Environmental management system requirements
Clause map
Clause 4 Context: determine external and internal issues, interested parties, scope and EMS processes. Clause 5 Leadership: top management accountability, policy, and assigned roles and authorities. The policy must commit to protection of the environment, fulfilment of compliance obligations, and continual improvement, and be maintained as documented information.
Clause 6 Planning: 6.1.1 general; 6.1.2 aspects, including life cycle perspective, changes, abnormal conditions and reasonably foreseeable emergencies; 6.1.3 compliance obligations; 6.1.4 planning action; 6.2 objectives and plans.
Clause 7 Support: resources, competence, awareness, communication, and documented information (creation, updating, control).
Clause 8 Operation: 8.1 operational planning and control, with operating criteria, control of outsourced processes, and management of planned and unintended changes; 8.2 emergency preparedness and response.
Clause 9 Performance evaluation: 9.1.1 monitoring, measurement, analysis and evaluation; 9.1.2 evaluation of compliance; 9.2 internal audit; 9.3 management review.
Clause 10 Improvement: 10.1 general, 10.2 nonconformity and corrective action, 10.3 continual improvement.
Traps
'Documented information' replaced documents and records; only required where the standard says maintain or retain. There is no mandatory environmental manual or management representative. Outsourced processes must be controlled or influenced. Objectives must be measurable if practicable and monitored, with plans stating what, resources, who, when, and how results are evaluated. Evaluation of compliance (9.1.2) is separate from monitoring (9.1.1). Correction fixes the problem; corrective action addresses the cause.
Rule of thumb
For every requirement ask two questions: what does the organization actually do, and what evidence proves it? Requirements are 'shall' statements; 'should' and guidance are not auditable requirements.