Summary

An organisation’s activities, products and services that interact with the environment are
referred to as “aspects”, which may have a negative or positive impact on the environment.
Typically, aspects might include emissions to air, discharges to water and waste arisings,
which in turn may generate environmental and health impacts such as global warming, water
pollution or contaminated land.

Some activities, such as those of an office-based service, will have relatively minor
environmental impacts, such as energy used and emissions linked to air conditioning.
Whereas some heavy industrial aspects such as processes that cause emissions to air and
discharges to water may have significant environmental impacts.

Managing environmental aspects and impacts is arguably the most important component of
an environment management system. This topic explains how to identify environmental
aspects and related impacts and provides useful methods for determining relative significance
in terms of risks to the environment. It also explains how to compile a register of significant
aspects and impacts.

In Practice
What is an Environmental Aspect?

An environmental aspect is described in BS EN ISO 14001 as an “element of an

organisation’s activities, products or services that interacts or can interact with the
environment”.

Identifying environmental aspects should take account of whether a particular activity,

product or service causes:

 air emissions
 effluent discharges
 waste arisings
 land contamination
 use of resources (eg, water, fuel and natural resources and materials).

The above aspects relate to those an organisation can control. There are other aspects over
which the organisation may have “control” or “influence”. These can include:

 product design — to improve environmental performance or extend life of products

 packaging — to minimise the use of material resources and energy
 performance — of contractors (on site) and suppliers of goods and materials
 land use — improve biodiversity and wildlife habitats on site.

What is an Environmental Impact?

Once the environmental aspect and the cause of that aspect have been identified, the next step
is to identify the potential environmental impacts associated with it that may adversely affect
the environment and human health. An environmental impact is described in BS EN ISO
14001 as a “change to the environment, whether adverse or beneficial, wholly or partially
resulting from an organisation’s environmental aspects.

The principal types of impacts are:

 those associated with inputs, eg extracted resources used in the form of raw materials
and energy — that can give rise to land degradation and depletion of natural resources
 those associated with outputs, eg emissions to air, discharges to water and waste
arisings — that may cause pollution
 those associated with on-site activities and processes, eg storage, cleaning, assembly
and packaging — that can also cause pollution or loss of materials and other
resources.

Requirements of ISO 14001

ISO 14001 requires organisations to use a systematic approach to determine its aspects and
impacts, by having documented procedures which:

 determine the environmental aspects of its products, services and activities, taking
into account current and planned activities, covering the aspects that it can both
control and influence
 determine the environmental impacts of each aspect
 assess the significance of these aspects and impacts.

An organisation must also consider:

 aspects which are under direct management control

 aspects which are indirect and do not fall under management control
 aspects which can be influenced, if not controlled
 past, current and future aspects
 actual and potential aspects
 linkages between environmental aspects and legal or other requirements.

Requirements of EMAS

The Eco-Management and Audit Scheme (EMAS) includes ISO 14001 as a specification for
an environmental management system (EMS), but goes beyond the EMS standard by stating
types of direct and indirect environmental aspects, as well as being more prescriptive when
determining significance. Furthermore, EMAS requires organisations to integrate a ‘life cycle
perspective’ when determining environmental aspects and also specifies that environmental
aspects must be considered for the initial review and environmental statement, which are
required for EMAS.

Processes, Aspects and Impacts Examples

The table below shows some types of activities and processes with examples of their aspects,
and subsequent impacts. More examples are shown in the annexes of ISO 14004: 2004.
 Example of Processes and Related Aspects and Impacts
Process Aspect Impact
Generation of  Unsustainable losses of
 Extraction of coal
electricity by coal natural resources
fired power stations
 Creation of photochemical
 Emissions of acidic gases
ozone, which affects plants
such as nitrogen oxides
and animals

 Emissions of carbon dioxide

 Climate change (via global
(and possibly other
warming)
greenhouse gases)

 Reduction of climate
Generation of  Zero emissions during change impacts and
electricity by wind generation sustainable energy
turbines production

 Location on hills  Visual impact

 Noise when turbines are

 Noise nuisance
moving

 Unsustainable
Paint spraying  Consumption of paints and
consumption of natural
using oil-based solvents
resources
paints and solvents
 Creation of photochemical
 Emissions to air of solvents ozone and other pollutants
during use that affect human health
and the environment

 Capture of overspray,
 Air emissions from
resulting in hazardous waste,
incineration, eg carbon
where disposal route may
dioxide, resulting in
either be incineration or
climate change. Air
conversion of secondary
emissions from SLF use.
liquid fuels (SLF)

Transportation of  Unsustainable losses of

 Use of oil-based fuels
goods using motor natural resources
vehicles
 Climate change (via global
 Emissions of carbon dioxide
warming)

 Emissions of particulate  Impact on human health,

matter especially people prone to
 Example of Processes and Related Aspects and Impacts
Process Aspect Impact
respiratory ailments

Positive and negative impacts

A single process can typically have many aspects and each aspect can have more than one
impact. For example, paint spraying can be an inefficient process and up to half the sprayed
paint can be wasted. The excess paint is typically captured using water that contains
chemicals to hold the paint and which produces a sludgy, waste effluent which may be
hazardous.

If the disposal route for the sludge is incineration, there will be air and solid emissions from
the incineration process. If the sludge is recycled into a secondary liquid fuel (SLF) and then
used as a substitute for fossil fuel in cement manufacture, for example, the overall impacts
may be both positive and negative. On the negative side, there will still be air emissions from
cement manufacturing, but this process removes the need for:

 landfilling the sludge, resulting in potentially polluting leachate and loss of land
resource
 primary air emissions from the incineration of sludge.

On this basis, there may be net positive impact from converting the sludge to SLF, noting that
commercial and stakeholder considerations may also come into play.

Direct and Indirect Environmental Aspects

A direct environmental aspect is one that is directly attributable to an activity or process and
can therefore be controlled. Indirect environmental aspects are typically those that arise
before an activity (known as upstream aspects) or after the activity (known as downstream
aspects).

Examples of upstream environmental aspects include:

 extraction of raw materials and resources

 sources of energy production
 packaging used by suppliers
 chemical content of a product
 manufacturing processes used by suppliers.

Examples of downstream environmental aspects include:

 energy use of products

 use of product by a customer
 disposal processes for by-products
 end-of-life issues of products.
An organisation cannot always control indirect environmental aspects, such as those in the
supply chain, but it can often influence suppliers and users to reduce, minimise or eliminate
the impacts caused by such aspects.

Ways to Influence the Control of Indirect Aspects and Their Impacts

Process Indirect aspects Influencing mechanism
Changing to energy suppliers who use a
Generation of electricity Releases of air
higher proportion of “low or no carbon”
by fossil fuel use emissions
sources
Requiring suppliers to increase fuel
Transportation of raw Releases of air
efficiency and improve logistics, ie reduce
materials by motor emissions (also traffic
the net emissions of air pollutants per unit
vehicles congestion)
of raw material transported per mile
End-of-life of products, Offering incentives to send spent toner
Waste disposal of spent
eg printer toner cartridges back to the manufacturer for
toner cartridges
cartridges refilling and recycling
Multiple direct and Requiring suppliers to reduce their own
Manufacturing of
indirect inputs and environmental impacts through
components for use in
outputs from implementing an EMS (ISO
assembly of products
manufacturing 14001/EMAS)

Suggested Approach — Aspects and Impacts Analysis

The United Kingdom Accreditation Service guidance to accreditation bodies requires EMS
assessors to verify that an organisation’s approach to aspects and impacts analysis is
appropriate to its activities, products and services.

A suggested approach to determine aspects and impacts, according to their significance,

includes the following five steps:

1. Identifying activities, component processes and products under all applicable

conditions.
2. Determining their environmental aspects.
3. Determining the impacts of these aspects.
4. Assessing the significance of these impacts.
5. Ranking the impacts according to their significance.

Identifying activities, processes and products

The first step is to analyse what an organisation does by describing its activities. Each activity
has an outcome, which may be a product or service, while activities also typically consist of
component processes. These can be mapped using a table or flow chart (process mapping).
When creating flow charts, consider normal conditions, abnormal events, historical
conditions and planned changes. The table below shows some examples of how normal,
abnormal, historical and planned events can affect the environmental aspects and impacts of
fuel storage. As well its own activities, an organisation also needs to take into account those
of its contractors and suppliers.

Examples of Normal, Abnormal, Historical and Planned Events on Environmental

Aspects and Impacts
Condition Process Aspect Impact
Above-ground volatile fuel Air pollution, such as
Evaporative
storage in containers with photochemical ozone production
Normal losses during
secondary containment — and its effects on plants and
filling
refilling the containers animal life
Spills, but within
Lack of control of filling,
Abnormal the contained Losses of a limited resource
resulting in overfilling
area
Controls to prevent Maximum efficiency of fuel
overfilling and recovery of Closed system to transfer due to minimisation of
Planned
evaporative, displacement prevent losses losses — resource use efficiency
losses and reduction of air pollution
Underground storage of
Underground Pollution of groundwater,
Historical fuels, with tanks still in place
leakage of fuels contaminated soil
and badly corroded

Note:

Aspects are not always related to releases (outputs). They also relate to inputs, eg
procurement.

Determining environmental aspects

EMAS and several standards in the ISO 14000 series, eg ISO 14031 for environmental
performance evaluation (EPE) and the ISO 14040 series of standards for life cycle analysis
(LCA), use an approach based on the mass-balance model or input-process-output model.

This model states that for every process, the inputs must be equal to the sum of the outputs
plus any losses through process inefficiencies and by-products. Using this approach enables
an organisation to quantify several measures, such as:

 amounts of raw materials used per unit activity or product

 consumption of energy per unit activity or product
 amount of waste produced for each process
 releases to atmosphere or water
 amount of fuel used to transport a unit product over a specified distance.
This approach underpins both EPE and LCA as such data allows an organisation to
understand the details of significant environmental aspects. Once such data is known, an
organisation can then target improvements at specific areas, eg increasing the fuel-use
efficiency for transporting goods.

A simplified flow chart for paint-spraying can show both the processes at each stage, together
with the inputs and outputs for each step.

Using the combination of process flow charts and input-process-output models can therefore
help an organisation to:

 determine the processes which combine to form an activity

 determine the environmental aspects for each process, by analysing the inputs and
outputs
 assess direct and indirect environmental aspects
 show the linkages between individual aspects and the laws or other requirements
which affect them.

Aspects to impacts

As an impact is the result of an interaction between an aspect and the environment, the next
step is to determine the nature of that interaction. An effective way of doing this for direct
environmental aspects — and in particular, releases to the environment — is to use a model
frequently employed for the assessment and management of contaminated land.

This model states that for every release from a process, there will be a source, a pathway that
it follows, and a point where the release interacts with “receptors” in the environment. The
following table shows some examples of sources, pathways and receptors.

Examples of Sources, Pathways and Receptors

Environmental aspect Source Pathway Receptor
Noise Machinery Air Local houses
The local environment and
Particulate emissions Boilers Air
local population
Effluent from spills Damaged Drainage Local rivers
 Examples of Sources, Pathways and Receptors
Environmental aspect Source Pathway Receptor
containers systems
Leakage of fuel from Permeable
Tanks Groundwater
underground storage tanks ground

Having determined the pathway and the actual or potential receptors for a release, the next
stage is to determine how such releases impact on the environment. Among other things, the
organisation should consider issues such as:

 effects of using land and resources

 pressures of activities on biodiversity
 acidification of water and soil
 changes to river quality
 effects of photochemical ozone
 effects of greenhouse gas emissions
 effects of noise on local populations and wildlife
 effects (including visual amenity) of quarrying and extraction of raw materials
 sensitivity of plants and animals to different releases
 people (those directly affected and other stakeholders).

Defining significance

A commonsense approach is to establish whether a particular aspect has the potential to have
a negative (or positive) impact on the environment. Activities that are subject to
environmental regulations will signal that environmental aspects and impacts are significant
and need to be properly managed.

There are statutory requirements for the controlled release of certain substances to air, land
and water, eg the release of polluting substances into watercourses will require a discharge
consent from the Environment Agency. Guidance on the significant impacts associated with
particular industries are prescribed in regulations, guidance notes and various authorisations
from the Environment Agency. See Croner-i Legislation Tracker.

The criteria for significance will need to consider the type, size and frequency of a particular
aspect and the potential scale, severity and duration of the associated impact. The scope of
significant impacts may extend beyond those controlled through regulations. Stakeholder
issues, for instance, are not always linked to legislation, yet they can still be highly
significant. For example, the noise produced on a site may not contravene regulations, but if
the site is located in a populous area, the noise may result in complaints from local residents.
An organisation’s relationship with the local community is an important issue and noise
levels will therefore be a significant aspect on that organisation’s register.

Each organisation should define its own significance criteria, recognising that such criteria
should be relevant, justified and consistent. The key point is acknowledging the “need to
manage” significant aspects associated with their activities. The list of “need to manage”
aspects will fall into a range of groups; for example, those that are managed for:

 legislative/regulatory compliance, eg liquid effluents, air emissions and waste

  performance targets for water, energy, raw materials usage, etc
 staff motivation and awareness training
 environmental impacts that include safety, eg hazardous chemicals storage, use and
spillage prevention
 routine planned maintenance, prevention of leaking pipes and smoke from boilers, etc
 multi-disciplined activities such as new developments.

As a guide, the following factors could be considered.

 Source of impact (the aspect of a company’s operations)

o Is the source a hazardous substance or process?
o Is the impact regulated, subject to policy or codes of practice? (If yes, there
should be cross-reference to a register of regulations?
o Transport route (eg transport of liquid via surface water drains to a river).
o Does the impact arise from normal, abnormal or emergency operations (or a
combination)?
o Is the impact a result of past, current or planned activities (or a combination)?
 Consequences
o Does the impact involve potential financial/legal liabilities?
o Is the impact likely to be the subject of stakeholder concern?
o Has the probability and consequence of the undesired event been considered?

Evaluating significance

As a general rule, a significant aspect is one that has, or can have, a significant impact.
Evaluation can be based on the consideration of both environmental concerns and business
concerns. Environmental concerns include the scale, duration and nature of the impact and
the likelihood of the impact occurring. Business concerns include adverse publicity,
inefficiencies (eg heating and waste materials), legal exposure and risk of prosecution and the
cost of preventing the impact.

The evaluation of significance requires a transparent methodology to determine the relative

significance of aspects and associated impacts. The methodology may be qualitative or
quantitative, or a combination of both. Establishing a scoring system can help to establish
priorities for action. The key is to ensure that the methodology remains consistent for all
aspects that give rise to environmental impacts.

One option might be to consider a “Control” rating and “Severity of Impact” rating matrix.
The simple equation would be represented as “Significance = Control × Severity of Impact”,
similar to risk-type matrices. Both the control and severity ratings would need to be explained
and given numerical values. For example, a “severity” rating 5 might be the highest rating
with potentially serious impacts whereas “severity” rating 1 might be insignificant. Similarly,
a high 5 control rating would be where there is no control and a low 1 control rating would
represent a high level of control. In this way it is possible to demonstrate levels of
significance for each aspect and associated impact.

A simple approach is to assign each aspect a score of 1 to 5 for each significance criterion,
and then add the scores together. For example, a score of 1 for the first criterion — the
potential to cause environmental harm — would signify low potential, whereas a score of 5
would signify high potential. The table below shows three aspects spanning the spectrum of
significance using this scale.

This listing process can be documented in a spreadsheet that can be designed with additional
columns for further information to be inserted later for other functions of the environmental
management system. The spreadsheet will also satisfy ISO 14001 Clause 4.4.4 on
Environmental Management System Documentation.

Calculation of Significance
Environmental aspect and impact
Emissions of carbon Storage of fuels and
Criterion Effects of
noise dioxide to the chemicals —
atmosphere accidental spills
Potential to cause environmental
1 5 5
harm
Sensitivity of the environment 3 5 3
Size and frequency of the aspect 1 5 3
Importance to employees and
1 5 3
stakeholders
Applicable legislation 2 3 5
Totals 8 23 19

It is important to agree the criteria for assessing significance. This might involve the EMS
review team and others with operational or environmental expertise, using the 1–5 scoring
approach identified above to assign scores and produce a qualitative/quantitative assessment
of significance. Croner’s Environmental Aspect Evaluation Record provides a useful
template.

Once assessments have been carried out, the next step is to look at the individual scorings and
extract the higher scoring items which are deemed significant. This then forms the list of
aspects and impacts which can be included in a register of environmental aspects and
impacts.

Prioritising aspects

The higher the rating, the more significant the aspect. On this basis, the table above indicates
that releases of carbon dioxide from energy sources is the most significant while the storage
and handling of chemicals and fuels would be the next most significant. Both of these aspects
would therefore have a top priority for action.

Having graded the aspects and impacts according to their significance, it is useful to tabulate
them showing the laws and other requirements which apply to them. This demonstrates clear
linkages between aspects, impacts and legal/other requirements.

The assessment of significance does not necessarily require a numerical approach. However,
numbers can be a useful way of imparting relative significance (eg to senior managers),
particularly if the numbers vary greatly.
The significance of an aspect may change depending on circumstances. For example, new
laws on energy efficiency and carbon emission trading could increase the rating for emissions
of carbon dioxide under applicable legislation.

On the other hand, although the sensitivity of the environment to fuel and chemical spills
cannot be reduced, the size and frequency of such spills can be reduced and therefore this
aspect would fall in significance as better management practices reduce its environmental
risk.

Environmental risk analysis

The approach shown in the table above is a simple form of environmental risk analysis,
where the first three criteria underpin a technique often used in safety assessments, known as
Failure Modes Effects Analysis (FMEA). While the scales and criteria shown in the
Calculation of Significance table can be effective for most circumstances, the approach can
be less effective for an organisation with many complex activities and many releases to the
environment. Under such conditions, FMEA can be a further useful tool.

Using FMEA, environmental risk is defined as:

 the chances of an environmental incident occurring

plus

 the chances of detecting the incident

both then multiplied by

 the severity of the consequences.

FMEA typically assigns a score of 0 to 100, with the scaling factors below.

FMEA Scale Factors

Chances of occurrence Chances of detection Severity of the consequences
Rating Rating Rating
Very high 5 Very high 0 Very high 10
High 4 High 1 High 8
Moderate 3 Moderate 2 Moderate 6
Low 2 Low 3 Low 4
Very low 1 Very low 4 Very low 2
None 0 None 5 None 0

For example, a poorly maintained chemical storage tank near a storm water drain, with no
emergency preparedness and no leak detection would rank the following scores.

 Chance of occurrence — very high = 5.

 Chance of detection — very low = 4.
 Severity of consequences — very high = 10.
The risk rating of the storage tanks would be 90 using FMEA, or high enough to place
remedial actions high up on the objectives and targets.

Following remedial actions — which might include secondary containment, leak detection,
better procedures for managing chemical storage and handling, and provisions for
emergencies such as spill kits — the rating would change as follows.

 Chance of occurrence — very low = 1.

 Chance of detection — certain = 0.
 Severity of consequences — very high = 10.

The risk rating is therefore reduced from 90 to 10, so the environmental aspect falls
dramatically in significance.

Regulatory Tools for Environmental Risk Assessment

The Environmental Agency’s (EA) environmental permit risk assessment guide explains how
to do a permit-related risk assessment. The Department for Environment, Food and Rural
Affairs has published a scheme for local authorities for use on industrial processes regulated
under the UK environmental permitting regulations.

Both these methodologies assess the environmental sensitivity, the environmental hazards of
the installation being considered, and how operators manage and control these risks.

Please note that the EA has withdrawn the original Operator and Pollution Risk Appraisal
(OPRA) scheme for sites operating under the Environmental Permitting Regulations (EPR)
and is moving towards a performance-based approach. The new approach is to enable the EA
to better focus on outcomes rather than rules at sites regulated under the Environmental
Permitting Regulations (EPR). The EA will also use innovation to realise step changes in
improved environmental standards and economic efficiencies, which will help drive social,
environmental and economic benefits by recognising positive and socially responsible
behaviours.

Compiling a Register of Significant Aspects and Impacts

The register should be documented in a way that external assessors can read and understand.
The register should explain:

 what the aspect and related impact is and how it arises from the organisation’s
activities.
 the process or method used to determine significance, and the scores or values
attached to the impact (perhaps by reference to supporting documents).
 details of the department and the position of the person responsible for the activity or
process in an organisation which generates the aspect and impact.
 how the organisation manages or controls the impact, ie through linkage to the rest of
the management system (such as the company policy, objectives and targets, the
register of regulations, and operational control procedures).
 The procedure used within the EMS to ensure that the Register of Environmental
Aspects and Impacts is kept up to date, such as a defined review period.
A register of environmental aspects and impacts provides an essential reference for
prioritising objectives and targets to improve overall environmental performance.

Format of the register

The register may be presented in a variety of formats.

A preferred approach might be a register containing the full range of identified aspects and
impacts, highlighting those assessed as being significant. This would facilitate periodic
reviews and updates which might reveal, for example, some impacts not previously
considered to be important becoming significant because of changes in legislation or
scientific knowledge, or through increase or change in production methods.

A hard copy of the register should be maintained as the primary copy. For updating
procedures, the register could either be computer-based or a paper document. See a template
of a Register here.

Additional Sources of Information

There are various sources of information which may be available and useful to an
organisation in determining the significant environmental impacts, such as:

 information contained in waste transfer notes

 conditions for process authorisations under the Environmental Protection Act 1990
 effluent consent conditions
 information gathered during applications for legal consents and authorisation
 information compiled for the purposes of the Control of Substances Hazardous to
Health Regulations (COSHH) 2002, eg safety data sheets
 information gathered during environmental assessments for new projects, where
relevant
 industry Codes of Practice.

Communications

EMAS requires organisations to establish mechanisms to control communications with

interested parties. Similarly, ISO 14001 also outlines certain requirements for
communicating, both internally and externally, an organisation’s environmental aspects and
its EMS. Guidelines on how this can be achieved are contained in the recently updated ISO
14004 EMS guidance standard.

It is important for an organisation to be aware of the concerns and requirements of interested

parties and to ensure that communications are dealt with in the most appropriate and efficient
way possible. Depending on the nature of the communication, this may need to be passed on
to the appropriate person within the organisation who is able to deal with it.

In all cases, there should be records which detail the correspondence which occurs.

List of Relevant Legislation

  EC Regulation No. 761/2001 allowing voluntary participation by organisations in a
Community Eco-management and Audit Scheme (EMAS)

Further Information
Publications

British Standards

The following are available from BSI

Clause 6.1.2: Environmental Aspects

The organization will need to determine the environmental aspects that relate to activities,
products and services within the scope of its Environmental Management System.  It is also
necessary to:

 determine where aspects can be controlled or influenced

 identify the environmental impacts associated with its environmental aspects
 take a lifecycle perspective in relation to its environmental impacts
 consider planned changes, such as new or modified activities, products or services
 take into account abnormal conditions and foreseeable emergency situations

Terms relating to clause 6.1.2

 The “environment” is the surroundings in which the organization operates and

includes air, water, land, natural resources, fauna, flora, humans and their
interrelationships.
 The organization can interact with the environment in many ways, such as through its
activities, products or services. Such interaction with the environment is termed an
“environmental aspect”.
 “Direct environmental aspects” are those which the organization can influence or
control.
 “Indirect environmental aspects” are those which the organization can influence but
cannot control.
 An “environmental impact” is an adverse or beneficial change to the environment
resulting from the organization’s environmental aspects.
 Taking a “lifecycle perspective” is to consider the environmental aspects of an
organization’s activities, products, and services that it can control or influence.
Lifecycle stages include acquiring raw materials, design, production, transportation,
delivery, use, end-of-life treatment and final disposal.

Having identified actual and potential environmental impacts and aspects for its operations,
the organization must determine which are significant. A defined method and criteria must be
applied to do this. Significant environmental aspects must be communicated throughout the
organization as appropriate.

The organization is required to maintain documented information of:

  environmental aspects and associated environmental impacts
 the criteria which has been applied to determine which environmental aspects result or
may result in a significant environmental impact
 significant environmental aspects

Clause 6.1.2 Environmental Aspects – Quick Check

 Have you identified environmental aspects and impacts:

 Under normal operating conditions?
 All normal activities, products and services?
 For abnormal activities, products or processes?
 For all accidents and potential emergency situations associated with activities,
products or processes?
 Associated with past, present and planned activities, products or processes?
 Associated with the full life cycle of the organization’s products or service?
 Have you identified where aspects can be influenced?
 Have you identified where aspects can be controlled?
 Has a criteria and method been established to determine which environmental aspects
result or may result in significant environmental impacts?
 Is the criteria for determine significant aspects documented?
 Is the criteria for determine significant aspects consistently applied?
 Do employees who assess aspects and impacts to determine significance giving
instruction or training on use off the criteria?
 Are significant environmental aspects identified and documented?
 Have you considered how significant environmental aspects are to be communicated
within the organization, and to whom?
 Are the organization’s environmental aspects regularly reviewed and revised as
necessary?