BS 8555: Implementing an EMS

In April 2003, BS 8555, ‘Environmental management systems – guide to the phased implementation of an environmental management system including the use of environmental performance evaluation’ was published. As Catherine Golds explains, the standard was written in response to a demand from the market place for a stepped approach to environmental management systems (EMSs).

The BS 8555 standard breaks the implementation of a formal EMS into six manageable phases and also focuses on environmental performance evaluation (EPE).

The six phases of BS 8555 are:

• commitment and establishing the baseline
• identifying and ensuring compliance with legal and other requirements
• developing objectives, targets and programmes
• implementation and operation of the EMS
• checking, audit and review
• EMS Acknowledgement (getting ISO 14001 and/or EMAS)

Each phase has a number of stages and each stage is described in a ‘stage profile’, which includes why and how to implement each stage as well as who should be involved. It also includes outputs and achievement criteria for each stage. The development of environmental performance indicators is a key feature of BS 8555. These indicators allow performance against environmental objectives and targets to be monitored and evaluated over time, demonstrating progress in continually improving environmental performance. Further information on EPE is contained in a standard in the ISO 14000 series, ISO 14031.

Auditors that are regularly assessing organizations to ISO 14001 will appreciate the time and effort that organizations invest in implementing and maintaining their system. The process of an assessment by an accredited certification body can be daunting for these organizations, in particular for the small and medium sized enterprises that will face time and resource constraints. With this in mind, the Acorn Scheme enables UKAS accredited inspection for organizations improving their environmental performance in accordance with the phases of BS 8555.

The Acorn Scheme is administered by the Institute of Environmental Management and Assessment (IEMA). It provides a framework for all organizations, regardless of shape, size or sector to be independently inspected against the achievement criteria in BS 8555 and receive formal recognition of the progress they have made in improving their environmental performance. Organizations can become registered to any phase within the IEMA Acorn Scheme up to and including phase 5. Beyond phase 5 they should seek EMAS or ISO 14001 registration.

An Acorn inspection aims to systematically compare the implemented elements of an organization’s EMS with the achievement criteria presented in each stage profile of the BS 8555 guidance standard. It is up to the client organization to determine which phases they wish to be inspected to. They can opt to be inspected after implementing each phase or just at a set point. If this is the case then the assessor inspects all the phases the client has implemented. The registration under the Acorn Scheme is a 12 month registration therefore the re-inspection process is a complete visit every 12 months. This may be at the same phase as the client is already registered to or they may choose to progress to a further phase. As with the original inspection, all the achievement criteria in all the phases must be met in order for the client to gain registration. The assessor will raise non-conformities as appropriate during the inspection where the client can not demonstrate that they have met one or more of the achievement criteria in a given stage profile of BS 8555. The client is given a 3 month window to close these out in order to gain registration under the Acorn Scheme. In some cases this can be closed out through documentary evidence but it may require an additional visit. The assessor is also encouraged to raise observations, in particular relating to the environmental performance of the organization. As always, positive observations are welcomed as well as constructive improvement opportunities.

There is a focus on legal compliance in phase 2 of the BS 8555 standard. Current experience in inspections under the Acorn Scheme has showed that the areas that require particular attention are the identification methodology for legislation. In some cases this is not adequately defined and the organization has not completely identified all the legislation and other requirements that apply to their activities. In addition, the assessor should also focus on the system of evaluation of legal compliance as this is still an area where organizations struggle to demonstrate evidence that the level of checks are adequate.

The BS 8555 standard gradually introduces the need for documentation and control of documents as the phases progress. These concepts feature strongly in phase 4. In the early phases, although there is some need for documentation, ‘robust evidence’ is often stated in the achievement criteria. As this is the case, it is critical that the assessor uses his skills of listening, interviewing and seeking evidence through a variety of sources.

As with other EMS audits, the time allocated for the inspection is based on the number of employees, the number of sites, complexity of activities, environmental sensitivity of the site, the nature of environmental impacts and the scope and extent of legal requirements. The competency requirements for auditors conducting this inspection work are similar to the competency required for ISO 14001 certification audits. However, there are additional requirements: an auditor must also demonstrate a good understanding of working within an SME environment; of the BS 8555 standard itself; and a familiarity with the concepts of environmental performance indicators and EPE in general.

About the author

Catherine Golds is Environmental and Health and Safety Business Sector Manager at NQA. Visit www.nqa.com