The identification of the organisation’s environmental aspects
 The evaluation of these environmental aspects using risk assessment methodology.
 The significant environmental aspects will need to be documented and periodically

reviewed
 The evaluation of significant environmental aspects should be part of the management of

change process within the organisation
Plan
Review Do
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Application
Guidance on and the development of a Register of significant environmental aspects is given

in SHEACO Guidance Document. However, below is a summary of the general approach
that should be used.
One of the purposes of identifying the significant environmental aspects is to assist the
prioritisation of improvement actions and the generation of the objectives and targets. In order
to determine which environmental aspects are significant, all of the environmental aspects of
an organisation will need to be systematically identified and their potential impact or effect on
the environment evaluated. A separate guidance document on the environmental aspects of
products and packaging is to be developed.
Determination of the Scope of the Assessment
While a large organisation such as a Business Group will need to consider the full range of it’s
environmental aspects i.e. products, operations, activities and services, it may be more
appropriate for some of it’s constituent organisations to adopt a more focussed approach.
For example, a manufacturing site, distribution centre or warehouse will probably have little
influence over formulation and design of the products and packs it is required to manufacture
or use and will focus on the environmental aspects related to utility management, waste,
effluent and air emissions. This will define the scope of the assessment carried out.
An illustration of this is provided in the next section.
Identification of Environmental Aspects
The identification of environmental aspects should be conducted using a systematic approach

in order to identify all potential environmental aspects within the organisation.
There are a range of typical environmental aspects associated with different types of
organisation. Different types of organisation will also have varying degrees of impact on the
environment due to both the nature and scale of its products, operations, activities and
services.
Plan
Review Do
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The following lists contain some typical environmental aspects that may be found in
administrative, technical and manufacturing organisations. The lists are not exhaustive and
are written as examples.
Administrative organisations
Aspects associated with product use Emissions to Air

Environmental aspects associated with the Heating boiler emissions
use of products and packs which are sold to Employee vehicle emissions
the consumer. Transport policy
Use of refrigerants in air conditioning
Utility consumption
Electricity Releases to Water
Steam Domestic sewage
Water Surface water
Gas/Fuel oil Cooling water
Solid waste Nuisance

General waste Visual impact
Packaging waste associated with Vehicle noise
products used by the organisation Noise from heating and ventilation systems
Generation and disposal of paper
Fluorescent tubing Emergency situations
Ink/Paint/Glue Major fire
Printer cartridges/toners
Aluminium cans
Plan
Review Do
13 Check
 Technical organisations
The environmental aspects associated with technical or laboratory based organisations such
as RIC’s and R&D laboratories will include many of those for Administrative organisations.
Below is a list which contains examples of the environmental aspects which may be found in
technical organisations.
Aspects associated with product and pack design Emissions to Air

Environmental aspects associated with the Boiler house emissions
product and pack innovation process Employee vehicle emissions
Environmental aspects associated with process Transport policy
innovation Use of refrigerants in air conditioning
Extracted air e.g. fume cupboards
Utility consumption e.g. boiler house emissions, welding fumes,
Electricity dust, VOC’s
Steam
Water Releases to Water
Gas/Fuel oil Domestic sewage
Surface water
Cooling water
Solid waste Waste water discharges e.g. pilot
General waste plant/laboratory
Packaging waste associated with
products used by the organisation Nuisance
Generation and disposal of paper Visual impact
Confidential waste Vehicle noise
Fluorescent tubing Odour
Batteries Noise from pilot plant etc
Ink/Paint/Glue Noise from heating and ventilation systems
Printer cartridges/toners
Aluminium cans Emergency situations
Hazardous waste Major fire
Solvents Fracture/spill of:
Oils/Grease Chemical tank
Clinical waste Fuel tank
Glass waste
Process waste Land contamination
Chemical waste Contaminated land
Plan
Review Do
14 Check
 Manufacturing organisations
The possible aspects associated with manufacturing organisations may include many of
those included for Administrative and Technical organisations. Below is a list which contains
examples of the environmental aspects which may be found in manufacturing organisations.
Aspects associated with product and process innovation Emissions to Air

Environmental aspects associated with the product and Boiler house emissions
pack innovation process Employee vehicle emissions
Environmental aspects associated with process Transport policy
innovation Use of refrigerants in air conditioning
Liasing with RIC regarding the implications of new Extracted air from operations
products and processes. e.g. boiler house emissions, welding fumes,
dust, VOC’s
Utility consumption
Electricity Releases to Water
Steam Domestic sewage
Water Surface water
Gas/Fuel oil Cooling water
Ammonia Process effluent
Compressed air
Nuisance
Solid waste Visual impact
General waste Vehicle noise
Packaging waste associated with Odour (process/treatment plant)
products used by the organisation Noise from factory
Paper
Fluorescent tubing Emergency situations
Batteries Major fire
Aluminium cans Major gas leak
Hazardous waste Fracture/spill of:
Solvents Chemical tank
Oils/Grease Fuel tank
Clinical waste
Glass waste Land contamination
Process waste Contaminated land
Chemical waste
Plan
Review Do
Check
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The identification stage will need to cover all environmental aspects falling within the
following areas :
 Direct and Indirect
Direct aspects are those aspects over which the organisation has direct control, e.g. the air
emission from a site operated boiler house. Indirect aspects are those aspects which are not
caused by the organisation, but over which the organisation can reasonably expected to have
an influence, e.g. materials purchased centrally by the parent organisation, air emissions from
a power station not operated by the organisation but whose power the organisation uses etc.
 Past, Present and Planned Operations
It is most likely that the majority of the environmental aspects that are judged to be
significant will arise from current activities. However, there can be environmental impacts
associated with past activities within the organisation and these impacts would need to be
taken into account, e.g. past activities which have left land contaminated that could cause
pollution of groundwater. The environmental aspects associated with future planned activities
will also need to be assessed to determine their likely environmental impact e.g. new raw
materials, new facilities, changes to the production capacity on a manufacturing site, etc.
 Normal, Abnormal and Emergency
Current operations will need to be assessed for their impact during normal everyday
operation, abnormal operation, e.g. start up, shut down, trials etc., and during emergency
conditions. It is likely that the probability of an emergency situation arising is very low, but
the environmental consequences (or impact) could be severe.
The most systematic way to identify an organisation’s environmental aspects is to initially

divide the organisation into a number of manageable sub-units. These sub-units will cover a
series of processes, activities and services. It is important that the process of dividing the
organisation covers all of the land area occupied by the organisation’s activities. This process
of geographical zoning will ensure that all operations are incorporated into the analysis even
those areas which do not fall within a natural management structure.
Each specific process, activity or service identified should be depicted using a “black box”
approach. All of the inputs and outputs associated with the process, activity or service will
need to be identified. This “black box” process is illustrated in the Figure 2 below :
Figure 2
Noise,vibration
Air emissions Visual impact
Direct input
General waste
Process, activity
or service
Indirect or Special waste
ancillary input
Liquid/aqueous Spillages
discharge
Plan
Review Do
Check
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For each process, activity or service under consideration, every aspect and its associated
impact will need to be itemised. This approach, producing an inventory of environmental
aspects should identify as much data as possible regarding each input/output.
Determination of Significant Environmental Aspects
There are a number of techniques that can be used to identify those environmental aspects
which are significant. A methodology for this is summarised in the separate Unilever
guidance document related specifically to the identification and evaluation of environmental
aspects.
The assessment methodology described in this document primarily relates to pollution or
waste emissions from the organisation. This should not be confused with the risk
assessment process for products and packaging.
i) Initial screening
Once all of the environmental aspects of the organisation have been identified, they should be
screened using the following questions:
a) Could the environmental aspect result in the organisation failing to comply with
current or future regulatory requirements?
b) Is the potential impact sensitive and likely to give rise to complaints or put the
organisation under public scrutiny ?
c) Is the volume, scale or financial loss associated with the environmental aspect
high?
If the answer to any of these questions is “yes” then the environmental aspect is likely to have
a significant impact on the environment. The particular aspect would subsequently need to be
incorporated in the risk evaluation stage.
ii) Risk Assessment
The environmental aspects which are judged to be significant based on the initial screening
exercise should now be evaluated in order to determine the extent of the environmental risk.
Environmental risk can be assessed by calculating the product of the likelihood of the event
occurring and the severity of the effect if the event did occur. The likelihood, or the probability
for an environmental aspect to occur, should be assigned with a number between 1 and 4 with
1 representing no likelihood or very little chance and 4 representing a frequent or permanent
chance of occurrence.
Similarly, the severity of the environmental harm resulting from the impact should be assigned
a number between 1 and 4 with 1 representing little harm or reversible impact and 4
representing a disaster with irreversible impact.
For example, the likelihood of a occurrence of an aspect may be reasonably high, scoring 3,
and the severity of the resulting impact may be relatively slight, scoring 2. The environmental
risk would be 3 x 2 =6. The risk assessment methodology should set a level as to the
significance rating which will allow all identified environmental aspects to be designated as
significant or not.
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As part of the risk assessment methodology, organisations will need to include those
environmental aspects that have a control measure in place and therefore take into account
the likelihood of a control failure. For example, in a manufacturing operation, a bund, can be
employed as a control measure to contain spillages from an chemical storage tank. Although
the potential severity of the chemical entering a watercourse, would be high, the correct design
of the bund when accompanied by a regular inspection and maintenance programme would
reduce the likelihood of the occurrence such that the aspect can be judged to be not
significant.
The overall risk assessment methodology should be easily understood and transparent such
that it would be possible for another party to repeat the assessment and reach a similar
conclusion.
Documentation of Significant Environmental Aspects
For the purpose of the assessment, the organisation will need to be able to demonstrate that
all environmental aspects have been identified and evaluated. All significant environmental
aspects will need to be documented. Good practice in this area would be to generate a
Register of significant environmental aspects.
The documented significant environmental aspects will need to be reviewed periodically to

ensure that it is up to date. The register will need to be updated as and when any changes are
made to the process, activity, service or product.
For the organisation to obtain certification of its environmental management system to ISO
Written procedure for identification and evaluation of environmental aspects

Organisations will need to establish and maintain (a) written procedure(s) to identify its
environmental aspects and determine those which can have a significant impact on the
environment.
External communication on significant environmental aspects

The organisation will need to consider whether or not to externally communicate information
related to it’s significant environmental aspects and record its decision. 5
There are cases where although the environmental aspect is being controlled using Best
Available Techniques it is still assessed to be significant. In such cases it would be necessary
to agree this with the regulating authority and provide evidence to this effect to the certifying
body.
5
In some cases, this information may be seen as commercially sensitive and the decision would be not to externally communicate this
information
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 Unilever Guidelines For The Development Of A Register Of Significant Environmental

Aspects (Currently in preparation)
 Guidance on Noise Control and Hearing Protection
 LCA Guidelines for Environmental Assessment of Products and Services
referred to:
Section 2 - Environmental Policy

Section 3.2 - Legal and other requirements
Section 3.4 - Environmental Management Programme
Section 4.2 - Training, Awareness and Competence
Section 4.6 - Operational Control
Section 4.7 - Emergency Preparedness and Response
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FRAMEWORK
3.
Ide ntify all the e nviro nme ntal
Planning as pe c ts Es tablis h and maintain
as s o c iate d with the o rg anis atio n a writte n pro c e dure fo r
ide ntific atio n and e valuatio n
o f e nviro nme ntal as pe c ts
Unde rtake an e valuatio n o f the
3.1
e nviro nme ntal as pe c ts and
S ig nific ant ide ntify tho s e whic h have the po te ntial
to have a s ig nific ant impac t o n the
Enviro nme ntal
e nviro nme nt
As pe c ts
Co ns ide r whe the r o r no t to
Co ns ide r c o ntro l me c hanis ms to e xte rnally c o mmunic ate
re duc e the s e ve rity o f the info rmatio n re late d to it’s
s ig nific ant e nviro nme ntal as pe c ts s ig nific ant e nviro nme ntal
as pe c ts and re c o rd it’s de c is io n.
Do c ume nt the s ig nific ant

e nviro nme ntal as pe c ts and ke e p
the m unde r pe rio dic re vie w
Ens ure the e valuatio n o f s ig nific ant

e nviro nme ntal as pe c ts
is an inte g ral part o f the
de ve lo pme nt and manag e me nt
o f c hang e pro c e s s e s
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3.2 LEGAL AND OTHER REQUIREMENTS
Each organisation must undertake a regular review to identify all applicable environmental
legislation and all applicable internal Unilever standards e.g. SHEACO, Business Group,
Category and Operating Company.
Each organisation must develop a plan which will ensure full compliance with internal
Unilever standards within a reasonable and defined timescale, agreed with its parent
organisation, e.g. Business Group.
All organisations must operate in compliance with applicable legislation, unless a specific
exemption or exemption period has been previously agreed with the relevant enforcement
authority.
Key Elements
The following are the key elements of this standard:
 A regular review to identify applicable environmental legislation

 A regular review to identify all applicable internal Unilever standards
 A plan to ensure compliance with applicable Unilever standards within an agreed time-
scale
 All organisations will need to operate in compliance with applicable legislation.
Application
In order to fulfil the above, the following will need to be in place.
Each organisation will need to ensure it is fully aware of and operating in compliance with
environmental legislation and regulations that are applicable to their products, operations,
activities and services.
The organisation will need to identify the relevant Unilever and industry standards and
identify where they apply. Based on this evaluation, the organisation will need to develop a
plan to ensure full compliance with all Unilever requirements within a reasonable defined
time-scale. The system established will need to ensure that a regular review is undertaken.
The system developed to ensure that appropriate legislation is identified, accessible and
complied with by each type of organisation, may be similar for different organisations such
as manufacturing sites, laboratories or offices. It need only vary insofar as it accommodates
the legislative requirements relevant to the organisation in question.
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There are many ways in which organisations can obtain information about applicable laws or
regulations. These include:
 Commercial services (offered on-line, on computer disk, and on paper)
 Regulatory authorities
 Trade groups / associations
 Public libraries
 Seminars and courses
 Newsletters / magazines
 Consultants
 The internet
 Customers, suppliers and other companies
 Business Group SHE and Regulatory Affairs personnel
 Unilever corporate units
Documentation should be kept regarding legal requirements including any consents and
permits that have been issued by the controlling authorities covering discharges to the
environment. Process authorisation/planning conditions should also be held together with
copies of any relevant internal standards, guidelines or codes of practice issued by Unilever,
Business Group or the Company.
It is recommended that minutes of meetings and documentation covering internal and

external communications on the above issues should be retained and cross referenced with
the legislation where necessary.
It is also recommended that organisations keep a register of environmental legislation which

summarises the legislation in place by providing a list of relevant legislation (including
issue date and reasons for any amendments/changes) and a summary of the main
implications for the site. This should be circulated to relevant individuals in the organisation
with the circulation being previously agreed. An example can be found in the SHEACO
Compendium of Good Practice.
The list of regulated environmental emissions in the register of environmental legislation will
form the basis of which emission sources/parameters need to be monitored (see Sections
3.2 and 5.1).
Written procedure for identifying legal requirements

To satisfy the requirements of ISO 14001 the organisation will need to have in place a
written procedure to identify and access legal and other applicable environmental
requirements
The written procedure will need to be reviewed at suitable time intervals and, where found
necessary, updated.
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referred to:

Section 5.1 - Performance Measurement and Monitoring
Section 5.2 - Incidents, Non-conformances, Corrective and Preventive Actions
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FRAMEWORK
Planning
(c o ntinue d)
Ide ntify all applic able
e nviro nme ntal le g is latio n
3.2 and Unile ve r s tandards .
Le g al and Othe r
Re quire me nts Pe rio dic ally update this
info rmatio n.
Es tablis h and maintain

a writte n pro c e dure fo r
the ide ntific atio n and
Ope rate in full c o mplianc e
e valuatio n o f
with applic able le g is latio n
c o mplianc e
with le g al and o the r
applic able
e nviro nme ntal
re quire me nts
De ve lo p a plan to e ns ure
full c o mplianc e with inte rnal
Unile ve r s tandards within
a re as o nable and de fine d
time s c ale
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3.3 OBJECTIVES AND TARGETS
Each organisation must establish, document and maintain a set of specific environmental
objectives and targets, relevant to its current significant environmental aspects and
consistent with its environmental policy.
Key Elements
The organisation will need to have environmental objectives and targets which are:
 established and documented

 periodically reviewed and updated
 relevant to the significant environmental aspects
 derived from a Corporate requirement e.g. environmental performance reporting
 consistent with the organisation’s environmental policy, i.e. they should be
constructed to enable the environmental policy to be achieved
Application
Objectives and targets
An environmental objective is an overall environmental goal arising from the environmental

policy, that an organisation sets itself to achieve.
An environmental target is a quantified performance requirement that needs to be set and
met in order to achieve an objective.
Each organisation will need to set objectives to meet the commitments stated in its
environmental policy. The objectives will need to be set based on the findings of the
environmental aspects evaluation.
In most cases, it would be expected that objectives would be set for each significant
environmental aspect identified.
Once the objectives have been defined, environmental targets will need to be set to support
these objectives. The targets should be quantified where practicable and should follow the
SMART principle :
Significant - The targets should be related to one or more of the

significant environmental aspects.
Measurable - The targets have to be measurable.
Achievable - The organisation will need to be in a position to achieve the target
Responsibility - An individual or individuals will need to be assigned responsibility
Timescale - The management programme established to achieve the target

should be time scheduled
25
The number of targets set should be in line with what can realistically be achieved before the
next Management Review.
The organisations objectives and targets will need to be documented.
Many objectives and targets will require a project team to be established to allow them to be
met. These projects will form the environmental management programme as detailed in
Section 3.4.
Examples of the typical format of objectives and targets can be found in the SHEACO
Compendium of Good Practice.
The process of establishing objectives and targets, and the inputs used, should be
proportionate to the nature and scale of the organisation, its complexity and its
environmental risks. More depth and detail will be required for setting objectives in
manufacturing organisations than, for example, in office organisations which may have
relatively few environmental aspects.
Key Performance Indicators
Key performance indicators (KPIs) are the units of measurement that organisations use to
measure progress against targets.
It is recommended that each organisation should establish environmental key performance

indicators that will show the progress in terms of continual improvement and meeting its
objectives and targets. Indicators should be used which are relevant to the organisation.
Clearly identifiable units within the organisation may find it useful to develop separate
indicators. E.g. for manufacturing sites, indicators may be expressed per tonne of production
whilst for other organisations with no production tonnage , total load will be more
appropriate.
Some typical environmental performance indicators for manufacturing sites are given in the
list of Key Performance Indicators listed on the SHEACO Compendium of Good Practice.
Appropriate parameters relevant to a particular organisation should be selected from this list,
however as a minimum Unilever requires the following parameters to be monitored and
improvement targets set for all manufacturing sites
 Chemical Oxygen Demand (COD)

 Hazardous Waste
 Non hazardous waste
 SOx from boilers
 Energy consumption
 Water usage
 Particulate emissions from spray drying towers (HPC only)
 SOx from sulphonation plants (HPC only)
Note: Ozone depleting substances (O.D.S.) will also be included in this list from 2001 as
a result of the UEG strategy review.
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Review/Updating of Objectives and Targets
The organisation will need to initiate and implement a formal periodic review and update
system for the environmental objectives and targets. The review will need to be conducted
regularly, e.g. annually.
The formal review and update process should include consideration of the following :
 Current objectives and targets

 Performance against current objectives and targets
 Changes in factors and/or requirements used in setting objectives, such as
- changes in the significant environmental aspects of the organisation’s products,
operations, activities and services
- technical advances in the understanding of environmental risks and new means
of control
- changes or impending changes in legal requirements
 Updating existing objectives and targets
 Introduction of new objectives and targets
The depth and detail of the review process should be proportionate to the circumstances of
the organisation.
Environmental objectives and targets

The organisation will need to establish and document environmental objectives for each
relevant function and level in the organisation. These objectives should be:
- agreed with those responsible for achieving them
- communicated to those involved in their implementation
Consider the views of interested parties

When establishing and reviewing its objectives, the organisation will need to consider the
views of interested parties. Examples of potentially interested parties include
- internal or external parties which might be concerned with or affected by the
environmental performance of the organisation e.g. regulators, industrial neighbours,
local community groups, contractors.
- external sources of information or data which could provide a relevant input to
defining the Unilever organisation’s objectives
27
referred to:
Section 2. - Environmental Policy

Section 3.2 - Legal and Other Requirements
Section 5.1 - Performance Monitoring and Measurement
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FRAMEWORK
Planning
(c o ntinue d)
3.3 Es tablis h and do c ume nt

Obje c tive s and e nviro nme ntal o bje c tive s
Targ e ts and targ e ts Es tablis h and do c ume nt
e nviro nme ntal o bje c tive s fo r
e ac h re le vant func tio n
Pe rio dic ally re vie w and update and le ve l within the
e nviro nme ntal o bje c tive s o rg anis atio n
and targ e ts
Co ns ide r the vie ws o f

inte re s te d partie s in the
s e tting o f o bje c tive s
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3.4 ENVIRONMENTAL MANAGEMENT PROGRAMME
Each organisation must establish and maintain a written management programme

(improvement plan) for achieving its objectives and targets. The means, responsibilities and
time-scales for achieving the organisation’s objectives and targets must be clearly defined
and adequate resources provided.
The management programme must be reviewed at regular and planned intervals and
revised as appropriate to reflect changing circumstances.
Key Elements
To ensure its effectiveness the environmental management programme will need to :
 be formal (i.e. an agreed written programme)

 designate responsibilities for achieving objectives and targets
 allocate adequate resource
 define the means and time frame for achievement
 allow progress in achieving objectives and targets to be reviewed and corrective
action to be taken where necessary
Application
In order to ensure a structured approach to the achievement of environmental objectives, a

formal management programme will need to be established.
The environmental management programme is the portfolio of environmental projects that
will need to be implemented to ensure that objectives and targets are met.
The environmental management programme will need to be kept under review and modified
to take into account new developments, the environmental aspects arising from new or
modified activities, products or services and changes in legislation. In this respect the
programme will need to be modified when :
- objectives and targets are revised or added

- progress in achieving objectives and targets is made or not made
- changes in products, operations, activities or services or other factors arise
The nature and detail of the environmental management programme will depend upon the
type of organisation (i.e. the objectives set will be related to the type of organisation and the
nature and extent of the environmental improvement plan will be directly related to these
objectives).
Typical things to be considered should include:
 environmental policy and objectives

 reviews of legal and other requirements
 results of significant environmental aspects evaluation
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 information from employee consultations, review and improvement activities in the
workplace
 reviews of opportunities available from new, or different, technological options
 continual improvement activities
 availability of resources needed to achieve the organisation’s environmental objectives
An example of the type of projects that may be included in the Management programme for
a manufacturing site can be found in the SHEACO Compendium of Good Practice.
Designation of responsibilities at each relevant function and level for the achievement of
objectives and targets
The organisation will need to designate the responsibilities at each function and level for the
achievement of the objectives and targets.
referred to:
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FRAMEWORK
Planning
(c o ntinue d)
3.4
De fine and do c ume nt the
Enviro nme ntal Es tablis h and maintain a writte n
re s po ns ibility and
Manag e me nt e nviro nme ntal manag e me nt pro g ramme
autho rity
Pro g ramme fo r ac hie ving the de fine d o bje c tive s
fo r ac hie ve me nt o f
and targ e ts
o bje c tive s fo r all re le vant
func tio ns and at all le ve ls
in the o rg anis atio n
De fine the me ans ,

re s po ns ibilitie s ,
and time -s c ale s fo r ac hie ving
o bje c tive s and targ e ts
Pe rio dic ally re vie w the c o nte nt

and
pro g re s s in the imple me ntatio n
o f the manag e me nt pro g ramme
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4 IMPLEMENTATION AND OPERATION
4.1 STRUCTURE AND RESPONSIBILITY
Within each organisation, the most senior person is responsible for the implementation and
performance of the organisation’s environmental management system.
Each organisation must nominate a competent person(s) to co-ordinate the overall

implementation of the organisation’s environmental management system. This person must
have access to the most senior person within the organisation
Each organisation must define, document and communicate individual roles, responsibilities
and authorities for the implementation, control and improvement of the environmental
management system and provide adequate resources.
Each organisation must establish access to a source of competent expert advice on

environmental care matters.
Key Elements

 The most senior person has overall responsibility for implementation and performance of
the environmental management system
 The nomination of an overall EMS Coordinator
 The need to define, document, and communicate individual roles, responsibilities and
authorities for environmental management.
 Provision of adequate resources
 Establish access to competent expert advice on environmental care matters.
Application
Ultimate responsibility for the environmental management system lies with top management.
The most senior person has overall responsibility for implementation and performance of the
environmental management system. This responsibility will need to include defining the
organisation’s environmental policy and ensuring that the environmental management
system is implemented.
The appropriate human, physical (e.g. facilities, equipment), and financial resources
necessary for the implementation of an organisation’s environmental policies and the
achievement of its objectives will need to be identified and made available by the
organisation.
The roles, responsibilities and authorities of personnel involved in the implementation,

control, and improvement of the environmental management system will need to be defined,
documented and communicated.
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The designated environmental responsibilities within the Unilever Corporate structure and
those of the Business Groups and Operating Companies are held on the SHEACO database
and also summarised in the Compendium of SHE Policies.
Individuals should be specified within the organisation who are responsible for:
- overall environmental performance of the organisation

- the environmental performance of individual activities on a line management
basis
- co-ordinating environmental matters within the organisation
- advising line management in environmental matters
- contacts with regulatory authorities, local residents, media etc.
Any additional environmental responsibilities will be defined as part of documented plans or

procedures e.g. Emergency Plan
The definition of roles, responsibilities and authorities should be proportionate to the type of
organisation and its significant environmental aspects.
For example an organisation with higher environmental risks such as a large manufacturing
site may have someone identified as a full time environmental manager, who is responsible
for providing support and advice on environmental issues to the senior manager and his line
management team.
Whereas for other smaller organisations with a lower environmental risk this duty may be
adequately covered by part of an appropriate manager's time e.g. a site engineer or
production manager who has been given responsibility for environmental matters on-site.
The managers responsible will need to have sufficient knowledge of the activities of the
organisation and environmental issues to undertake their roles effectively. They will also
need to be appropriately trained (see Section 4.2) and know when and in what
circumstances it is necessary to seek further expert advice or assistance.
Access to competent expert advice will need to be established in the speciality of

environmental care. This expert advice may be internal to the organisation (e.g. for large
manufacturing units and/or organisations with higher risks), or external to the organisation
(e.g. for smaller sourcing units, warehouses, distribution centres, office organisations).
Where the expertise is external to the organisation it may be provided by the parent
organisation (e.g. the Business Group), or by a Unilever corporate unit e.g. SEAC, or by an
external consultancy.
Deputies should be appointed for key members of the emergency team especially
individuals responsible for dealing with external contacts (e.g. media, regulatory authorities)
during an emergency. (see Section 4.7).
The structure and responsibilities of the members within the project teams carrying out the
environmental management programme should also be detailed.(See Section 3.4)
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Appointment of appoint an Environmental Management Representative
The organisation will need to appoint an environmental management representative (EMR)

who, irrespective of other responsibilities, shall have defined roles, responsibilities and
authority for :
- Ensuring that the environmental management system requirements are

established, implemented and maintained in accordance with the standard
- Reporting on the performance of the environmental management system to

top management for review and as a basis for improvement of the
environmental management system.
A typical structure for the implementation of an environmental management system can be

found in the SHEACO Compendium of Good Practice.

referred to:
Section 2 - Environmental Policy

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4.2 TRAINING, AWARENESS AND COMPETENCE
Within each organisation, all individuals working for that organisation must be given relevant
environmental care training or information, as appropriate. This training or information must
be proportionate to the individual’s environmental care responsibilities, abilities, literacy and
the environmental aspects associated with their work, including emergency preparedness.
Specific individual or group training needs must be periodically assessed to ensure that each
individual or group is competent to perform their role within the organisation’s environmental
management system.
This training must make clear the importance of effective environmental management to
Unilever as a global company.
Key Elements
In order to ensure that employees in all functions and at all levels of the organisation are fully
aware of the importance of the environmental management programme within the
organisation, a training programme will need to be in place which:
 provides an environmental induction to all employees as soon as they commence work

at the organisation
 identifies the appropriate type and detail of environmental awareness training for each
function based on the environmental implications of their activities
 provides the identified environmental awareness training
 records what training each employee has had.
For other individuals working for the organisation, environmental information will need to be
provided that is appropriate to their roles and proportionate to the nature and scale of the
environmental risks associated with their roles.
Application for Employees in All Functions and at All Levels
Employees should be able to perform their tasks in an efficient and competent way and
understand the impact that their activities can have on the environment if performed
incorrectly.
Appropriate training programmes will need to therefore be established for all employees
including senior management, line management, employees, new recruits and staff assigned
to new tasks, equipment etc.
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Development of Training Programme
The key steps in developing a training programme are listed below :
1) Assess environmental training needs and requirements for each individual using the
criteria in the framework standard.
2) Define training objectives
3) Select suitable programmes that meet regulatory and organisational requirements
4) Prepare training plan (who, what, when, where and how)
5) Implement training programme
6) Evaluate training effectiveness
7) Improve training programme as needed
Good practice would be to maintain records on all training received by employees.
 Induction Training
It is important that relevant environmental issues are covered in induction training. This
induction training should cover:
- principles of the organisation’s environmental policy including responsibilities

of individuals at all levels
- principal environmental risks for the organisation and how these are
controlled including details of the emergency plan
- general rules in place for the organisation including permits to work and
housekeeping
- environmental issues associated with particular areas where individuals are
working.
 Training Needs Analysis
In order to ensure that all employees (i.e. in all functions at all levels in the organisation) are
able to undertake their jobs competently and with due regard to the environmental
implications, a system will need to be in place in order to identify the particular skills and
competencies needed by each employee, which employees need training and what training
is required. The system needs to include the following key aspects:
- identification of the training needed by managers and other functions to

ensure that they have appropriate knowledge of the environmental
management system in place at the organisation in question
- identification of the functions and tasks done at the organisation which could
or do have an impact on environmental care.
- definition of the competencies required and the identification of any shortfalls
between the level possessed by the individuals and the level required
- identification of the training needed by each employee including specialist
training for particular tasks and functions (e.g. those with specific
environmental roles, those who have specific roles in emergency planning
etc.)
- provision of appropriate training by competent trainers
 General Awareness Training
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Particular items that employees should be made aware of include:
- the importance of conforming with the policy and procedures

- the organisation’s significant environmental aspects, and the potential for their
activities to impinge on the significant environmental aspects, and the benefits
of improved performance
- consequences of departure from operating procedures e.g. potential for
infringing legal limits
 Specialised Training
More specialised training is recommended for some employees as summarised in the table
below :
Type of Training Audience Purpose

Awareness of strategic importance Senior management To gain commitment and alignment to
of environmental management the organisation’s environmental policy
Skills enhancement Individuals with environmental To improve performance in specific
responsibilities areas of the organisation e.g.
operations, R&D and engineering
Compliance Individuals whose actions can To ensure regulatory and internal
affect compliance requirements are met
included in the skills enhancement training are:
- Individuals responsible for emergency/crisis management

- Managers designated to deal with the media
For emergency/crisis management and media handling, it is recommended that external

training should be obtained.
Refresher Training
Regular refresher training should be given to all employees but should be focused on those
employees working on tasks which have a higher risk of impacting on the environment.
Lessons learned from incident reports and investigations should be considered in prioritising
such refresher training.
Review
All training programmes will need to be reviewed periodically and when there has been
significant change in the operations or on the introduction of new machinery, equipment,
processes or modifications of any of these. When new equipment, processes, or
modifications to equipment and processes are introduced, additional update training should
be given to appropriate employees, e.g. based on the environmental aspects evaluation of
the new operations or modifications.
Records should be kept of any reviews and update training done.
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Application for Other Individuals Working for the Organisation
There needs to be a system in place to address the following

 identification of the environmental information needed for such individuals
 provision of the required information
 update and review as appropriate
Note that the information required for certain groups of individuals, may need to include
formal environmental induction training.
The key requirements identified above will apply to all organisations, but the nature and
extent of training required will need to be adapted to the type of organisation. For example,
in the case of a manufacturing operation there will be considerable training required to
ensure that the employees are able to expedite their duties in a manner that ensures that the
environmental aspects are adequately controlled. Similarly, there will be specific training
requirements for people working in RIC’s and distribution facilities. It is likely that those in
office-based organisations will need different training from those in manufacturing or RIC
organisations.
In all cases, the training and/or information needs analysis will need to be designed to
identify the extent and type of training and/or information required and thus is fundamental
for all organisations.
Written procedure for training

To satisfy the requirements of ISO 14001, the organisation will need to have in place a
written procedure to ensure that adequate and appropriate training is given to all employees.
The written procedure will need to be reviewed at suitable time intervals and, where found
necessary, updated.
referred to:
Section 3.1 Significant Environmental Aspects

Section 4.1 Structure and Responsibility
Section 4.6 Operational Control
Section 4.7 Emergency Preparedness and Response
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FRAMEWORK
Imple me ntatio n &

Ope ratio n (c o nt’d) Ge ne ral e nviro nme ntal induc tio n
o r aware ne s s training
4.2 fo r all EMPLOYEES
Training ,
Aware ne s s &
Co mpe te nc e Ide ntify the s kills and
c o mpe te nc ie s , s kills ne e de d by
all EMPLOYEES at all le ve ls
Ide ntify training ne e ds fo r

all EMPLOYEES Es tablis h and maintain
a writte n pro c e dure to
Es tablis h and imple me nt a e ns ure ade quate and
training pro g ramme appro priate training is
appro priate to the ide ntifie d g ive n to all e mplo ye e s
ne e ds
Re vie w the training pro g ramme

- pe rio dic ally
- whe n the re has be e n a c hang e
in the o pe ratio ns
Pro vide re fre s he r / update

training in ac c o rdanc e with
the re vie ws and ne e ds
S ys te m o f training re c o rds
S ys te m fo r pro viding e nviro nme ntal

info rmatio n to OTHER INDIVIDUALS
wo rking fo r the o rg anis atio n
Ide ntific atio n o f ne e ds ,

pro vis io n o f e nviro nme ntal info rmatio n,
re vie w and update
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4.3 COMMUNICATION
Each organisation must periodically provide environmental information, as requested by

Unilever, by its parent organisation e.g. Business Group, or where legally required to do so
e.g. by an external authority.
Each organisation must establish and maintain a system for receiving, documenting and
responding to relevant communication from external interested parties.
Key Elements
The key elements are

 Systems for providing environmental information
- internally within Unilever as requested, and
- where legally required to do so e.g. By an external authority
 Systems for dealing with communications from external interested parties
Application
Provision of environmental information
Environmental information, will need to need to be provided internally within Unilever e.g. to
the Business Group on request or to an agreed programme. Environmental information will
also need to be provided to external authorities where legally required to do so, for example
to meet legal requirements or specific demands or requests.
Systems for provision of environmental information will need to be set up and implemented.
The following should be defined within this system:
 The likely demands or requests for information, both internally to Unilever and externally
 What information is to be communicated
 To which authorities and agencies
 Whether within Unilever or outside Unilever
 How the information is to be assembled, when, and by whom or by which functions
 When the information is to be communicated, by whom or by which functions
 Whether proactively, e.g. As good practice, to meet general industry norms, to maintain
or enhance reputation, or reactively / passively, e.g. on request or demand from the
agency concerned
 How copies of the information provided are to be retained within the organisation
It would be good practice for this system to be reviewed periodically for its adequacy, and
revised where found necessary. The scope of the system should be proportionate to the
nature of the organisation’s operations.
When requested, or required under an agreed programme, the necessary information will
need to be provided. This should be done following the above system.
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All manufacturing sites will need to report their environmental performance as required by
their Business Group and to Unilever on an annual basis using the proforma designed for
this purpose.
Recommended indicators for environmental performance reporting are detailed in the
Compendium of Good Practice on the SHEACO Database.
Dealing with external communications from external interested parties
A system for recording and dealing rapidly with external communications will need to be
established which defines:
 Mechanisms for receiving and acknowledging communications (timescales for

acknowledgement, medium of reply etc.)
 Responsibilities for investigating and responding to complaints (and authorities if

necessary)
 Responsibilities for actioning recommendations, ensuring they are carried out in

agreed timescales and that they achieve desired results
 Method of recording and documenting communications
This system will need to be maintained, i.e. reviewed periodically for its adequacy, and
revised accordingly. The scope of the system should be proportionate to the nature of the
organisation’s operations.
Written procedure for internal communication
To satisfy the requirements of ISO 14001 the organisation will need to have a written
procedure for internal communication between the various levels and functions of the
organisation.
 Mechanisms for internal communication

Motivation of individuals working for the organisation to improve the organisation’s
environmental performance is important and may be enhanced through positive recognition
of good performance when environmental objectives and targets are achieved.
Effective internal communications require mechanisms for information to flow top-down and
bottom-up. A mechanism should be established for communicating current environmental
issues to all levels of the workforce and debate should be encouraged to generate ideas in
order to improve the organisation’s environmental performance. Regular briefings should be
held to inform all individuals working for the organisation of the organisation’s environmental
performance/improvements and progress against environmental objectives and targets.
This can most readily be achieved by regular meetings, notice boards, internal reports
regarding progress against targets, electronic mail, newsletters, internal committees etc.
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Check
In addition Unilever Corporate environmental information (e.g. SHEACO documentation) is

also available via the Intranet.
External communication on significant environmental aspects

The organisation will need to consider whether or not to externally communicate information
related to it’s significant environmental aspects and record its decision.7
referred to:
Section 2. - Environmental Policy

Section 3.2 - Legal and Other Requirements
Section 5.1 - Performance measurement and monitoring
7
In some cases, this information may be seen as commercially sensitive and the decision would be not to externally communicate this
information.
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FRAMEWORK
Imple me ntatio n &

Ope ratio n (c o nt’d)
4.3 Pro vis io n o f e nviro nme ntal info rmatio n

Co mmunic atio n inte rnally within Unile ve r as Es tablis h and maintain a
re que s te d writte n pro c e dure fo r
inte rnal c o mmunic atio n o f
e nviro nme ntal info rmatio n
Pro vis io n o f e nviro nme ntal info rmatio n
to e xte rnal bo die s whe re le g ally
re quire d to do s o
Es tablis h and maintain a s ys te m

fo r re c e iving , do c ume nting and
re s po nding to c o mmunic atio ns
fro m e xte rnal inte re s te d partie s
Co ns ide r whe the r o r no t to

e xte rnally c o mmunic ate
info rmatio n re late d to it’s
s ig nific ant e nviro nme ntal
as pe c ts and re c o rd it’s de c is io n.
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4.4 DOCUMENTATION
Each organisation must establish and maintain an information system, in paper or electronic
form, which:
 describes the core elements of the management system and their interaction,
 provides direction to related documentation.
Key Elements
The key elements associated with this framework standard are:
 The organisation will need to review its documentation and information needs for
environmental care to identify what documentation is required
 Appropriate documentation will need to be produced as identified above
 Establish an index of documentation that clarifies where the various appropriate
documentation is available
 Maintain the documentation and information system (i.e. review periodically against
requirements and update as necessary).
Application
The primary purpose of the documentation system is to describe the core elements of the
management system and clarify the relationships and interactions between them. It is
composed of the environmental management manual, procedures, work instructions and
records.
Clear direction will need to be provided to all the forms of documentation in the system.
This is the main function of the environmental management manual.
The documentation system will need to be maintained by reviewing it periodically and
updating where necessary.
The requirements and extent of the documentation system should be appropriate to the type
of organisation. Documentation is required for the key parts of an environmental
management system that are applicable to the organisation in question.
Documentation should be proportionate to the environmental risks. It is important that

documentation is kept to the minimum required for effectiveness and efficiency. Where
appropriate or desired by the organisation, one system can be used for all the SHE
management documentation.
It is not necessary to replace existing documentation such as manuals, procedures, and

work instructions where these already exist and describe adequately the current
arrangements. For organisations where such documentation already exists, it may be more
effective to develop an overview document which describes the relationships between
existing procedures/documents and the requirements of the environmental care framework
standard.
A model framework for the environmental management systems manual is provided in the
SHEACO Compendium of Good Practice.
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Figure 3, illustrates a suggested hierarchy for the documentation system:
Figure 3 Document Hierarchy
Environmental Management Manual
Procedures
Working Instructions
Records
It is not necessary and probably impracticable for the manual to contain all the relevant
information in a single document. It is recommended that the manual should include a brief
summary of each topic and provide direction to the location of related more detailed
documentation
If the above measures are in place, then the organisation should satisfy the requirements for
certification of its environmental management system to ISO 14001.
referred to:
Section 4.5 - Document and Data control

Section 5.3 - Records and Record Management
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FRAMEWORK
Imple me ntatio n &

Ope ratio n
(c o ntinue d)
4.4
Do c ume ntatio n
Es tablis h and
maintain an e nviro nme ntal
info rmatio n s ys te m
a) Pro vide info rmatio n

o n the c o re e le me nts
o f the e nviro nme ntal
manag e me nt s ys te m
Re vie w info rmatio n
and do c ume ntatio n
ne e ds fo r e nviro nme ntal
b) Pro vide dire c tio n
to the re late d
do c ume ntatio n
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4.5 DOCUMENT AND DATA CONTROL
Each organisation must establish and maintain systems for the management of all statutory
and other critical documents and data relating to its environmental management system.
Key Elements
Systems for the management of:

 all statutory documents and data relating to its environmental management system.
 other critical documents and data relating to its environmental management system.
Application
All documents and data that are critical to the operation of the environmental management
system and the performance of the organisation’s environmental activities will need to be
identified and managed. Critical documents and data include those required under statutory
requirements, i.e. legally required documents and data.
The management of the identified critical environmental documents and data should include
systems for the identification, approval, issue, and eventual removal of critical environmental
documentation, and control of the critical environmental data.
The system for management of the critical environmental documents and data will be similar
for all organisations. The extent of the critical environmental documents and data will be
proportional to the organisation’s activities and its significant environmental aspects. They
will be more extensive for manufacturing organisations, and possibly research &
development organisations, than for office organisations.
Every effort should be made to minimise the bureaucracy associated with the document and
data control system. However, the system for managing the critical documents and data will
need to ensure that they:
 are issued and approved in a defined way
 can be located
 are periodically reviewed, revised as necessary and approved for adequacy by
appropriate personnel
 current versions are available at the necessary locations
 obsolete documents and data are promptly removed from all points of issue and points of
use, or otherwise assured against unintended use
 obsolete documents and data retained for specific purposes (e.g. to meet legal
requirements, or to preserve knowledge) are suitably identified
Responsibilities and authorities for the document and data control systems should be
defined.
Critical environmental documents and data will need to be available and accessible when
required, e.g. in an emergency , by keeping them in a safe area. Methods for the electronic
backup of data should be employed where appropriate. The systems will need to be
reviewed and, where found necessary, updated periodically.
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In accordance with good practice for document control, the controlled documents should be:
 Legible
 Dated (including date for revision, or expiry date)
 Include revision history
 Readily identifiable (e.g. With a reference number, and with revision number or version
number)
 Maintained in an orderly manner
 Retained for a specified period
 Replaced with new versions as the need arises
 List of persons / places to which the documents were issued
Examples of Critical Environmental Documents and Data
Here are some examples of environmental documents and data that an organisation might
decide are critical. Those in bold are required by the framework standard:
- The organisation’s environmental policy

- Lists of the organisation’s significant environmental aspects
- List of currently applicable environmental legislation
- List of currently applicable Unilever environmental standards
- Environmental objectives and targets
- Details of environmental management programme
- Details of organisation’s environmental roles and responsibilities
- Environmental training plans, course contents, and records of who was
trained on what
- Documents related to external communication
- Documents which describe the core elements of the EMS and provide
direction to related documents
-
- Procedures and work instructions related to the control of the
significant environmental aspects
- Details of the organisation’s emergency plan
- Results of tests and exercises related to the emergency plan
- Reports of legally required equipment inspections
- Critical maintenance records (e.g. for equipment, vehicles)
- Environmental performance data reported internally within Unilever and
externally to the authorities
- Reports and investigations of potentially serious incidents, including reports
required by the authorities
- Plant engineering drawings
- Hazardous material datasheets
- Documents and/or data related to the monitoring of the significant
environmental aspects
- Environmental audit reports and resultant action plans
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Written procedure for document and data control

procedure for the management of all documents and data relating to its environmental
management system.
This procedure will need to be reviewed periodically and, where found necessary, updated.
For organisations where other management systems are in place it is sensible that the
same document control procedure is used for all.
referred to:
Section 4.4 - Documentation

Section 5.3 - Records and Record Management
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FRAMEWORK
Imple me ntatio n &

Ope ratio n
(c o ntinue d)

4.5
s ys te ms fo r the Es tablis h and maintain
Do c ume ntatio n and manag e me nt o f e nviro nme ntal a writte n pro c e dure fo r
Data Co ntro l do c ume nts and data, the manag e me nt and
c o ve ring ; -- c o ntro l o f all e nviro nme ntal
do c ume nts and data
a) S tatuto ry e nviro nme ntal

do c ume ntatio n and data
b) Othe r c ritic al e nviro nme ntal

do c ume ntatio n and data
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4.6 OPERATIONAL CONTROL
Each organisation must identify those operations and activities that are associated with its
significant environmental aspects, where control measures need to be applied.
Each organisation must plan these activities to ensure that they are carried out under
specified conditions by establishing and maintaining:
 documented procedures and/or work instructions to cover situations where their
absence could lead to deviations from the environmental policy or objectives and
targets,
 specific operating criteria in the procedures, where appropriate,
 systems for the purchase and/or use of substances, goods, equipment and services
and their identified environmental aspects,
 systems for the design and maintenance of:
 the work organisation,
 the workplace,
 process installations,
 equipment,
 operating procedures, including their adaptation to human capabilities,
in order to eliminate or reduce environmental aspects at their source, and by communicating

relevant procedures and requirements to suppliers and contractors.
Key Elements

 identify those operations and activities where control measures need to be applied.
 plan these activities to ensure that they are carried out under specified conditions
Application
Operational control is concerned with formally documenting why and how environmental
management tasks are carried out. This is particularly important where an operation is
complex and/or the potential environmental impacts are significant. These controls will need
to take the form of documented procedures.
The organisation will need to identify and decide the operations and activities where control
measures need to be applied. These will be specific to the organisation. They will be more
extensive for a manufacturing operation or factory than for an office organisation. To identify
what they are, the organisation will need to consider the following:
 The output from environmental aspects evaluation, including the identified significant
environmental aspects(see section 3.1)
 The environmental policy and environmental objectives and targets (see sections 2 and
3.3)
 The identified legal requirements, and other requirements such as those required by
Unilever standards or advised by Unilever guidance (see section 3.2)
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The organisation will need to determine those activities, relevant to their own operations,
where control measures are required. The identification of the significant environmental
aspects is key to this.
There are a number model procedures available on the SHEACO Compendium of Good
Practice which can be used as an initial starting position and adjusted to suit an
organisation’s specific conditions.
Clearly, not all of the procedures will be relevant to all organisations.
For example, administrative organisations may require a procedure for Emergency response
but not for liquid effluent or hazardous substances management.
Examples of activities that require operational control will also be inclusive of activities such
as:
 Maintenance of control equipment,
 Management of contractors and
 Relationships with suppliers or vendors which could affect the organisation’s
environmental performance.
Guidance regarding a number of the key operational control activities is given in the
following sub-sections.
New / Changed Products, Processes and Equipment
Systems need to be in place to ensure that environmental considerations are taken into
account when considering the introduction of new products or raw materials and new
processes/equipment. Each capital proposal, plant modification, new product introduction or
significant product reformulation should be examined to ensure that the potential impact of
the proposal on the environment has been taken into account and to ensure that best
environmental practice has been considered. A formal procedure/checklist is recommended
to fully evaluate the potential effects. Where appropriate, the Unilever mandatory
toxicological and process safety clearance systems will need to be used.
Any changes will also need to be assessed to determine if they give rise to additional
significant environmental aspects and whether the significant environmental aspects
evaluation needs to be updated.
Contractors and Suppliers
Systems need to be in place to ensure that potential significant environmental aspects of

contractors and suppliers are effectively managed.
The environmental aspects of the service the contractors/suppliers are providing will need to
be determined and if necessary the controls required for any significant environmental
aspects should be written into the contract.
Any contractors working for the organisation e.g. engineering, transport, solid waste
contractors, will need to be made aware of the organisation’s environmental policy, any
relevant general procedures and requirements together with any particular environmental
considerations associated with the particular operation they will be working with.
Guidelines in this area are available in SHEACO guidance document “Principles for the Safe
Management of Contractors” .
Control of Discharges to the Environment
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Environmental control procedures will need to be in place which includes a description of the
control measures to ensure that all discharges meet relevant legislation and/or Unilever
internal standards.
Key production related activities that are likely to require operational control procedures are:
 Air Emissions Management

 Water / Liquid Effluent Management
 Solid Waste Management
 Noise and Visual Impact
 Hazardous substances Management
 Energy Management
Procedures covering the management of environmental emissions will contain a number of

common elements :
 Emission sources
The emission sources will have been established as part of the Identification of
significant environmental aspects(See Section 3.1). The list of emissions will indicate
the location of each emission source, any control devices fitted and whether the
emission is significant.
 Compliance
The particular emissions or group of emissions that are subject to regulatory
compliance will need to be identified.
 Responsibility
A person will need to be assigned responsibility for ensuring that the facility operates
in compliance with all relevant regulations
 Control
The designated person should ensure that the best available techniques are used to
control environmental emissions and that any control equipment is regularly
maintained.
 Monitoring
All environmental emissions that require measurement in order to assess compliance
with legislation will need to be incorporated into a measurement schedule.
 Records
All records of monitoring, maintenance programmes, regulatory inspections,
treatment and compliance problems etc. should be retained.
Management of Hazardous Substances
The organisation will need to manage effectively and safely the use of hazardous
substances as defined by National legislation.
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Additional written procedures for operational control

To satisfy the requirements of ISO 14001 the organisation will need to have written
procedures for
the purchase and/or use of substances, goods, equipment and services and their identified
environmental aspects.
This procedure will need to be reviewed periodically and where found necessary, updated.
 Principles for the Safe Management of Contractors
 Guidance on the Acoustic Design of Factories
referred to:

Section 3.3 - Environmental Objectives and Targets
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FRAMEWORK
Imple me ntatio n &

Ope ratio n (c o nt’d) Ide ntify o pe ratio ns and
ac tivitie s that are
as s o c iate d with the
4.6 s ig nific ant e nviro nme ntal as pe c ts
Ope ratio nal
Co ntro l
Fo r the s e o pe ratio ns and ac tivitie s , e s tablis h and
maintain do c ume nte d pro c e dure s and wo rk ins truc tio ns
to e ns ure c o mplianc e with po lic y, o bje c tive s , le g is latio n
and Unile ve r s tandards .
S tipulate o pe rating
c rite ria in pro c e dure s & Es tablis h and maintain
wo rk ins truc tio ns writte n e nviro nme ntal c o ntro l
pro c e dure s with re s pe c t to ne w
Es tablis h and maintain s ubs tanc e s , g o o ds ,
o pe ratio nal c o ntro l s ys te ms e quipme nt and s e rvic e s
with re s pe c t to ne w s ubs tanc e s , g o o ds , purc has e d by the
e quipme nt and s e rvic e s purc has e d o rg anis atio n
by the o rg anis atio n
Es tablis h o pe ratio nal c o ntro l

s ys te ms with re s pe c t to the de s ig n
o f the wo rkplac e , pro c e s s e s ,
e quipme nt e tc
Co mmunic ate
pro c e dure s and
o the r re quire me nts
to s upplie rs and
c o ntrac to rs
Re vie w and update s ys te ms

plans and pro c e dure s
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4.7 EMERGENCY PREPAREDNESS AND RESPONSE
Each organisation must periodically6 identify and evaluate the environmental aspects arising
from its operations, activities and services to determine the potential for serious incidents or
emergency situations.
Each organisation must establish comprehensive emergency plans to prevent or at least

mitigate the likely consequences associated with each potentially serious incident or
emergency situation.
Emergency plans must be documented and then kept under periodic review.
Where practicable (possible), each organisation must periodically6 practise their

environmental care emergency plans.
6
More detailed requirements, regarding this issue, will be defined in a separate Unilever SHE Specific Standard - Environmental Care
Emergency Planning.
Key Elements
 Identification and evaluation of hazards to determine potential for serious incidents or

emergencies
 Preparation and implementation of appropriate Emergency Plans
 Documentation and review of Emergency Plans
 Practise and testing of Emergency Plans
Application
Identification and Evaluation of Potential Environmental Incidents
The significant environmental aspects evaluation should have identified those areas with the
potential to result in a major environmental incident.
Preparation and implementation of appropriate Emergency Plans
Emergency plans to mitigate the consequences of the identified events should then be
developed and these plans should include the following key aspects, which should be
documented within the plan:
 A defined emergency/crisis management team

 A nominated incident controller
 Clear instructions for contacting Unilever, Business Group, Company, and external
emergency services contacts
 Clear instructions for alarm signals, plant shutdown activities, evacuation procedures,
definition of escape routes and clear marking of these
 Clearly marked and known assembly points
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 Clear identification of where any hazardous materials are stored on site together with
details of types and quantities
 Key isolation valves should be marked on site plans and these should also be clearly
physically identifiable
 An emergency control centre suitably located and containing the appropriate equipment
 Arrangements for the protection of vital equipment and vital records
 arrangements for the re-commencement of business following any emergency
 a suitably trained media contact should be nominated.
(N.B. any emergency plan will also need to consider OH& S emergencies and thus cross-
reference to the guidance on the corresponding section of the Occupational Health and
Safety Framework Standards should be made.)
All of those people with specific roles in the plan (including first aid and other medical aid
personnel) will need to be suitably trained and the training will need to be kept current.
Suitable emergency equipment should be provided and this should include:
 detection and alarm equipment

 fire-fighting equipment
 emergency lighting
 safety showers
 eyewash facilities
 breathing apparatus
 spillage and clean-up equipment
 alternative communication systems.
The emergency plan should also include arrangements for contacts with appropriate external
bodies and, where possible, mutual aid agreements with other local operations.
Note: Serious accidents and incidents will need to be promptly reported to Unilever
in accordance with the classification of incidents and the timescales defined in
Unilever reporting protocols. They will need to also be investigated and the
investigation formally reported within the criteria and timescales defined in Unilever
reporting protocols.
(See section 5.2)
Documentation and Review of Emergency Plans
All the details contained in the emergency plan will need to be documented. A formal
mechanism will need to be in place whereby the emergency plans are reviewed e.g.
annually or following any real emergencies, tests drills or the findings from any risk
assessments done on new plant, equipment, process or modifications to these.
Such a system will need to define:
 when such reviews and updates should be done

 a mechanism to trigger this process (e.g. after a drill or when a new assessment of
environmental aspects has been completed)
 who is responsible for initiating and progressing the process of review and updating of
the plans
 a mechanism to inform all relevant people of any changes that are made to the plans.
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Appropriate training programmes will need to be established for all those involved (see
Section 4.2).
It would be good practice to give copies of the finalised documents to the appropriate
external emergency services.
Practice and testing of Emergency Plans
There should be a defined plan to do drills and practices of the emergency procedures at the
operation. This plan should:
 define the type of drill or test to be done

 who should be involved
 when such drills or practices need to be done
 who is responsible for organising and expediting such exercises
 who is responsible for analysing the lessons learned from the above exercises and
ensuring that the emergency plans are reviewed and updated.
In particular, emergency plans and procedures should be reviewed following any real
emergencies. Lessons learned should be developed from tests, drills, and actual
emergencies.
Written procedure for emergency plans

To satisfy the requirements of ISO 14001 a written procedure will need to be in place to
identify the potential for and respond to accidents and emergency situations. This procedure
will need to be reviewed periodically and, where found necessary, updated.

 Unilever Serious Incident reporting and investigation protocol
 Guidance on Emergency Planning
 Unilever Guidelines For The Development Of A Register Of Significant Environmental
Aspects
A Specific Standard is to be prepared on this subject (see note 5 above)
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referred to:

Section 4.2 - Training Awareness and Competence
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FRAMEWORK
Imple me ntatio n &

Ope ratio n
(c o ntinue d)
4.7 Pe rio dic ally ide ntify and

Eme rg e nc y e valuate hazards
Pre pare dne s s and that c o uld le ad to s e rio us
Re s po ns e inc ide nts o r e me rg e nc y
Es tablis h e me rg e nc y Es tablis h and maintain

plans to de al with all writte n pro c e dure s fo r the
po te ntially s e rio us ide ntific atio n o f po te ntial
e me rg e nc y s ituatio ns e me rg e nc y s ituatio ns
and the de ve lo pme nt o f
e me rg e nc y plans
Do c ume nt e me rg e nc y plans
Pe rio dic ally prac tis e

e me rg e nc y plans , whe re
prac tic able
Re vie w and re vis e plans

pe rio dic ally and fo llo wing
te s ts , drills , and
e me rg e nc y inc ide nts ;
de ve lo p le s s o ns le arne d
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5 CHECKING AND CORRECTIVE ACTION
5.1 PERFORMANCE MEASUREMENT AND MONITORING
Each organisation must establish and maintain systems to monitor and measure its
environmental performance on a regular basis.
These systems must provide for the measurement of :
 the key parameters of its operations and activities that can have a significant
potential impact on the environment,
 progress in the implementation of agreed objectives and targets,
 compliance with procedures, work instructions and defined operating criteria,
 compliance with applicable legislation,
 compliance with applicable internal Unilever standards,
The recording of this data must be sufficient to enable the identification of appropriate
corrective and preventive action.
Any monitoring equipment used must be calibrated, maintained and records of the
calibration results and any equipment maintenance retained.
Key Elements
The key elements of this framework standard are:
 set up systems to monitor and measure environmental performance
 these systems will need to cover the five points listed in the framework standard
 ensure that the results of the measurements are recorded appropriately (see framework
standard)
 any monitoring equipment used will need to be calibrated and maintained
Application
Monitoring Compliance with Legal and Internal Unilever Standards
Organisations will need to establish and maintain a regular specified monitoring programme
for discharges to the environment to ensure compliance with legislation and to review
progress against targets. The emissions and parameters to be monitored will be
determined by :
 Emissions associated with potential significant environmental aspects (this will

automatically include emissions subject to legislation - see Section 3.2)
 The critical performance parameters used by the organisation
 The environmental performance indicators used by the organisation/Unilever(see
Sections 3.3 and 3.4)
This programme would probably be in addition to any monitoring carried out by appropriate
regulatory authorities. In addition to assessing legislative compliance, monitoring should also
be conducted to assess performance against best or recommended practice and to
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determine whether new plant or modifications to existing plant are performing according to
predictions.
A system will need to be established to monitor the disposal of waste (both hazardous and
non-hazardous). The quantities and relevant documentation (consignment notes) for the
disposal of hazardous waste together with details of any waste registration schemes will
need to be recorded.
The frequency and extent of the measurements will be determined by:
 Legal or authority requirements

 Ease by which the sampling can be conducted and analysis carried out, e.g. COD versus
BOD
 Importance of parameters in terms of environmental impact and proximity to consent
levels
 Accuracy required e.g. for performance indicators
 The need for assessing charges for disposal
 The cost of sampling and analysis
Monitoring Progress against Objectives and Targets
It is recommended that the progress against targets and objectives is reviewed at a

frequency which is appropriate to the organisation. Ideally this should be done either monthly
or quarterly. This can be done through a variety of routes such as regular employee team
meetings, weekly/monthly management meetings, internal environmental committees etc.
Clearly the more frequent the review of progress against targets, the more effective control
measures are likely to be in terms of achieving continual improvement. Indeed many
organisations review their effluent/waste loads and utility consumption against datum as part
of their routine operational controls. In addition progress is often demonstrated to the
workforce with the use of notice boards and regular production meetings.
Monitoring Compliance with Legal and Internal Unilever Requirements
Under Section 3.2 of this guidance, each organisation will need to identify key legislative and
Unilever internal requirements. Under this Section 5.1 (this section), a system will need to
be established to monitor the compliance of the organisation against such requirements.
Monitoring Compliance with Procedures and Work Instructions
In order to test compliance with procedures, work instructions and defined operating criteria,
it is recommended that organisations implement a schedule of inspections.
 Physical Inspections
It is recommended that physical inspections are conducted on a regular basis. The planned
inspections would pay particular attention to environmental issues to ensure recommended
practices and procedures are being implemented and adhered to.
These inspections should be undertaken at regular intervals and include an assessment of

the overall condition of equipment, control measures, housekeeping etc. Records should be
kept and follow up arrangements established to ensure the required improvements are
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implemented. Individual responsibility for completion of the improvements along with the
timescale for completion should be defined.
Discrete parts of the organisation should also be subject to planned inspections on a regular
basis. These inspections can be of varying levels of detail from general housekeeping
inspections to full physical conditions tours. The type of inspection and the frequency these
are carried out will need to be determined by the organisation, taking into account the risks
involved and required timescales to ensure that no deterioration in performance occurs.
Responsibilities for the completion of any actions identified from the above should be set and
the actions completed by the specified times.
Records
Records of the data developed from the above will need to be kept and the responsibility for
the recording and custody of the information will need to be established.
Maintenance of Monitoring Equipment
Monitoring equipment used in the collection of this information needs to be subjected to

regular calibration checks as recommended by the manufacturers. The equipment should
also be part of a preventative maintenance programme.
Written procedure for monitoring and measuring environmental performance

The organisation will need to establish a written procedure for the monitoring and
measurement of environmental performance. This procedure will need to cover the full
scope of the monitoring and measurement systems outlined above under 5.1 (a) - framework
standard.
The procedure will need to be reviewed periodically and, where found necessary, updated.
Written procedure to assess compliance with legislation

The organisation will need to have a written procedure to assess compliance with legislation.
The procedure will need to be reviewed periodically and, where found necessary, updated.
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referred to:
Section 3.2 - Legal And Other Requirements
Section 3.3 - Objectives And Targets
Section 4.6 - Operational Control
Section 4.7 - Emergency Preparedness and Response
Section 5.2 - Incidents, Non-Conformances, Corrective And Preventive Actions
Section 5.4 - Management Systems Audit
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FRAMEWORK
5.
Es tablis h and maintain s ys te ms Es tablis h and maintain
Che c king to mo nito r and me as ure e nviro nme ntal writte n pro c e dure s fo r
and Co rre c tive pe rfo rmanc e mo nito ring and
Ac tio n
me as uring e nviro nme ntal
pe rfo rmanc e
5.1
Ke y parame te rs o f o rg anis atio n’s
Pe rfo rmanc e
o pe ratio ns whic h c an have s ig nific ant
Me as ure me nt and
impac t o n the e nviro nme nt Es tablis h and maintain
Mo nito ring
writte n pro c e dure s to
Fo r mo nito ring pro g re s s in the as s e s s c o mplianc e with le g is latio n
imple me ntatio n o f ag re e d
o bje c tive s and targ e ts
Fo r mo nito ring c o mplianc e with

pro c e dure s , wo rk ins truc tio ns , and
o pe rating c rite ria

applic able le g is latio n

applic able inte rnal Unile ve r s tandards
Re c o rding o f data and re s ults to

allo w fo r c o rre c tive ac tio ns
Mo nito ring e quipme nt to be

c alibrate d and maintaine d
Re c o rds o f c alibratio n and

mainte nanc e o f mo nito ring
e quipme nt to be ke pt
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Check
5.2 INCIDENTS, NON-CONFORMANCE AND CORRECTIVE AND

PREVENTIVE ACTION
Each organisation must establish and maintain systems for:
 reporting and investigating non-conformances7, including those which arise from

environmental incidents,
 the reporting of serious incidents to Unilever,
 taking action to mitigate any consequences arising from such events,
 the initiation and completion of corrective and preventive actions,
 confirmation of the effectiveness of corrective and preventive actions taken.
Any corrective and/or preventive actions taken must be appropriate to the magnitude of the
problem and commensurate with the significance of environmental aspects identified.
7
The word “Non conformance” as used in this document is defined to mean any deviation from procedures, work instructions, operating
criteria, applicable legislation or internal Unilever standards etc., that could either directly or indirectly result in a significant impact on
the environment.
Key Elements
The key elements to be put in place to meet this framework standard are systems for:
 reporting and investigating non-conformances, including those which arise from
environmental incidents,
 the reporting of serious incidents to Unilever, as defined by Unilever reporting
protocols
 making corrective actions (e.g. based on the results of investigations)
 confirming the effectiveness of the corrective actions (e.g. follow-up process)
Application
Incident Investigation and Corrective and Preventive Action
In the event of an incident on or off site e.g. involving the accidental discharge of potentially
harmful materials into the environment, there needs to be an established system to
investigate the incident and determine the root cause(s). A follow up report should be issued
documenting the actions necessary to prevent a recurrence of the situation.
The system and responsibilities for initiating investigation and corrective action in the event
of non compliance with specific requirements e.g. discharge standards, should be defined. In
addition individual responsibilities for actions and timescales for completion should also be
specified. Progress of actions should be regularly reviewed.
Note: Serious accidents and incidents will need to be promptly reported to Unilever
in accordance with the classification of incidents and the timescales defined in
Unilever reporting protocols. They will need to also be investigated and the
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investigation formally reported within the criteria and timescales defined in Unilever
reporting protocols.
The procedure for reporting and investigation of serious incidents can be found on the
SHEACO website.
Non Conformance of Management System
A system needs to be in place to correct any identified deficiencies in the elements of the
environmental management system. This system should ensure that the problem is
investigated, the root cause(s) identified and that corrective actions are identified,
implemented and recorded. Once corrective or preventive actions have been implemented,
they will need to be checked to confirm their effectiveness and modified if necessary.
Written procedures for reporting and investigation of all non-conformances

To satisfy the requirements of ISO 14001, the organisation will need to have written
procedures for:
 defining responsibility and authority for investigating non-conformance
 taking action to mitigate any impacts
 initiating and completing corrective and preventive actions.
The purpose of these procedures is to formalise the systems which the organisation has put
in place under (b) above.
These procedures will need to be reviewed periodically and, where found necessary,
updated.
The organisation will need to also implement and record any changes in the procedures as a
result of corrective and preventive action.

 Unilever Serious Incident Reporting and Investigation Protocol
referred to:

69
Plan
Review Do
Check
70
FRAMEWORK
5.
Che c king Es tablis h and maintain s ys te ms

and Co rre c tive fo r re po rting and inve s tig ating
Ac tio n Es tablis h and maintain
writte n pro c e dure s fo r
5.2 the re po rting and
Inc ide nts , no n- inve s tig atio n o f all
c o nfo rmanc e s no n c o nfo rmanc e
and c o rre c tive o r No n-c o nfo rmanc e s
pre ve ntive ac tio ns
Re po rting s e rio us inc ide nts

and inc ide nts to Unile ve r
Es tablis h and maintain s ys te ms fo r taking

ac tio n to mitig ate c o ns e que nc e s
o f no n-c o nfo rmanc e s
Es tablis h and maintain s ys te ms

fo r the initiatio n and c o mple tio n
o f c o rre c tive ac tio ns

s ys te ms fo r c o nfirmatio n o f
the e ffe c tive ne s s o f
c o rre c tive ac tio ns
Plan
Review Do
71 Check
5.3 RECORDS AND RECORD MANAGEMENT
Each organisation must establish and maintain a system for the identification, maintenance,
storage and retrieval of environmental records, including the results of audits, performance
and management system reviews.
Key Elements
The key elements of records management are:
 Define responsibility for custody and maintenance of records

 Identification of records to be kept
 Indicate location and form of records(paper or electronic)
 Establish how long records should be retained for
 Establish an effective retrieval system
Application
Environmental records provide the evidence that the environmental management system is
working effectively and is being implemented as designed.
Firstly, it is necessary to decide on what records are kept with the focus on records that add
value and avoid bureaucracy.
In designing the records management system, the organisation needs to consider
- who needs access?
- to what records?
- in what circumstances?
Organisations may wish to consider using an electronic EMS records management system.
Maintaining records electronically can provide an excellent means for rapid retrieval of
records as well as controlling access to sensitive records. If electronic systems are used,
then regular back up should be carried out.
Organisations may consider combining the records management processes for environ-
mental and health & safety records.
Whilst establishing a records retention policy, organisations will need to ensure that the im-
plemented system takes into account records retention requirements specified in applicable
environmental regulations and Unilever or parent organisation’s requirements.
Examples of the types of environmental records that should be kept as part of an

environmental management system are listed below:
 Information on the applicable environmental legislation or other requirements

 Consents covering the discharge of emissions into the environment and the disposal of
waste along with appropriate authorisations/permits.
 Emissions data
 Non-conformance corrective action reports.
Plan
72 Review Do
Check
 Correspondence/meetings with the authorities

 Complaints records
 Training records
 Process information
 Product information
 Utility consumptions
 Inspection, maintenance and calibration records
 Pertinent contractor and supplier information
 Incident reports
 Information on emergency preparedness and response
 Information on significant environmental aspects
 Management reviews
 Minutes of environmental inspections
 Internal/external environmental audit reports
Written procedure for records management

procedure for the identification, maintenance and disposition of environmental records.
These records will need to include training records as well as the results of audits and
reviews.
This procedure will need to be reviewed periodically and, where found necessary, updated.
System to ensure good standards of records

A robust system for records will need to be established and such a system will need to
ensure that:
 Records are legible, identifiable and traceable to the activity, product or service
 Records are readily retrievable
 Records are protected against damage, deterioration or loss
 A front-line manager or more senior manager signs off records.
There are many sections of the Framework Standards that require the appropriately stored
and readily retrievable records. However, the following section is particularly relevant.
73
Section 4.4 - Management Systems Documentation
Plan
Review Do
74 Check
FRAMEWORK
Che c king &

Co rre c tive Ac tio n
(c o nt’d)
Es tablis h and maintain a
Es tablis h and maintain a writte n pro c e dure to
5.3
s ys te m to ide ntify, maintain e ns ure that all ne c e s s ary
Re c o rds and
and s to re and re trie ve e nviro nme ntal re c o rds re c o rds are s to re d
Re c o rds
appro priate ly
Manag e me nt
Es tablis h and maintain a s ys te m to s to re Es tablis h a ro bus t

the re s ults o f audits , pe rfo rmanc e re vie ws s ys te m fo r
and manag e me nt s ys te m re vie ws e nviro nme ntal re c o rds
Plan
Review Do
Check
75
5.4 ENVIRONMENTAL MANAGEMENT SYSTEM AUDITS
Where required by its parent organisation8, each organisation must ensure that its
environmental care management system is subjected to an independent audit9, in order to
determine whether or not the organisation’s environmental care management system:
 conforms to planned arrangements for environmental care management, including

compliance with internal Unilever standards e.g. SHEACO, Business Group,
Category, Operating Company,
 has been properly implemented and maintained,
 is effective in meeting the organisation’s policy and objectives,
The key recommendations arising from these audits must be presented to the organisation’s
top management.
The organisation’s management programme must then be extended to include the actions
arising from the audit recommendations.
The time period between independent environmental care management system audits must
be related to the degree of perceived business risk but must be no greater than every three
years.
8
More detailed requirements, regarding this issue will be defined in a separate Unilever SHE Specific Standard - Environmental Care
Management System Auditing
9
An” independent environmental audit” is one undertaken by someone from outside the specific organisation being audited. Alternatively,
personnel who work for the organisation can undertake an environmental audit, but in these circumstances the audits must then be verified
by someone from outside that specific organisation
Note: Section 5.4 is only relevant to those organisations whose parent organisation
has mandated that they implement a programme of independent environmental
management audits. All organisations however, will need to assess their compliance
with the Environmental Care Framework Standards, on an annual basis, as part of the
Unilever Corporate Audit “Positive Assurance” process. All Unilever manufacturing
sites will need to be subjected to an independent environmental management
systems audit at least every three years.
Key elements
 Where required by its parent organisation, each organisation’s environment audit pro-
gramme will need to ensure that independent audits are carried out at least every three
years.
 The auditing protocol will need to ensure that the environmental management system:
- conforms to planned arrangements for environmental care management
- has been properly implemented and maintained
- if effective in meeting the organisation’s policy and objectives
 Audit recommendations will need to be presented to senior management
 Actions arising from audits will need to be incorporated into the environmental manage-
ment programme.
Plan
Review Do
Check
76
Application
The organisation will need to consult with its parent organisation (e.g. Business Group) to
determine whether or not independent audits of the organisation’s environmental
management system are required.
If the parent organisation requires it, the organisation will need to ensure it receives an
independent audit of it’s environmental management system . The audits and audit
programme will need to be capable of determining whether or not the environmental
management system conforms to planned arrangements, has been properly implemented,
and is effective in meeting policy and objectives.
The key intention is to evaluate conformance with the Unilever Environmental Care
Framework Standards, progress of plans to achieve conformance, and progress of the
development and extension of the environmental management programme.
The audit process should address the scope, frequencies, methodology, competencies,
responsibilities and requirements for a carrying out the audits and reporting the results.
Audit protocol
The audits will need to consider

- environmental policy, procedures, and systems,
- their implementation at the workplace,
- the practices and conditions in the workplace
A suitable environmental audit protocol should be used that enables these issues to be
assessed systematically.
An audit protocol is a questionnaire and/or checklist, often with explanatory notes, that
guides auditors to carry out the audits in a structured and consistent way.
The organisation should select, preferably in agreement with its parent organisation, an audit
protocol appropriate to its needs. This can be a proprietary audit protocol from an external
organisation, or a protocol devised within Unilever, or a protocol devised by the organisation
or its parent organisation. Into the future, however, organisations are likely to find most
benefit from using an audit protocol whose structure is consistent with the structure of the
Unilever Environmental Care Framework Standards and/or the structure of ISO 14001.
Co-operation and management support
Top management should demonstrate commitment to environmental management system

auditing and its effective implementation. Relevant personnel should be informed of the
purposes and benefits of the audits. Staff should be encouraged to cooperate fully.
Top management should address the audit findings and recommendations, and take
appropriate action within an appropriate timescale.
Auditor qualifications
Auditors need to have suitable skills, knowledge and experience in environmental

management systems and auditing and therefore training will need to be provided where
necessary. Independent auditors certifying to ISO 14001, should comply with ISO 14012;
"Guidelines for environmental auditing - Qualification criteria for environmental auditors".
Plan
Review Do
Check
77
Audit Output, Results, and Follow-up
The output of the audits should include:

 detailed assessments of the effectiveness of environmental management systems and
procedures, ideally including information on their relevance
 the level of compliance with procedures and practices
 the identification of corrective actions and areas for improvement
 a timely and clear report which records the audit activities, findings, results, and
recommendations
The results of the environmental management system audits should be communicated

promptly to all relevant parties, in a way that suits the needs of the organisation.
Specifically, the key recommendations arising from the audits will need to be presented to
the organisation’s top management.
The organisation’s management programme will need to then be extended to include the
actions arising from the audit recommendations. An action plan of agreed remedial
measures should be drawn up together with nominated responsible persons, completion
dates and reporting requirements.
Follow-up monitoring should be established to check implementation of the action plan.
Established Environmental Management System audit programme

To meet the requirements of ISO 14001, the organisation will need to establish an audit
programme and systems for periodic environmental management system audits, even if not
specifically required by its parent organisation. To meet the requirements of ISO 14001, this
could be a programme of internal audits, conducted by competent, preferably independent
people. The scope of this audit programme and systems would need to be similar to that
described above under “Application”.
This audit programme and systems will need to be reviewed periodically and, where found
necessary, updated.
Written procedures for auditing the Environmental Management System

The organisation will also need to have written procedures for auditing its environmental
management system. This procedures will need to make reference to:
 the scope, frequencies, and methodologies
 the competencies, responsibilities, and requirements
for conducting the audits and reporting the results.
This procedure will need to be maintained, i.e. reviewed periodically and, where found
necessary, updated.
Independent auditors should comply with ISO 14012; "Guidelines for environmental auditing
- Qualification criteria for environmental auditors". A summary of the qualifications and
experience required can be found on the SHEACO Compendium of Good practice.
Plan
Review Do
Check
78
A common approach adopted by the independent ISO 14001 certifying bodies is to conduct
a surveillance audit (approx. 2 days duration) each year with an audit of the complete
system every three years (approx. 5 days duration) to re-affirm certification to ISO 14001.
 ISO14012
All sections of the environmental management system and this guidance document are
related to environmental management systems audit, and should be referred to as
necessary.
Plan
Review Do
Check
79
FRAMEWORK
Che c king &

Co rre c tive Ac tio n
(c o nt’d)
5.4 Whe re re quire d by the pare nt o rg anis atio n:

Es tablis h and maintain a
Audit writte n pro c e dure
Audits o f the e nviro nme ntal manag e me nt
fo r pe rio dic auditing o f
s ys te m mus t be do ne by
the o rg anis atio n’s
inde pe nde nt audito rs at le as t 3 ye arly
e nviro nme ntal manag e me nt
s ys te ms .
Ke y re c o mme ndatio ns fro m

audits mus t be pre s e nte d to
to p manag e me nt
The manag e me nt pro g ramme

mus t be e xte nde d to
addre s s audit re c o mme ndatio ns

an audit pro g ramme fo r
e nviro nme ntal manag e me nt s ys te ms
Plan
Review Do
Check
80
6 MANAGEMENT REVIEW
Each organisation’s top management team must, at least annually, review the performance
and consider the adequacy of its environmental care management system to ensure its
continuing suitability, adequacy and effectiveness.
The management review must address the possible need for changes to policy, objectives
and other elements of the environmental management system in the light of management
system audits, changing circumstances and the commitment to continual improvement.
Key Elements
In this top management review of the environmental management system, the following key
issues will need to be addressed:
 that the system is being fully implemented
 that the system continues to be appropriate to ensure the stated objectives for the
organisation can be achieved
 that the system is suitable to ensure the principle of continual improvement.
The review should be based on a report on the overall performance of the environmental
management system that includes the following:
 the results of any management systems audits
 corrective actions carried out since the last review
 recorded instances of the ineffectiveness of the system
 the adequacy and effectiveness of the emergency procedures
 any possible actions to generate continual improvement.
Application
Management reviews are the key to continual improvement and to ensuring that the EMS
will continue to meet the organisation’s needs over time. Therefore, at least on an annual
basis, or following an audit, the top management of an organisation will need to review the
environmental management system in order to ensure its continuing suitability and
effectiveness. Such reviews may result in changes to the policy, objectives, targets, the
management programme and to the overall design of the management system in order to
correct any deficiencies.
Formal documentation of management reviews

The completed management reviews will need to be formally documented.
81
All sections of the environmental management system and this guidance document are
related to the environmental management review, and should be referred to as necessary.
Plan
Review Do
Check
82
FRAMEWORK
6.
Manag e me nt To p manag e me nt te am
Re vie w mus t re vie w the pe rfo rmanc e and Fo rmal do c ume ntatio n o f
c o ns ide r the ade quac y o f the manag e me nt re vie ws
its e nviro nme ntal manag e me nt
s ys te m, at le as t annually
Exte nd manag e me nt pro g ramme

to addre s s re quire d impro ve me nts
in the de s ig n and/o r o pe ratio n o f
the e nviro nme ntal manag e me nt s ys te m
83
84
APPENDIX I TPM SELF ASSESSMENT - OCCUPATIONAL SAFETY, HEALTH & ENVIRONMENT - OSHE
SCOPE DEPT
AREA
Category: Items to check: Evaluation Criteria Points
Low Middle High
1) Policy a) Is a signed and up-to-date copy of No policy or out of date (0–1) Policy up to date but not Yes, policy up to date,
the organisation’s OH&S policy displayed and with only prominently displayed and
clearly on display and has it been minimal communication thoroughly communicated (4)
well communicated to each and (2-3)
every employee?
b) Is a signed and up-to-date copy of No policy or out of date (0-1) Policy up to date but not Yes, policy up to date,
the organisation’s Environmental displayed and with only prominently displayed and
policy clearly on display and has it minimal communication thoroughly communicated (4)
been well communicated to each and (2-3)
every employee?
c) Are the key policy objectives Very few employees can recall About half of the employees Most employees can recall the
known to a cross section of the key Health & Safety and can recall the key Health & key Health & Safety and
employees Environmental Policy objectives Safety and Environmental Environmental Policy
(0) Policy objectives (1) objectives (2)
2) Planning a) Are employee teams involved in Employee teams not involved Employee teams are consulted Employee teams play a major
the identification and evaluation of (0) when these activities are role in this process (3-4).
OH&S Hazard \ OH&S hazards in the workplace? undertaken (1-2)
Environmental For example through
Aspect identification Autonomous Maintenance,
and evaluation Early Equipment Management,
Kaisens, Task Hazard Analysis
etc
b) Are employee teams involved in Employee teams not involved Employee teams are consulted Employee teams play a major
the identification and evaluation of (0) when these activities are role in this process (3-4).
sources of waste\loss and in the undertaken (1-2)
conservation of resources eg water, For example through
energy etc? Autonomous Maintenance,
Early Equipment Management,
Kaisens, Task Hazard Analysis
etc
c) Are the findings from these No (0) Some of the findings are All key information is visually
2
SCOPE DEPT
AREA
Low Middle High
identification and evalution processes visually displayed. Updating of and locally displayed, updated
visually displayed in the workplace information is conducted by and maintained by the
and are they then updated and staff external to the employee employee teams. For example
generally maintained by the team (1) by the use of Radar Charts (2)
employee teams?
3) Planning a) Do the employee teams have clear No (0) OH&S activity targets are OH&S activity targets are
targets with respect to activities defined for employee teams defined for employee teams
Objectives, targets designed to reduce the risk of injury but employees are not really and employees are really
and improvement in the workplace? involved in the process of involved in the process of
programmes agreeing and setting these agreeing and setting these
targets targets
(1-2) (3-5)
b) Do the employee teams have clear No (0) Waste and resource Waste and resource
targets with respect to activities conservation activity targets conservation activity targets
designed to reduce waste and are defined for employee are defined for employee
conserve resources in the teams but employees are not teams and employees are
workplace? really involved in the process really involved in the process
of agreeing and setting these of agreeing and setting these
targets targets
(1-2) (3-5)
4) Implementation a) Have general and specific No (0) Minimal expectations or Employee SHE responsibilities
and Operation employee SHE responsibilities been standards have been been well defined,
documented and communicated? documented and documented and thoroughly
Structure and communicated (1) communicated (2)
responsibility b) Are SHE issues a regular item on No (0) SHE issues are a regular item SHE issues are a regular item
the agenda of TPM Team meetings on the agenda of TPM Team at the top of the agenda of
and Safety focused meetings ie; tool meetings and Safety focused TPM Team meetings and
box talks, safety lunches etc? meetings ie; tool box talks, Safety focused meetings ie;
safety lunches etc (1-2) tool box talks, safety lunches
etc (3)
c) Are TPM tools/techniques being No (0) TPM tools/techniques are used TPM tools/techniques are
3
SCOPE DEPT
AREA
Low Middle High
frequently used by employee teams adhoc to analyse/identify, routinely being used to analyse
to identify, analyse and resolve analyse and resolve OHS& and identify hazards ie; why,
OHS& hazards\issues and to reduce hazards\issues and to reduce why analysis, CEDAC. (3)
waste and conserve resources ie; waste and conserve resources
why, why analysis, CEDAC? hazards. (1-2)
d) Is the Site OSHE Adviser an active No (0) The Site OSHE Adviser The Site OSHE Adviser is an
member of the TPM Factory Steering occasionally attends the TPM active member of the TPM
Group meetings? Factory Steering Group Factory Steering Group
meeting (1) meeting (2)
5) Implementation a) Does the skills matrix clearly No (0) The skills matrix simply The skills matrix identifies
and Operation identify the OH&S and Environmental identifies the general each individual’s general and
Care training skills and need for all awareness OH&S and specific OH&S and
Training, awareness employees? Environmental Care training Environmental Care training
and competence needs of employee team needs (3-4)
members
(1-2)
b) From the gaps identified from the No evidence of a training plan The skills matrix identifies skill The skills matrix is
skills matrix is there a clear training (0) gaps but specific SHE training accompanied by a
plan specific to SHE requirements? requirements are unidentified comprehensive training plan
(1) specific to SHE requirements
(2-3)
c) Are Teams regularly using One No application of “One Point One Point Lessons are One Point Lessons are being
Point Lessons to deliver SHE Lessons” for SHE related issues occasionally used to deliver used to deliver SHE
training/awareness? ie to support (0) SHE training/awareness (1) training/awareness. OPLs are
SHE procedures and works a key function of procedures
instructions and works instructions and are
regularly reviewed and
maintained (2-3)
6) Implementation a) Are employee teams given SHE No (0) Management only provide Management proactively
and Operation information by management in full employee teams with SHE provide employee teams with
compliance with local legal information on a random and SHE information in full
4
SCOPE DEPT
AREA
Low Middle High
Communication requirements? eg: MSDS, adhoc basis. Most information compliance with local legal
Workplace Noise Levels, OH&S is available but only from the requirements. (2)
Committee minutes etc Site OSHE Adviser. (1)
b) Have the organisations overall No (0) The organisations overall SHE The organisation’s overall SHE
SHE objectives, annual targets and objectives, annual targets and objectives, annual targets and
improvement plans been cascaded improvement plans are improvement plans are
and communicated to employee cascaded and communicated cascaded and communicated
teams? to all employee teams once a to all employee teams and
year (1-2) then progress is
communicated throughout the
year. (3-4)
c) Have employee teams established No (0) Employee teams have Employee teams have
processes for recording and sharing established informal established effective
SHE information and data with each processes for recording and processes for recording and
other? sharing SHE information and sharing SHE information and
eg: Activity boards, One Point data across employee teams. data across Teams. eg:
Lessons, Minutes of Team Meetings (1-2) Activity boards, One Point
Lesson folders, Minutes of
Team Meetings (3-4)
7) Implementation a) Have operational SHE control No (0) A detailed plan is in place to Operational SHE control
and Operation procedures, work instructions and implement SHE control procedures, work instructions
operating criteria been clearly procedures, work instructions and operating criteria have
Operational control defined for all hazardous tasks? and operating criteria for all been clearly defined for all
hazardous tasks. (1-2) hazardous tasks. (3-4)
b) Are employee teams formally No (0) Employee teams are Employee teams are formally
involved in the design of new or sometimes formally involved in involved in the design of new
revised OH&S control measures eg. the design of new or revised or revised OH&S control
equipment, procedures, work OH&S control measures eg. measures eg. Early Equipment
instructions and rules? Early Equipment Management, Management, new procedures,
new\modified procedures, work instructions and rules. (3-
work instructions and rules. 4)
5
SCOPE DEPT
AREA
Low Middle High
(1-2)
c) Are employee teams formally No (0) Employee teams are Employee teams are formally
involved in the design of new or sometimes formally involved in involved in the design of new
revised environmental controls or the design of new and/or and/or revised environmental
waste minimisation measures? eg. revised environmental controls controls or waste minimisation
equipment, procedures, work or waste minimisation measures
instructions and rules? measures. (2)
(1)
8) Implementation a) Have emergency plans and No (0) Emergency plans and Emergency plans and
and Operation procedures been clearly defined for procedures have only been procedures have been clearly
all reasonably foreseeable SHE clearly defined for a very defined for all likely SHE
Emergency planning emergency situations? limited number of SHE emergency situations (3-4)
and response emergency situations (1-2)
b) Are employee teams formally No (0) Employee teams are informally Employee teams are formally
involved in the design and practice of involved in the design and involved in the design and
OH&S emergency control measures? practice of OH&S emergency practice of OH&S emergency
Is crisis and emergency management control measures. control measures. Crisis and
equipment clearly identified and Some limited crisis and emergency management
accessible to employee teams? emergency management equipment is clearly identified
equipment is accessible to and accessible to thoroughly
employee teams. trained employee teams
(1-2) (3-4)
c) Are employee teams formally No (0) Employee teams are informally Employee teams are formally
involved in the design and practice of involved in the design and involved in the design and
environmental emergency control practice of environmental practice of emvironmental
measures? Is crisis and emergency emergency control measures. emergency control measures.
management equipment clearly Some limited crisis and Crisis and emergency
identified and accessible to employee emergency management management equipment is
teams? equipment is accessible to clearly identified and
employee teams. (1) accessible to thoroughly
trained employee teams (2)
6
SCOPE DEPT
AREA
Low Middle High
9) Checking and a) Are the KPI’s for OSHE clearly No. OSHE KPI’s data is held by KPI’s for OSHE are sometimes KPI’s for OSHE are routinely
corrective action displayed and communicated? management and not cascaded displayed and communicated. and clearly displayed and
e.g. via activity boards, shift (0) (1-2) communicated.
Performance reviewing, team meetings? (3-4)
measurement and
monitoring For example via Activity For example via up-to-date
Examples might include the number Boards, Shift Reviews, and exciting Activity Boards,
of SHE One Point Lessons prepared, Employee Team meetings. Effective Shift Reviews,
the number of near misses recorded, Employee Team meetings.
waste reduction achieved over a
period of time the number of Total
Recordable and FAC accidents.
b) Is there a recognition system in No recognition system in place An informal recognition system A comprehensive recognition
place for proactive SHE (0) is in place for proactive SHE system is in place for proactive
achievements ie safety equipment achievements (1-2) SHE achievements. (3)
gifts such as First Aid Kits, Smoke
Detector and Fire Extinguishers for
the car or home?
c) Is progress on specific employee No (0) Progress on specific employee Progress on specific team
team based proactive environmental team based improvement based proactive environmental
care improvement objectives projects are occasionally care improvement projects are
periodically reviewed by reviewed by management on periodically reviewed by
management with the employee an adhoc basis. (1-2) management with the
teams? employee teams and formal
recognition is given (2-3)
10) Checking and a) Are all SHE accidents/incidents No (0) SHE accidents/incidents are All SHE accidents/incidents
corrective action reported, investigated and is the investigated and the necessary are investigated and the
corrective action taken proportional corrective action taken (1) necessary corrective action
Incident reporting, to the potential severity of the taken is proportional to the
investigation and accident\incident? potential severity of the
7
SCOPE DEPT
AREA
Low Middle High
analysis accident\incident. Thorough
communication always follows
(2)
b) Are employee teams formally and No (0) Employee teams are informally Employee teams are always
directly involved in the investigation and indirectly involved in the formally and directly involved
of SHE incidents and in the investigation of SHE incidents in the investigation of SHE
identification of both the immediate (1-2) incidents and in the
and root causes? eg; are employee identification of both the
teams using TPM tools and immediate and root (3-4)
techniques? ie why, why analysis etc.
c) Are employee teams formally and No (0) Employee teams are informally Employee teams are formally
directly involved in the reporting and and indirectly involved in the and directly involved in the
investigation of SHE near misses and reporting and investigation of reporting and investigation of
in the identification of the immediate SHE near misses SHE near misses and in the
and root causes? (1-2) identification of the immediate
and root causes
(3-4)
Total Score
Out of a possible 100
Percentage

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GUIDANCE FOR APPLICATION OF

THE UNILEVER SHE FRAMEWORK STANDARDS

1.1 General Requirements

4. Implementation and operation

5. Checking and Corrective Action

Sections 2-6 of the guidance are structured as follows:

(a) Framework Standard

1.1 General Requirements

An environmental management system (EMS) is an organisational framework that should be

The key elements are summarised below and illustrated in Figure 1:

3 - Implementation and Operation (DO)

4 - Checking and Corrective Action (CHECK)

5 - Management Review (REVIEW)

1.3 Unilever Organisations

 administration units, e.g. head offices, corporate centres and marketing/sales

 technical establishments, e.g. research laboratories, regional innovation centres

Where necessary, any differences or adaptations for implementation of the environmental

(a) Framework Standard

The policy must include:

 a clear statement of overall environmental objectives,

(b) Guidance to Meet the Framework Standard

Additionally the organisation will need to:

An example of a model environmental policy can be seen in the Compendium of Good

(c) Guidance for Certification to ISO 14001

Make the environmental policy available to the public

(d) Reference to Specific Standards and Further Guidance

 Compendium of Unilever Policies for Safety, Health and Environment

Section 3.1 - Significant Environmental Aspects

(f) Flow chart of requirements

Pre pare and do c ume nt an

Po lic y to be autho ris e d and

Re vie w e nviro nme ntal po lic y annually,

3.1 SIGNIFICANT ENVIRONMENTAL ASPECTS

(a) Framework Standard

(b) Guidance to Meet the Framework Standard

The identification and effective elimination, reduction and/or improved control of an

The identification and evaluation of an organisation’s environmental aspects is essential if

The key elements are:

 The identification of the organisation’s environmental aspects

 The evaluation of these environmental aspects using risk assessment methodology.

 The significant environmental aspects will need to be documented and periodically

 The evaluation of significant environmental aspects should be part of the management of

Guidance on and the development of a Register of significant environmental aspects is given

Determination of the Scope of the Assessment

Identification of Environmental Aspects

The identification of environmental aspects should be conducted using a systematic approach

Aspects associated with product use Emissions to Air

Solid waste Nuisance

Aspects associated with product and pack design Emissions to Air

Aspects associated with product and process innovation Emissions to Air

 Direct and Indirect

 Past, Present and Planned Operations

 Normal, Abnormal and Emergency

The most systematic way to identify an organisation’s environmental aspects is to initially

Determination of Significant Environmental Aspects

ii) Risk Assessment

Documentation of Significant Environmental Aspects

The documented significant environmental aspects will need to be reviewed periodically to

(c) Guidance for Certification to ISO 14001

Written procedure for identification and evaluation of environmental aspects