Iat A

IATA Environmental Assessment
Standards Manual (IESM)

Effective 1 February 2015
2nd Edition
NOTICE
DISCLAIMER. The information contained in this
publication is subject to constant review in the light
of changing government requirements and regula-
tions. No subscriber or other reader should act on
the basis of any such information without referring
to applicable laws and regulations and/or without
taking appropriate professional advice. Although ev-
ery effort has been made to ensure accuracy, the
International Air Transport Association shall not be
held responsible for any loss or damage caused by
errors, omissions, misprints or misinterpretation of
the contents hereof. Furthermore, the International
Air Transport Association expressly disclaims any
and all liability to any person or entity, whether a
purchaser of this publication or not, in respect of
anything done or omitted, and the consequences
of anything done or omitted, by any such person or
entity in reliance on the contents of this publication.
© International Air Transport Association. All

Rights Reserved. No part of this publication may
be reproduced, recast, reformatted or trans-
mitted in any form by any means, electronic or
mechanical, including photocopying, record-
ing or any information storage and retrieval sys-
tem, without the prior written permission from:
Senior Vice President

Member and External Relations
International Air Transport Association
33, Route de l’Aéroport
1215 Geneva 15 Airport
Switzerland
IATA Environmental Assessment Standards Manual (IESM)

ISBN 978-92-9252-628-3
© 2015 International Air Transport Association. All rights reserved.
Montreal—Geneva
IEnvA Standards Manual
APPROVAL PAGE
Step Name Date
Stephen Causby, Manager – IEnvA

Reviewed by: Environmental Assessment, Aviation September 2014
Environment Dept. IATA
Jon Godson, Assistant Director Best

Reviewed by: Practices, Aviation Environment Dept. September 2014
IATA
Michael Gill, Director, Aviation

Reviewed by:
Environment Dept. IATA October 2014
Paul Steele,
Senior Vice President, Member and
Approved by: January 2015
External Relations & Corporate
Secretary. IATA
INTENTIONALLY LEFT BLANK
Contents
RECORD OF REVISIONS i
REVISION HIGHLIGHTS ii
INTRODUCTION iii
Section 1 – Environmental Commitment (ECO) 1
Section 2 – Scope and Locations (SCO) 2
Section 3 – Environment Policy (POL) 4
Section 4 – Aspects & Impacts Register (REG) 8
Section 5 – Roles and Responsibilities (ROL) 9
Section 6 – Documentation and Records (DOC) 10
Section 7 – Legal and Other Obligations Register and Compliance Review (LEG) 13
Section 8 – Aspects and Impacts Significance (AIS) 16
Section 9 – Objectives, Targets and Impact Management (OBJ) 22
Section 10 – Monitoring and Measurement (MON) 27
Section 11 – Communication (COM) 30
Section 12 – Training (TRA) 36
Section 13 – Non Conformity, Corrective Action and Preventive Action (NCC) 40
Section 14 – Operational Control (OPC) 47
Section 15 – Emergency Preparedness (ERP) 51
Section 16 – Internal Assessment (INA) 56
Section 17 – IEnvA Management Review (MGR) 63
RECORD OF REVISIONS
EDITION NUMBER REVISION NUMBER ISSUE DATE EFFECTIVE DATE
Edition 1 0 1 June 2014 1 June 2014
Edition 2 0 1 February 2014 1 February 2014
i
REVISION HIGHLIGHTS
The following table provides a brief description of the most significant changes contained in this IEnvA
Standards Manual Ed2. It is not intended to indicate every editorial change (e.g. typographical
correction, formatting improvement), but should any discrepancy exist, the contents of this manual
have precedence over this table.
IESM Ed. 2 Revision Details
Description of Significant Changes

Section 6 - DOC · DOC 6.06 – Standard has been re-worded by changing the word “recent” to
the word “material”.
· DOC 6.12 – Standard has been removed
Section 9 – OBJ · OBJ 9.07 – Standard amended “The Operator’s environmental
management plan shall include decisions about if and how the
environmental management plan should be communicated and define any
relevant stakeholders.”
Section 10 – MON · MON 10.02 – The words “information on” have been removed from the
standard.
· MON 10.03 – The words “information on” have been removed from the
standard.
standard.
standard. The standard has also be amended to include the words “if and”
to allow an operator to decide not to communicate monitoring results.
· MON 10.07 – The standard has been rewritten to refer back to the
operator’s original document storage process in DOC 6.11.
·
Section 11 - COM · COM 11.05 – “internal” has been replaced with “external” to accurately
reflect the intent of the standard.
· COM 11.06 – “internal” has been replaced with “external” to accurately
reflect the intent of the standard.
reflect the intent of the standard. The words “and tracking” have also been
removed from the standard.
reflect the intent of the standard. The words “and tracking” have also been
removed from the standard.
Section 12 - TRA · Introduction – Partially reworded to provide better clarity.
Section 13 – NCC · Introduction – Amended to include environmental management in addition
to environmental performance.
Section 16 - INA · INA 16.02 Guidance – The term “site walk around” has been replaced with
“visual site assessment”.
· INA 16.06 – Standard was incorrectly numbered and has been corrected to
16.04.
Section 17 - MGR · MGR 17.10 – Typographical amendment.
· MGR 17.11 - Typographical amendment.
· MGR 17.11 – Recommended practice has been changed to a standard with
the amendment of should to shall.
ii
INTRODUCTION
1 Purpose
The IEnvA Standards Manual (IESM) is published in order to provide the Environmental
standards, recommended practices, associated guidance material and other supporting
information necessary for an operator to successfully prepare for an IEnvA Assessment.
The IESM is the sole source of assessment criteria utilized by Environmental Assessment
Organizations (EAOs) when conducting an assessment.
2 Structure
The sections/chapters in the IESM are organized as follows:
Section 1 – Environmental Commitment (ECO)
Section 2 – Scope and Locations (SCO)
Section 3 – Environmental Policy (POL)
Section 4 – Aspects & Impacts Register (REG)
Section 5 – Roles and Responsibilities (ROL)
Section 6 – Documentation and Records (DOC)
Section 7 – Legal and Other Obligations Register and Compliance Review (LEG)
Section 8 – Aspects and Impacts Significance (AIS)
Section 9 – Objectives, Targets and Impact Measurement (OBJ)
Section 10 – Monitoring and Measurement (MON)
Section 11 – Communication
Section 12 – Training (TRA)
Section 13 – Non Conformity, Corrective Action, and Preventive Action (NCC)
Section 14 – Operational Control (OPC)
Section 15 – Emergency Preparedness (ERP)
Section 16 – Internal Assessment (INA)
Section 17 – Management Review (MGR)
3 Examples of IESM Documents and Forms
Certain IESM documents and forms may be depicted in this manual for the illustrative
purpose of providing examples. Some, or all, of these published examples may have
subsequently undergone revision, and thus may not be the current version of the document
and/or form in use for Program activities.
4 IESM Documentation
This IESM Manual, used in association with the following related manuals, together comprise
the IESM documentation system:
1. IEnvA Program Manual (IEPM);
2. IEnvA Recommended Practices (IERPs);
3. IATA Reference Manual for Audit Programs (IRM)
iii
5 English Language
English is the official language of the IEnvA Program, and the IESM documentation is written
in “international” English, using the Merriam-Webster dictionary as the basis (refer to M-W
online at the following internet address: http://www.merriam-webster.com).
6 Software Platform
The IATA standard software platform for IEnvA Program documentation development and
delivery, is the Microsoft Windows Office© suite of software applications. Any document
automation using macros (e.g. within MS Word© or MS Excel©) may not perform as originally
designed when using any other type of platform.
7 Manual Revision
IATA will publish revisions to this manual to ensure the content remains current and meets
the needs of the IEnvA Program.
1. During a regular revision cycle:
a. a change to the IESM will always result in a new Edition of the manual.
b. the cover of the IESM will indicate the Edition’s effectivity date, while the footer of the
pages within will indicate the Edition number and the published date.
c. A revision to the IESM becomes effective on the first day of the third month following
the month the revision is published (e.g. a revision published in October 2010 is
effective on January 2011).
2. During a short revision cycle, where a rapid change to this manual is required:
a. a Temporary Revision (TR) will be issued to the IESM;
b. The TR will indicate:
i. a unique reference number linking it to the appropriate Edition;
ii. an IESM reference number associated to the content requiring change;
iii. a clear effectivity date;
iv. the signature and date of the approving authority.
8 Manual Approval Cycle
1. IATA will internally draft any required changes, in consultation with applicable parties, if
necessary.
2. IATA will determine if consultation is required for any nessesary changes. If consultation
is sought, it will be arranged with the IEnvA Working Group. No defined consultation
period exisits and consultation times will be determined according to nessesary changes
required.
3. Agreed changes by the IEnvA Working group will be incorporated by IATA for final
approval;
4. Final approval is by the Senior Vice-President, Member and External Relations.
9 Content Changes
1. A published revision to this manual will contain a revision bar (e.g. I ) in the left margin,
indicating the adjacent information has been changed.
2. A new edition will be accompanied by a Revision Highlights table that will highlight only
the significant changes made. It is incumbent on the reader to review every Section in
detail to familiarize themselves with any detailed changes.
10 Conflicting Information
1. Manuals within the IEnvA documentation system are not revised concurrently, thus
creating the possibility of conflicting information in different manuals.
iv
2. In the case of conflicting information in different IEnvA manuals, the information contained
in the manual with the most recent revision date can be presumed to superseed any
previous revision date.
11 IEnvA Documents and Forms
This manual, and other referenced IEnvA documents and forms, will be made available on the
IATA IEnvA Extranet. Operators involved in the IEnvA Program will receive access to the
Extranet on signing the relevant IEnvA involvement documents (MOU, contract etc).
12 Abbreviations, Acronyms, Definitions
1. The terminology used in the IESM Manual is consistent with that in the other manuals that
comprise the documentation system. Any related terms, as they are used in the context of
the IEnvA Program and its documents, are defined in the IATA Reference Manual for
Audit Programs (IRM).
2. Where text within the IESM Manual is italicized followed by an asterisk ( * ), this indicates
that the italicized word is defined (e.g. corrective action* ), and the reader is encouraged
to refer to the IRM.
13 Exemptions
The IATA Senior Vice-President (SVP), Member and External Relations, reserves the right to
allow exemption(s) to any requirement of this manual, taking into account all circumstances,
and is responsible for authorizing any such exemption(s).
14 IEnvA Authority
The IEnvA Program operates under the authority of the IATA Environment Committee
(ENCOM) pertaining to the IESM.
v
Section 1 – Environmental Commitment (ECO)
Introduction and Purpose

Having a documented commitment to participate in the operation of the IEnvA Management System is an
essential first step in the process of having a working environmental management system. Commitment to
the program by senior management (and other key stakeholders) is essential for a robust system that will
ultimately drive, track and improve environmental performance of your airline. By demonstrating commitment
from senior management to the IEnvA Management System, it facilitates engagement from a wide range of
stakeholders and staff, ensuring the program will continue into the future, embedded within and essential to
the airline operator’s environmental management.
Background and Basis

This requirement has been made part of the IEnvA Program as it is an essential basis of the standard(s)
(including but not necessarily limited to) ISO 14001, BS8555 and EMAS. It is requirement for program
membership by IATA and is seen as an essential requirement for successful implementation of the IEnvA
Management System.
Requirements and Guidance

ECO 1.01 The Operator shall provide evidence of commitment to the implementation of the IEnvA
Program including endorsement by the CEO, Senior Executive or equivalent.
Guidance
Evidence of commitment to the IEnvA program may include either of the following:
i) Memorandum of Understanding (MoU) signed by the Chief Executive and/or other senior
executive demonstrates a clear commitment to the program; and/or
ii) Contract with IATA for IEnvA support including documentation, registration, training, assessment
and software tools represents a key milestone for the development of IEnvA.
The European Eco-Management and Audit Scheme (EMAS) regulation states that “…the organization
should acknowledge that commitment, responsiveness and active support from the side of the
management is a prerequisite for the success of those processes.” Awareness of practical business
programs such as IEnvA is likely to strengthen the level of long-term commitment from senior
management towards building and running an effective EMS. A detailed briefing of the benefits of
incorporating the IEnvA Management System and the provision of short awareness sessions (online or
live) will assist senior management to develop a clear understanding of the reasons for developing and
implementing the IEnvA Management System. The provision of support and guidance available through
the IEnvA Management System means that the process of developing an EMS will be more efficient and
effective, thereby reducing the resources expended by the airline operator.
ECO 1.02 The Operator shall ensure that a documented commitment to human and financial
resources is made available for the implementation and operation of the IEnvA Program.
Guidance
To meet this standard, the Operator can do the following:
i) Identify specific employee(s) with responsibility for implementing the IEnvA Management System
with sponsorship by a Senior Executive that reports to the CEO, Board of directors or equivalent,
ii) The selected employee(s) is (are) competent and provided with sufficient time to manage the
IEnvA Program,
iii) Sufficient financial resources are available to continue with the maintenance, day to day
operations and future improvement of the IEnvA Program.
1
Section 2 – Scope and Locations (SCO)

An appropriate awareness and understanding of the selected scope and boundaries for the Operator’s
IEnvA Program is necessary so that business activities that fall within the chosen scope can be properly
assessed and controlled, where necessary. Independent assessment of the IEnvA Program requires the
boundaries (physical locations related to the Operator’s chosen scope of activities) to be clearly stated, and
this is to be documented within each Operators IEnvA Program documentation.

This requirement has been made part of the IEnvA Program as it is an essential part of the standard(s)
(including but not necessarily limited to) ISO 14001:2004, BS855:2003 and EMAS (Regulation 1221/2009). It
is seen as an essential requirement for successful implementation of the IEnvA Management System.

SCO 2.01 The Operator shall document its locations in which it conducts activities that are within the
scope of its IEnvA Program.
Guidance
There are two distinct categories of scope within the IEnvA Management System which are defined as
CORE and CORE+. Operators will initially focus on CORE activities, followed by CORE+ activities
relevant to their business model.
CORE includes management of environmental aspects arising from:
i) Flight operations (transportation of passenger and freight) including; engine start up, taxiing, take-
off and landing, cruise, use of auxiliary power unit (APU), cabin operations and other
environmental impacts generated during the flight (waste water, cabin waste, potable water
uptake) phase.
ii) Corporate activities within the Operators country of origin including, office administration buildings,
corporate canteens, sales desks, station management offices, plant rooms associated with
corporate offices (e.g. Heating, Ventilation and Air conditioning), car parks, security and ancillary
services including procurement services, training, marketing and landscaping/horticulture around
any buildings.
CORE+: management of environmental aspects arising from modules to be developed in the future
include:
i) Ground Operations: ground support equipment (GSE); airside traffic; aircraft refueling; and, aircraft
de-icing;
ii) Aircraft maintenance, repair, and overhaul (MRO);
iii) Catering;
iv) Laundry;
v) Retail shops;
vi) Warehousing and freight handling (including refrigeration).
The Locations Register will be an essential reference document when understanding the operating
profile of the Operator for Environmental Assessment Organizations (EAOs) and internal staff alike. As a
majority of legal requirements have a fixed spatial point (i.e. the legal requirements relate to a specific
area or location) it is imperative to understand the locations and extent of the activities at which the
Operator functions. Airlines are somewhat unique in the sense that they may have potentially extensive
number of flight destinations and physical locations (offices, hangars, warehouses, etc.) all with varying
operational limits. Some locations may consist of single sales or service desk with a leased area of
2
SCO
<10m2 and a single staff member with no exclusive electricity or water utilities; where other locations are
large multilevel office buildings with large number of staff. Despite differences in the operations at each
location it will become important in Section 7 (Legal and Other Obligations) to understand how
significant each location is.
Evidence of compliance to the requirements could include:
i) A complete list of flight destinations and locations register of corporate activities,
ii) Supplementary evidence maybe requested by an Assessor to be submitted in a timely fashion;
evidence may include a building inventory, lease contracts, flight schedule, destination map, etc.
SCO 2.02 The Operator shall review and update, if necessary, its locations register at least annually.
3
Section 3 – Environment Policy (POL)

The need for a documented Environmental Policy is well understood by most airline operators who wish to
develop a coordinated approach to environmental management. The policy describes the environmental
direction, aspirations and intent of the Operator to improve its environmental performance and comply with
relevant legal and other obligations that are relevant to the scope of the IEnvA Program. The policy sets the
tone and basic governance and framework of the IEnvA Program. The aspirations outlined within the policy
should cascade into appropriately articulated objectives and then into measurable targets with supported
environmental programs within the IEnvA Management System. The policy provides a clear message to
internal and external stakeholders, and for this reason the wording should be carefully constructed and
phrased so that a wide range of interested parties can interpret the intent of the policy consistently.
This chapter provides concise standards and guidance to enable Operators to develop and implement an
appropriate environmental policy.

is a requirement for program membership by IATA and is seen as an essential requirement for successful
implementation of the IEnvA Management System.

POL 3.01 The Operator shall have developed an Environmental Policy that is endorsed by the Senior
Executive, CEO or equivalent.
Guidance
The environmental policy is comprised of phrases that have been established, reviewed and agreed by
the Senior Executive or equivalent, to support the overall environmental or sustainability strategy that the
Operator may have. This also ensures that the policy is aligned with other strategic business objectives
and no conflicts will ensue.
NB* EMAS (Section B4) includes greater emphasis on ‘employee participation’ in the development of the
environmental policy than ISO 14001:2004. Some Operators may wish to seek comments on the
drafting or review of the policy from the employees; however this is not a requirement for the IEnvA
Program.
Evidence of compliance with this requirement will be in the form of a signature from the CEO or
equivalent at the bottom of a company approved Environmental Policy.
POL 3.02 The Environmental Policy shall include a commitment to comply with applicable legal
requirement and other obligations.
Guidance
The commitment to comply with legal requirements and other obligations should be included within the
policy and by making this declaration the Operator acknowledges it will make every effort to remain
compliant with environmental regulations. The statement of commitment is easily placed within the text
of the policy, but this does obligate the airline operator to develop effective mechanisms to identify, keep
up to date with and comply with the legal or other obligations which correspond to the Airline Operator’s
activities.
‘Other obligations’ may include codes of practice to which the airline operator subscribes and/or
compliance with 3rd party environmental obligations such as airport noise regulations or specific
contractual requirements placed upon the airline operator. This may also include IATA mandates.
4
POL
Compliance with applicable environmental legal and other obligations represents a critical performance
indicator which will be verified during the IEnvA Assessment.
POL 3.03 The Environmental Policy shall include a commitment to continual improvement of its IEnvA
program and prevention of pollution where reasonably practicable.
Guidance
These requirements are included within the environmental policy to ensure that the Operator continually
improves the IEnvA Program. While prevention of pollution is the intent of the clause, some activities of
Operators will inevitably produce negative environmental impacts where prevention of pollution is not
possible (e.g. burning fuel in aircraft engines). In these circumstances, the impacts should be reduced to
as low as reasonably practicable. There are two elements to what is ‘reasonably practicable’. An
Operator must first consider what can be done - that is, what is possible in the circumstances to reduce
the environmental impact. They must then consider whether it is reasonable, in the circumstances to do
all that is possible. When considering what is reasonable practicable the Operator should consider the
pollution prevention hierarchy of:
i) Prevention
ii) Reduction
iii) Reuse (then Recycle)
iv) Control
Continual improvement can be demonstrated by the following:
i) Expansion: more and more business areas get covered by IEnvA
ii) Enrichment: more and more activities, products, processes, emissions, resources etc. get
managed using IEnvA environmental guidance.
iii) Upgrading: an improvement of the structural and organizational framework of IEnvA, as well as an
accumulation of know-how in dealing with environmental issues.
POL 3.04 The Environmental Policy shall be documented and reviewed at least every two years.
Guidance
Step 1: Documenting the Policy
Operators are required to document their environmental policy and its revisions. This requirement is
easily addressed by making sure that the policy is properly maintained under document control, with
signature preferably of the CEO, dated and with a document reference and revision status in the footer.
Step 2: Implementing the Policy
The Operator should ensure the statements that are made within the policy can be substantiated. For
example, if the Operator has committed to reducing cabin waste generated can it demonstrate that it has
put together programs to achieve this reduction?
Step 3: Maintaining and reviewing the Policy
Any changes to the scope, operations or aspects should also be formally evaluated during the
management review and where appropriate included in a revision of the environmental policy.
Management should fully understand how changes to their activities may impact the environmental
performance of the Operator. Any resulting changes to the environmental policy reflect the awareness
and understanding that senior management have of environmental issues. It is important that this
process is carried out in a comprehensive manner.
POL 3.05 The Environmental Policy should be communicated to all persons working for the Operator.
Guidance
The environmental policy should be communicated internally by the Operator. Established
communication channels used for communicating any corporate information would be appropriate for
disseminating the environmental policy. The reason for communicating the environmental policy is to
5
impart awareness to all employees with regard to the overall direction and intent of the IEnvA
management system and also ensure they are aware of the importance and relevance of what that
means to them.
The best form of communication is through briefings or short training sessions, formalized by a sign-in
sheet which can also be used as a training record. Simply placing the environmental policy on a notice
board or a mass email campaign is unlikely to generate the necessary awareness and understanding
when compared to a short training and Q&A session. The relevance of the policy may be lost on some
employees who may see it as just another corporate initiative.
Employees of the Operator should be made aware of the policy and what it means to the Operator, and
can be extended to others who may be carrying out work on behalf of the Operator. Persons who work
on behalf of the Operator may include:
i) Subcontractors carrying out short work assignments,
ii) Long term contract staff, and,
iii) Self-employed persons.
iv) All other service providers to the Operator.
POL 3.06 The Environmental Policy shall be made available to the public, relevant stakeholders, and
other interested parties.
Guidance
To meet this standard, the environmental policy can be displayed in relevant areas where the public can
reasonably expect to visit which may include:
i) Operator’s website,
ii) annual report, and,
iii) at the Operator’s corporate offices
The Operator should also have an effective system for dealing with requests from the public for copies of
the environmental policy. This should include establishing to whom requests are directed and who has
responsibility for closing enquires related to environmental matters.
POL 3.07 The Environmental Policy shall be appropriate to the nature, scale and environmental
impacts within the chosen scope and boundaries of the Operator.
Guidance
The Operator should succinctly describe the main business operations and the scope and boundaries
the policy will cover. The policy is likely to be more widely displayed and publicized by the Operator, so
once the scope of the IEnvA has been agreed; this information should be summarized within the policy.
The reader of the policy should be able to quickly appreciate the scale and extent of the activities of the
Operator. There may exist differences in scale between a domestic/regional and international airlines
with many destinations worldwide. The types and diversity of key business activities should be concisely
stated within the environmental policy; and provide the reader with an understanding of the key
environmental issues it aims to tackle.
POL 3.08 The Environmental Policy shall include the provision for setting and reviewing environmental
objectives and targets.
Guidance
In addition to provisions to set and review environmental objectives and targets within the Environmental
Policy, the Operator should develop its own system or process for defining and delivering targets and
objectives. This requirement can be addressed by stating how the Operator defines and agrees to its
objectives (such as at a management review), and reviews progress towards achievement through the
use of various monitoring mechanisms available as part of the IEnvA Program. These include:
i) Inspection processes,
ii) Reporting and periodic analysis of performance,
6
POL
iii) Internal audit,

iv) Data verification and other similar methods, and,
v) Effective communication of relevant information
The challenge for the Operator is to set appropriate, realistic and meaningful objectives and then to
actually achieve them preferably within the agreed timescales. There needs to be a clear link between
the aspirations and values mentioned in the policy and those environmental objectives and targets set,
for example one aspiration in the policy may be to improve environmental awareness. It would then be
expected to see an objective and actions translating how this aspiration would be achieved.
The inclusion of any environmental aspirations within the policy document should be carefully thought
out and agreed by senior management as they are ultimately responsible for the successful
achievement (or otherwise) of these.
POL 3.09 The Environmental Policy shall be clear, concise, and available in the common language
used by the Operator and also in English.
Guidance
The Operator should create a policy that:
i) Uses clear and concise terminology which can be understood by interested parties from outside
the airline industry;
ii) Should not contain phrases or sections that may be viewed by interested parties as a self-
promotional document;
iii) Is available as a minimum in English and the main language of the Operator and;
iv) Should not contain more than one page of A4 text
7
Section 4 – Aspects & Impacts Register (REG)

The Aspects and Impacts Register (‘the A&I Register’) is the backbone of the IEnvA program, allowing the
Operator to document its activities, the environmental aspect of that activity and any associated
environmental impacts that are within the selected scope of the IEnvA program. The development of the
register allows the Operator to think critically about is activities and the associated impacts that result from
conducting that activity.
The Operator must consider its operations (within the chosen Scope and Boundaries) that have an
interaction with the natural environment and identify any existing environmental documentation, programs or
mitigation initiatives that the Operator may currently have. The Register also enables the Operator to identify
relevant permits or legal obligations, current monitoring and mitigation practices and, thus establish any
material gaps in current environmental management practices. The Register also allows the Operator to
establish a baseline or starting point of how environmental impacts and environmental performance are
currently managed and to demonstrate improvement during the IEnvA program.
The Operator is not expected to perform any extra activities (such as monitoring or reporting) in the initial
IEnvA process, or as a result of developing the Register. Actions resulting from the development of the
Register are first considered when determining the significance of the Aspects and Impacts (see section 8 -
AIS).

This requirement has been made part of the IEnvA Program as it is an essential basis of the standard(s)
(including but not necessarily limited to) EMAS, ISO 14001 and BS8555. It is requirement for program
membership at Stage 1 by IATA and is seen as best practice and an essential requirement for successful
implementation of the IEnvA Program.

REG 4.01 The Operator shall document and maintain a register of environmental aspects and
environmental impacts and their corresponding business activities within the scope of the IEnvA Program.
REG 4.02 The Operator shall have a documented procedure to keep the register up to date, identifying
new environmental aspects and environmental impacts and removing any redundant entries.
Guidance
The intent of the A&I Register is to show that the Operator’s activities have been considered and that the
operator understands all reasonable environmental impacts that result from conducting normal activities.
The development of the A&I Register may be conducted in conjunction with section 7 (LEG) to ensure
that all relevant legislative or other obligations are listed against each impact.
The Operator may also list any existing monitoring or control measures that are already in place.
8
Section 5 – Roles and Responsibilities (ROL)

Having clearly defined roles and responsibilities is a key component to ensuring that the IEnvA Program is
implemented and maintained. The appointment of a Senior Executive (or equivalent) as the IEnvA
Representative (or Sponsor), to support IEnvA and report the programs performance to the CEO (or
equivalent), thus providing an assurance that IEnvA will be an integral part of the Operators business. The
following section outlines other resources required to successfully implement the IEnvA Management
System.

This requirement has been made part of the IEnvA Management System as it is an essential part of the
standard(s) (including but not necessarily limited to) ISO 14001:2004, and EMAS (Regulation 1221/2009). It

ROL 5.01 The Operator shall appoint a senior executive as the IEnvA representative to report to
Senior Management on the performance of the Operator’s IEnvA Program.
Guidance
The representative is required to ensure that the IEnvA requirements are implemented, maintained and
continually improved; in addition to reporting the performance of the IEnvA program to senior
management.
While it is not necessary that the IEnvA representative have any environment expertise, it is desirable
that they understand key environmental concepts and have the ability to report on the performance of
the IEnvA Management System.
ROL 5.02 The Operator shall nominate a focal point for IEnvA Implementation and Management and
provide sufficient resources and authority to facilitate effective environmental management.
Guidance
The purpose of the IEnvA focal point is to facilitate IEnvA communication between IATA and the
Operator, and manage the IEnvA program. The focal point will also be the key liaison for external
environmental assessments undertaken by EAOs. The IEnvA focal point should be appropriately
qualified with relevant experience and knowledge.
Sufficient resources may include both human and financial resources; specifically demonstrated by
having documented IEnvA related tasks within job descriptions. Evidence of financial resources
allocated to IEnvA can be documented in budget descriptions with references to IEnvA management or
implementation.
These requirements need to be considered and regularly reviewed to ensure that any changes in the
scope of the Operator’s activities resulting in changes to environmental aspects have appropriate
resource allocations.
Staff performing day-to-day activities are expected to have a level of environmental competence that
may be achieved through training, education or by relevant on the job experience.
9
Section 6 – Documentation and Records (DOC)

The purpose and intent of this requirement is to ensure that essential components of the IEnvA Management
System are documented within the Operator’s IEnvA Manual; and that these documents (and other relevant
records) are controlled to ensure only current versions are used.
Documentation and control of records is an important component of the IEnvA program to ensure that,
amongst other things, environmental data and related documentation are controlled to ensure data integrity
allowing environmental performance to be measured and demonstrated in a consistent manner.
The procedure to control records and documents should be as simple as possible to avoid being overly
arduous whilst ensuring sufficient control..
By law, most Operators conducting flight operations (and MRO operations) should already have
comprehensive document control and publication procedures to ensure currency of publications and control
use; in most cases it is advised to utilize existing business policies and procedures if possible to do so.

standard(s) (including but not necessarily limited to) ISO 14001:2004. It is a requirement for program
membership by IATA and is seen as an essential requirement for successful implementation of the IEnvA
Program.

DOC 6.01 The Operator shall have an IEnvA Program Manual that includes (or references to
documents held within other manuals) an Environmental Policy that meets the IEnvA standards.
documents held within other manuals) the Scope and Boundaries of the IEnvA program that meets the
IEnvA standards.
documents held within other manuals) a legal and other obligations register that meets the IEnvA standards.
documents held within other manuals) other procedures that are required within the IEnvA standards.
Guidance
This can be achieved by having the above documentation and procedures within a controlled manual(s)
available to relevant staff.
DOC 6.05 The Operator shall have a documented process to control documents and records related to
the IEnvA Program that includes: document approval, review and re-approval.
the IEnvA Program that includes: revision status and identification of material changes.
the IEnvA Program that includes: appropriate version availability at point of use.
the IEnvA Program that includes: documentation legibility.
the IEnvA Program including all external documentation relevant to the IEnvA program
the IEnvA Program including the identification of superseded documents
10
DOC
the IEnvA Program that includes: storage, protection, retrieval, retention and disposal of documents
including records.
Guidance
The follow provides guidance regarding points DOC 6.05 – 6.11; and provides the Operator a choice
between using an electronic or paper-based document control process. Electronic document control is
preferred as it reduces the quantity of paper required and the number of steps in the document control
process. Despite this, electronic document control is not always practical and as such both methods are
provided.
i) Document approval, review and re-approval – (Electronic + Paper Method) This can be achieved
by establishing a review / approval procedure that all documentation that forms part of the IEnvA
program (policy, scope and boundaries and procedures etc.) must go through prior to being
published in the IEnvA Manual. The recommended solution to achieving this is by incorporating a
review/approval header/footer box in the documents to which the appropriate persons must initial
and date prior to a document being published. An example header is provided below:
Document Name Environmental Policy Date of 20-08-13

Issue
File Reference c:\corp_serv\env\policy.doc Page 1
Example Footer (On First page of relevant document only)
Document Environmental Policy FINAL

Name
Reviewer Name Title Date
Approved
Subject Matter S. Williams GM Safety Risk Env. 10-08-13
Expert
Compliance to J. Smith Environment Manager 15-08-13
IEnvA
THIS IS A CONTROLLED DOCUMENT - UNCONTROLLED IF PRINTED
ii) Revision status and identification of recent changes - (Electronic + Paper Method) The document
revision requirement can be complied with by stating the current status of the document.
Published documents for use will be marked as ‘FINAL’. This can be seen in the footer example
above.
iii) Appropriate version availability at point of use – (Electronic Method) Appropriate version at point of
use can be complied with by ensuring that only electronic versions (and hence the most up to
date) are made available at required locations. This can be performed by ensuring all staff have
access to a computer terminal or publishing the manuals using iPads or tablet computers. (Paper
Method) To comply with version control using a paper based document control system is more
involved than the electronic method and involves a number of additional steps. A register of
applicable documents will need to be kept within the Operator’s IEnvA Management System
Manual. The register will list each document and the revision status of each document. The
register will need to be updated to reflect any changes in revision status of any IEnvA documents.
In this way, if a documented paper procedure is to be used, the staff member should firstly check
the register of documents to see if the published procedure that they are using is the most up to
date appropriate version. If the version status of the procedure matches the version status of the
register the staff member will know that the most current procedure is being used. This paper
based version control system may also be bolstered by a document delivery, retrieval and tracking
system. This system can be achieved by developing a delivery list for the paper based documents
11
or entire manual and when a document is developed or revised and published, the document is
delivered with a delivery receipt and the superseded versions retrieved.
iv) Documentation legibility - (Electronic + Paper Method) Document legibility can be overcome by
producing any documents in a word processor or a computer bases word processing application. If
hand written documents need to be produced, they may be checked for legibility in the checking
process in point (i) above.
v) External documentation relevant to the IEnvA program has a controlled distribution – (Electronic
Method) External documentation relevant to the IEnvA Program can be controlled (in this case
controlled meaning appropriately distributed) by sending an attachment to an email with a read
receipt. (Paper Method) Paper based external documentation can be distributed by a paper based
read and sign receipt. The receipt should be retained as proof of distribution.
vi) Identification of superseded documents - (Electronic Method) Identification of superseded
documents is complied with by stating that ‘THIS IS A CONTROLLED DOCUMENT –
UNCONTROLLED IF PRINTED’. The will only work if the IEnvA Manual is published exclusively in
electronic format. Superseded electronic versions should be watermarked with ‘SUPERSEDED’.
(Paper Method) When new paper based documents are published, old versions should be marked
as ‘SUPERSEDED’. It is only necessary to keep one superseded paper based version for
historical purposes. Other copies can be destroyed.
vii) Storage, protection, retrieval, retention and disposal of documents including records - (Electronic
Method) Storage, protection, retrieval, retention and disposal of IEnvA documents should be in line
with any existing company procedures. Electronic versions can be retained indefinitely if need be.
(Paper Method) Storage, retention and disposal of paper documents would need to be not less
stringent than the most stringent legal requirement. In most cases this will be in line with retention
of taxation and financial records, usually 5 – 7 years
12
Section 7 – Legal and Other Obligations Register and
Compliance Review (LEG)

A commitment to comply with environmental legislation and other obligations to which the Operator
subscribes is a key principle of the IEnvA Program. The IEnvA Program requires that the Operator has a
documented process for identifying its legal requirements and other obligations and maintains an up-to-date
register of these requirements and obligations.


LEG 7.01 The Operator shall have a documented procedure to identify applicable legal requirements.
Guidance
While high-level, highly publicized direct environmental legislation (e.g. EU Emissions Trading Scheme)
may already be known, most direct legal requirements are generally associated to a specific
environmental impact. The Legal Requirements and Other Obligations identification procedure could
utilize the Aspects and Impacts Register.
In addition to this, it is advised that the Airline Operator checks with relevant government and regulating
bodies for applicable legislation. It is advantageous but not essential that this task be performed by staff
with technical or legal backgrounds or by external legal experts. The latter method also provides an
additional level of risk mitigation, ensuring expert legal opinion.
Examples of Environmental Legal Requirements:
Air Emissions
i) Use and disposal ozone depleting substances (ODS). Countries that are signatories to the
Montreal Protocol are likely to have regulations in place regarding the use and disposal of
ODS. Commercial buildings with refrigerated HVAC systems should check to ensure
appropriate gas are being used.
Noise
i) Noise from sources other than aircraft during LTO may have associated regulations such as
APU usage and run times.
ii) Noise emissions and restrictions from commercial buildings. Obligations may be written into
contracts or other agreements. Sources of noise are likely to be from HVAC, loading bays or
other plant and equipment.
Water Consumption
i) Potable water use or hose pipe bans for garden beds associated with corporate facilities
ii) Abstracted water requirements for limited capacity or reporting obligations
iii) Requirements to submit water efficiency management plans or similar
iv) Knowledge of operations in water scarce areas
v) Requirements to purchase any new fixtures or fittings with a minimum efficiency rating or
standard
13
Wastewater
i) Trade waste or effluent consent includes requirements for disposal of foul liquids going to sewer.
For corporate activities, this could be things such as cooling tower water discharge that contains
high concentrations of mineral salts and antibacterial / antifungal chemicals.
Waste
i) Disposal of quarantine waste from international flights
ii) Disposal of fluorescent light tubes or CFLs may be regulated due to the substances they contain
Biodiversity
i) Recording and reporting of bird strikes
LEG 7.02 The Operator shall have a documented procedure to identify other obligations to which it
subscribes.
Guidance
Depending on the type of other obligation, some will have already been identified during the review of
the Environmental Legal Requirements. It is recommended the identification of airport-specific “other
obligations” is performed in a 2 step approach:
Step 1: Other Obligations at home ports
At home or major ports, it is recommended that appropriate airline staff meet with airport environmental
staff so that airport* specific obligations can be discussed directly and regularly into the future. This may
also be performed by being an active member of an airport environmental committee that is run by the
airport or the airport regulator.
Step 2: Other Obligations at out-ports
For out-ports and other smaller bases, the Operator may choose to use a central obligations database
provided by IATA.
Other Obligations may also include:
i) Corporate Social Responsibility (CSR) Reporting (Global Reporting Initiative, Dow Jones
Sustainability Index, etc.);
ii) Carbon Reporting (Carbon Disclosure Project, annual reporting to the IATA World Airlines
Transport Statistics, etc.);
iii) Voluntary Principles or Codes of Practice;
iv) Agreements with Community Groups and Non-Governmental Organizations.
Specific parts of the obligation and the degree to which the obligations apply should also be considered
and documented if relevant.
LEG 7.03 A register of applicable legal requirements and other obligations shall be established and
kept up to date by the Operator.
Guidance
The Legal Requirements and Other Obligations Register provides documentary evidence that the
procedure(s) stated have been implemented by the Operator. The register would provide sufficient
information to the Operator to easily see all of their environmental legal requirements and other
environmental obligations in a comprehensive register. The register should also summarize the main
requirements or actions (if any) that the Operator must do to be compliant.
LEG 7.04 The Operator shall either demonstrate compliance with its legal requirements and other
obligations OR demonstrate that they have developed a procedure that ensures environmental compliance
to the requirement.
Guidance
14
LEG
In addition to and separate from identifying applicable obligations, is the requirement of the Operator to
assess compliance with the legal requirements and other obligations register. The internal evaluation of
compliance to the obligations register should be a matter of working through the Legal Requirements
and Obligations Register and viewing evidence of the compliance against each requirement.
Compliance checks should be performed on a regular basis and evidence of compliance should be
retained. The frequency of compliance checks depends upon the risk of those obligations and also
whether there have historically been any non-compliance.
Using Section 4 (Scope and Locations), identify locations where activities are conducted by an external
service provider. Activities conducted at outstations are more likely to be conducted by an external
service provider than at home ports and hubs where Operators will often conduct the activities
associated with the aspects and impacts themselves. However, this may not always be the case with
certain tasks such as catering waste disposal could exclusively be performed by an external catering
company at both out stations and even in the hub and home ports.
For activities that are conducted by external service providers ensure that there is a service level
agreement, contract or similar in place that includes a clause ensuring that the service provider complies
with all relevant (environmental) legislation. If no such agreements or contracts exist or if the
agreements do exist but do not include a legal compliance clause, then an agreement should be sought
to develop agreements or contracts and/or include legal compliance clause as soon as practicable or as
a minimum upon contract renewal. With contracts / service level agreements in place, the legal
compliance obligations can then be discharged to the service provider. The Operator should have a
process in place to check service providers are compliant with legal and other obligations as per contract
requirements (e.g. KLM service contract).
For the remaining activities where the Operator cannot discharge their legal requirements or other
obligations, the Operator needs to assess that the activities are conducted in compliance to all relevant
environmental legislation or other obligations that have been identified in the legal register. Compliance
evidence will depend on the activity being undertaken and the legal or other obligation in question. For
example: compliance checking of waste water disposal could involve shadowing your staff that performs
the waste water collection and disposal to ensure that it is compliant with any legal or airport obligations.
Compliance checking should be combined with internal assessments where possible but should not stop
the internal assessment of Operator activities that have significant environmental impacts but do not
have a legal or other obligation associated with them.
Where two conflicting pieces of legislation occur and compliance with one means non-compliance with
the other, the Operator is expected to comply (or show a commitment to comply) with the law that
promotes the greatest environmental performance or is in the best interest of the Operator.
15
Section 8 – Aspects and Impacts Significance (AIS)

In order to understand the environmental impacts of an Operator’s activities, the Operator should evaluate
the significance of the environmental impacts of its activities. This is important in order to prioritize
environmental risks and impacts, and is achieved by Operator’s determining significance via a specified
methodology.
By rating significance, the Operator will be able to understand which of its activities are likely to have the
greatest risk of impacting the natural environment. The Operator will then be able to allocate resources and
implement adequate management practices and controls to manage these environmental activities in a
planned and coordinated manner.


AIS 8.01 The Operator shall assess and rate the significance of its Environmental Aspects and
Impacts using a significance test that determines if there is an associated legal or other obligation.
Impacts though a significance test that determines any known, current or future financial costs.
Impacts though a significance test that determines if there is a possibility of reputational damage to the
Operator or the airline industry.
Impacts though a significance test that determines the severity or potential severity by calculating the
consequence and frequency of all environmental impacts if not already deemed significant.
Guidance
The Operator will have a documented register of environmental aspects and environmental impacts
upon completion of Stage 1 (see REG 4.01 – 4.02). The Aspects and Impacts Register will be used as
the basis for determining significance.
Step 1: Assessing the current situation
If the Operator has an existing and established quantitative method for rating risks this should be used in
order to promote the continuity of business processes.
However, if the Operator has not previously evaluated the impact of its activities on the environment, the
Operator may use the significance testing method provided by IATA to assess all of its Environmental
Impacts. The Operator may also choose to reclassify the definitions for the likelihood and consequence
ratings with reference to the political, financial and social environments to make more accurate
assessments of significance compared to the definitions provided in the example below.
Operators that already have conducted significance testing may also wish to compare their current
testing against the one recommended by IATA.
Step 2: Determining frequency of activities
In Stage 1 of the IEnvA Program, the Operator should have identified all of its environmental aspects
and impacts. Once this is achieved, the Operator should seek to determine the significance of its
activities in all normal, abnormal and emergency situations.
16
AIS
i) Normal activity - activities that occur frequently (e.g. daily or under standard operating
circumstances such as generation of waste),
ii) Abnormal activity - activities that rarely take place but are planned (e.g. controlled activities that
occur one a very infrequent basis such as the construction of a new building),
iii) Emergency situations - foreseeable activities that lead to environmental harm under emergency
situations such as spillages or jettisoning and hull losses.
Step 3: Using significance testing methods
Determination of significance can be identified both by quantitative and qualitative parameters; however,
it is recommended that a quantitative methodology is used to aid in consistency.
In situations where the Operator does not have a method for identifying significance, the following
significance testing methodology is recommended. However, it should be noted that this is not a
prescriptive methodology and Operators may determine significance according to other additional
parameters (e.g. safety implications, costs of change, alignment to environment policy).
It should be noted that when initially determining the significance of environmental aspects, the Operator
should evaluate significance as though there are no controls in place (raw risk), rather than against an
assessment for the Operator with control measures in place (residual risk). The control measures will be
considered to reduce likelihood or consequence later in the process.
The recommended methodology is briefly described below:
i) Determine whether there is an associated legal or other obligation associated with the
environmental aspect;
ii) Determine whether there is an associated financial implication associated with the environmental
aspect;
iii) Determine whether there is a stakeholder concern or reputational concern for the Operator
associated with the environmental aspect;
iv) Identify the likelihood of an environmental impacts occurs;
v) Evaluate the consequence of the environmental impact (or severity) and whether there is a
financial implication; and
vi) Continually review and update the Aspects and Impacts Register.
The following section details a possible methodology of determining the environmental significance of an
Operator’s activities. Operators can choose to develop their own measures of significance but must still
test for: legal requirements, financial implications, stakeholder concern, and impact severity.
Determine whether there is a legal or other obligation associated with each of the Environmental Aspect
and Impacts identified in section 4 (REG); the process is illustrated in the following flowchart:
Does the Environmental Aspect of an Operator’s activity have an

associated legal requirement or other obligation that the Operator must
comply with?
Yes No
This is not yet categorized as

This is significant
significant (see step 2).
If the aspect is not considered significant following a test of legal and other obligations, the Operator
should proceed to assess financial implications:
Determine whether there is an associated financial implication associated with the environmental aspect.
17
Financial risks include current and known future cost liabilities such cost of current resources costs or
future liabilities such as remediation of contaminated lands from fuel spillage. Other future liability costs
may include costs to meet emission reduction targets from operational changes or emission offsets.
The following table details one possible methodology for categorizing financial risks. Please note that
this methodology is not exhaustive and the Operator should assess the financial implications and select
a scoring methodology that best suits their business model.
Possible measures that could be broken into High, Medium and Low:
Category
% of turnover
actual cost
impact to business
i) Aspects with a high financial implication can be considered significant.

ii) Aspects with a medium to low financial implication can be considered significant.
iii) If the aspects are not considered significant, the Operator should continue to test the significance
as described below.
If known financial risks (current or future) have no accurate financial figures and cannot be accurately
assessed the environmental impact should be deemed as significant.
Determine whether there is an associated stakeholder concern or reputational concern for the Operator
related to the environmental aspect.
The following table provides guidance for determining the significance of stakeholder and reputational
concerns for the Operator. Please note that this methodology is guidance and Operators will need to
assess the stakeholder and reputational impacts and review the significance to their business. The
table below acts as a guide.
Stakeholder/ Category
Reputational
Concerns
Low No stakeholders have expressed concern/ interest about this issue and it is very
unlikely that stakeholders are concerned. No major reputational risks exist.
Medium A defined number of stakeholders have expressed concern/interest about the issue
and it is very unlikely that this is a major reputational issue.
High A number of stakeholders have expressed concern about this issue or there is a high
likelihood that if they were aware of the issue they would be concerned. Regular
requests for action or concerns raised by staff, communities, customers or external
groups. This would include an Enforcing Authority or something similar.
The issue to likely to have far reaching reputational impacts for the Operator, the
aviation industry or both.
Aspects with a high stakeholder / reputational concern will be considered significant.

Aspects with a medium to low stakeholder / reputational concern will not be considered significant.
If the aspect is not yet considered significant, the Operator should continue to test the significance as
described below.
Assess the Likelihood of an Environmental Impact occurring
The following table highlights the recommended criteria for assessing the likelihood of an environmental
impact occurring for an environmental aspect:
18
AIS
Likelihood Guidance Score

Certain Frequent activity, event occurs daily 5
Likely Activity or event which occurs regularly (at least once per month to once per 4
week)
Possible Activity or event which occurs more than once per year 3
Unlikely (rare) Annually occurs from between once every year and once every several (2 to 2
during 9) years.
Very rare Highly improbable event. Once in every 10 to 25 years 1

Evaluate the consequence of the Environmental Impact.
The following table highlights criteria for the assessment of Consequence (or the Severity of the
Environmental Impact).
Consequence Guidance Score

Major Very serious, long term (10 years plus) environmental damage to ecosystem 5
function.
Potential for damage to the environment, which is likely to be long lasting and
costly to remediate. This could include failure of a bulk tank or major spillage
from an aircraft with contents of diesel being released into the surrounding soil
and groundwater or a serious or toxic effect on beneficial or protected species.
Under Normal conditions this could be environmental impact(s) that occur(s)
on an international or global scale. Relevant to the following impacts:
- global warming
- depletion of the ozone layer
- Depletion of a non-renewable resource (that is extremely scarce or in danger
of being completely used up).
Moderate Serious medium-term environmental damage with noticeable effects to 4
ecosystem function. Potential for some damage to the environment, but
without lasting effects. This includes; noticeable nuisance off-site, e.g.
discernible odor, emissions migrated off-site.
This may be relevant to generation and disposal of wastes, depletion of non-
renewable resources (that are not yet scarce or in danger of being completely
used up), and overuse of renewable resources such as wooden products.
Minor Moderate short term (less than 6 months) effects to biological or physical 3
environment.
Insignificant Minor effects on biological or physical environment. There are no lasting 2

effects and is easily remedied at a minimal cost.
No impact/ Positive Relevant if the environmental aspects has no identified environmental impact 1
impact under normal conditions, or if the identified environmental impact(s) are
beneficial.
After identifying a score for both the likelihood and consequence criteria, the Operator should then
multiply these scores in order to identify risk of a serious environmental impact occurring for an
environmental aspect.
Significance rating = Likelihood X Consequence
For example if the environmental aspect has a score of 3 for likelihood and the consequence has a
score of 2, the total score will be 6.
Significance testing results summary
19
The following points and table summarize the criteria for assessing the impact of its activities for normal,
abnormal, and emergency situations:
Legal Requirement
Aspects with a legal or other requirement will be considered directly as significant
Aspects that do not have a legal or other requirement associated with it are not considered directly as
significant. However this may become significant during financial and stakeholder implication are evaluated or
once the likelihood and consequence criteria is calculated.
Financial implications
Aspects with a high financial cost of over X% of turnover will be considered significant
Aspects have a financial cost of less than X% of turnover associated with it are not considered directly as
significant. However this may become significant once the stakeholder implications and/ or likelihood and
consequence criteria is calculated.
Stakeholder Concern / Reputational Concern

Aspects with a high stakeholder concern or reputational concern will be considered significant
Aspects that have medium to low stakeholder concern or reputational impact associated with it are not
considered directly as significant. However this may become significant once the likelihood and consequence
criteria are calculated.
Scoring (likelihood of occurrence multiplied by the consequence of the impact) is illustrated in the
example diagram below:
Example Airline Scoring Methodology:

i) All scores for aspects which are 15 and above will be considered significant
ii) Scores below 15 will not be considered significance.
Likelihood
Consequence
0 1 2 3 4 5
1 1 2 3 4 5
2 2 4 6 8 10
3 3 6 9 12 15
4 4 8 12 16 20
5 5 10 15 20 25
Therefore, an aspect and its associated impact can be considered as significant either:
i) by directly having a legal obligation associated to it;
ii) by having a financial implication which has a turnover of greater than X%;
iii) by having stakeholder concerns or reputational concerns for the Operator;
iv) by having likelihood and consequence scoring of equal to or greater than 15.
AIS 8.05 The Operator shall review and update the significance ratings for its environmental impacts
on its impacts register on an annual basis as a minimum.
Guidance
It is important that the Operator continues to review and update the significance aspects and impacts
register as necessary. It is advised that the review of the register is undertaken at least on an annual
basis or following any major changes to facilities or operations.
The environmental aspects need to be reviewed as part of the Management Review process (refer to
section 17 Management Review). Where the Operator adds new activities to its operations (e.g. the
20
AIS
addition of a new type of fleet or a new route to the schedule), the Operator should also make sure these
are evaluated for significance and included within the aspects and impacts register.
Many aspects registers are cross-referenced to Environmental Legislation Registers. The purpose of this
is to ensure that the aspects to which environmental legislation applies and vice versa are clearly
understood and can be demonstrably controlled within a system. Regardless of the significance scoring
systems applied to determine the scoring of environmental risk, all environmental aspects which are
governed by environmental legislation shall be regarded as significant.
Once the Significance of each environmental aspect is identified the Airline Operator should establish
methods of controlling potential impacts. The control methods should utilize the typical hazard control
hierarchy of:
i) Elimination – Avoid tasks that are associated with environmental aspect;
ii) Substitution – Change products or services to remove environmental aspect;
iii) Engineering – Implement some type of engineering control or remove environmental aspect;
iv) Administration – Utilize procedures, training or work procedures to remove or reduce the
environmental aspect / hazard or risk.
Significant Environmental Aspects may be controlled through the development of a work instructions or
control procedures which may reflect environmental legal concerns or act to reduce or mitigate the
environmental risk. Additionally, the training of staff or contractors may also result in reduced risk.
Alternatively, Significant Environmental Aspects may be dealt with through the setting of Objectives and
Targets often relating to the procurement of resources, implementation of equipment, adaptation of
facilities, or development of monitoring programs.
21
Section 9 - Objectives, Targets and Impact Management (OBJ)
Introduction
The Operator needs to develop, implement and track environmental objectives and targets to meet the
commitments made in its Environmental Policy and assist the Operator to:
i) Improve their management of their environmental impacts
ii) Drive continuous improvement of the Operator’s environmental management
Objectives and targets should be based on the Operator’s Significant Aspects and Impacts and would then
go on to identify any areas for improvement within the IEnvA Program or specific impacts that are relevant to
the Operator.
Objectives and targets are required to have associated programs with measurable metrics (where possible)
to demonstrate how the objectives and targets will be achieved. The objectives and targets need to be
regularly reviewed to align with the Operator’s activities and to facilitate continual improvement.

The scope of this chapter relates to all Objectives and Targets developed and programs implemented to
manage environmental impacts that fall within the scope of the Airline Operator’s IEnvA Program. This
requirement has been made part of the IEnvA Program as it is an essential part of the standard(s) (including
but not necessarily limited to) ISO 14001:2004, BS8555:2003 and EMAS (Regulation 1221/2009). It is a
requirement for program membership by IATA and is seen as an essential requirement for successful

OBJ 9.01 The Operator shall have a documented procedure to develop, implement and review its
environmental objectives and targets for the impacts it deems significant.
OBJ 9.02 The Operator’s procedure shall include relevant objectives that drive improvements in
environmental management performance or environmental performance.
OBJ 9.03 The Operator’s procedure shall include detailed targets to deliver the Airline Operator’s
objectives.
OBJ 9.04 The Operator’s procedure shall include the provision for communicating and raising
awareness of the objectives, targets to relevant stakeholders.
OBJ 9.05 The Operator shall develop environmental (impact) management plans that provide a plan
to achieve each target and objective set.
OBJ 9.06 The Operator’s environmental management plans shall identify relevant stakeholders and
define the roles and responsibilities for managing, tracking and analyzing objectives, targets.
OBJ 9.07 The Operator’s environmental management plan shall include decisions about if and how
the environmental management plan should be communicated and define any relevant stakeholders.
Guidance
Step 1: Establishing a procedure
Establish a procedure for developing environmental objectives, targets and environmental impact
management programs
Where the Operator has a system in place for developing environmental objectives, targets and
environmental impact management program
The Operator may have an established system to set and monitor objectives, targets and environmental
impact management programs (for example through their Environmental department and/or
22
OBJ
Management teams). However, the Operator will need to check the following guidance to ensure that
any existing process is compatible with the IEnvA requirements.
Where the Operator does not have a system in place for developing environmental objectives, targets
and environmental impact management programs
For Operators that do not have an established system for setting and monitoring environmental
objectives, targets and environmental impact management programs, the following methodology should
be followed.
Step 2: Define responsibility for objectives and targets
The Operator should define roles from across the business who will have responsibility for setting
objectives and targets and have accountability for tracking and reviewing performance. This will include,
but not limited to:
i) the Environment department;
ii) other departments which play a key role in environmental performance including legal requirements
or operational control (e.g. Flight Crew, Engineering, Aircraft Ground Handlers);
iii) other departments which play a key role within the management system (e.g. HR who may have
accountability for training and awareness); and
iv) Senior Management.
For further details on Roles and Responsibilities refer to the IEnvA Program - Roles and Responsibilities
section 5. Parties involved in the setting of objectives and targets shall be competent and have an
understanding of the business operations, the significant aspects and impacts of the Operator and/or
environmental management systems.
Step 3: Scope of objectives
The Operator should identify a number of objectives in line with the Operator’s environmental policy and
goals, and should relate to the significant aspects and impacts and environmental management
improvement areas. These will be high level statements with specific details provided within targets and
programs. Objectives will provide more long-term measures and goals (e.g. a commitment to reduce
carbon emissions). Objectives may relate to improvements identified from inspections, internal audits,
stakeholders concerns, legal requirements and other requirements as well as the significant aspects and
impacts assessment. Overall, objectives will be classified as:
· Environmental Management Improvement Objectives
Examples may include:
o Improve awareness of the environmental policy, objectives and targets
o Improve the effectiveness of the internal auditing program
o Revise operational controls for noise continual descent levels
o More accurate data collection and analysis system
o Improve environmental emergency response training
· Environmental Performance Improvement Objectives
Examples may include specific improvements regarding the environmental impacts such as:
o Increase recycling ratios and waste generation from the aircraft
o Reduce energy consumption
o Reduce hazardous waste generation
o Reduce carbon emissions from an activity or reduce carbon footprint
Step 4: Establishing detailed targets

The Operator should set targets which will enable them to achieve the objectives. These will be more
detailed and may provide quantitative measures. The Operator should only implement targets which are
‘SMART’ - this requires targets to be:
· Specific – should specify what the Operator wants to achieve e.g. is there a description of a
precise or specific behavior / outcome which is linked to a rate, number, percentage or
frequency?
23
· Measurable – should be an area/issue the Operator can measure whether they are achieving
the target or not.
· Achievable – should be attainable.
· Realistic – should be achievable given the costs/budgets/timeframes/resources available to
Airline Operator.
· Time bound – should have a timeframe over which the target will be achieved (e.g. a year or
specific date).
Targets will need to relate to both environmental impacts and management performance objectives, and
in order for targets to be measurable, performance indicators or metrics will need to be defined.
Performance indicators or metrics, sometimes known as Key Performance Indicators (KPIs), will need to
be established within the target to enable the Operator to measure progress towards an objective. These
may include examples such as:
· quantity of raw material (e.g. aircraft fuel);
· quantity of energy used (e.g. electricity for buildings, Auxiliary Power Units (APUs));
· quantity of emissions (e.g. CO2 from operations, from flights);
· quantities of specific pollutants emitted (e.g. for air quality NOx)
· tonnage of waste produced (e.g. from aircrafts, ground operations, offices);
· efficiency of material and energy used;
· percentage waste recycled;
· land area set aside for wildlife habitat.
In addition, there may also include management metrics such as:
· investment in environmental protection;
· number of environmental accidents (e.g. unplanned releases);
· number of prosecutions or breaches of legal or other requirements.
Baseline (Usage) data
The Operator may need to identify baseline data in order to establish a benchmark for
improvement and to allow the Operator to show continual improvement – e.g. achievements
made in comparison to previous years or year on year performance. Therefore, an initial target
might be made around collecting one year’s data before a further target can be established to
make improvements.
Normalized data
The Operator may need to establish whether the metrics will be actual reductions or relative
targets where data is normalized i.e. analyzed over a common factor (e.g. compared per
employee/FTE, per passenger/PAX, per number of flights, per floor space or per turnover).
Normalized metrics assist the Operator to achieve relative reductions and understand whether
practices are improving and becoming more efficient. For instance, the Operator may be
growing i.e. increasing its operations; however, the environmental impacts per flight or per
passenger are becoming more efficient i.e. the amount of waste per passenger is decreasing
despite the total quantity of waste increasing.
Environmental Management Performance – Examples
· Objective: Improve awareness of the environmental policy, objectives and targets
o Target: Develop and deliver online environmental awareness training to 80% staff and
contractors by end of 2013.
· Objective: Improve the effectiveness of the internal auditing program
24
OBJ
o Target: 100% of Internal Auditors to receive external training on auditing techniques and
requirements by June 2013
Environmental Impact Management – Examples
· Objective: Increase recycling and waste reduction from the aircraft
Targets:
o Monitor all waste quantities from aircrafts and tonnages – obtain baseline data for 2012
by end of year
o Implement waste strategy for aircraft waste for 2013 and set specific targets levels for
recycling
· Objective: Reduce carbon emissions

Targets:
o Reduce related carbon emissions by 20% from Auxiliary Power Units (APUs) by end
2015 in comparison to 2005 levels with new monitoring equipment installed by 2012
o 50% aircraft to improve fuel efficiency by 30% by end of 2013 with fleet investment and
operational efficiency
o Replace lighting in 100% owned (and where possible leased) buildings with LED
lighting/efficient lighting by end 2013
o Achieve 25% reduction in grams of CO2 per passenger kilometer (gCO2/paxkm) by
2020
· Objective: Improve aircraft noise management

Targets:
o Implement and document noise mitigation action plan for all aircraft by Q1 2013
o Provide refresher training for aircrew on requirements of action plan by Q2 2013
o Reduce average noise per flight by 15% by 2015 in comparison to 2005
Step 5: Implementing tailored environmental impact management programs for achieving objectives and
targets
The Operator will need to develop programs for achieving the environmental objectives and targets that
they have now developed. The programs should address roles, responsibilities, processes, resources,
timeframes, priorities and the actions necessary to achieve the environmental objectives and targets.
Programs may relate to specific environmental impacts or to business activities that have multiple
environmental impacts. Each program should have specific performance metrics, indicators and actions
identified to implement each program. These actions may deal with specific projects, services, sites or
facilities.
Step 6: Monitoring, tracking and analyzing objectives, targets and programs
Objectives, targets, programs and metrics will need to be monitored and tracked on a regular basis to
assess performance and impacts. The frequency of when the objectives and targets are set is flexible,
however, this will need to be reviewed as a minimum on an annual basis as part of the Management
Review.
The Operator will need to analyze their progress towards objectives and targets and set new goals in
order to demonstrate continual improvement (regarding environmental performance and impacts) and to
align them with any changes within the business. This will need to be reviewed within the Management
Review meeting.
When changes in processes, activities, services and products within the scope of the environmental
management system occur, the objectives and targets and associated programs should be revised as
necessary. Performance indicators and actions may then need to be redefined in light of these changes.
This process may be required, for example if the policy is changed or after a Management Review.
25
The Operator will need to decide on the type of data and how this collected and monitored - further
details are provided in the IEnvA Program - Monitoring and Measurement Section 10.
Step 7: Communicating and raising awareness of objectives, targets and programs
The Operator should communicate their objectives, targets and programs. The Operator should decide
on the audience and level of detail communicated, however, it is recommended that all staff and
contractors are provided high level information to increase awareness and improve engagement.
Objective and targets may be disclosed publicly through the Operator’s sustainability reporting. Further
details on communication channels and methods are provided in Section 11 (COM).
OBJ 9.08 The Operator shall review the objectives, targets, and environmental impact management
plans as a minimum on an annual basis.
26
Section 10 - Monitoring and Measurement (MON)
Introduction
The Operator will need to check and evaluate their performance against their environmental impacts.
Monitoring and measurements need to relate to the Operator’s significant aspects and impacts, objectives
and targets, operational controls, and any specific metrics required by the Operator.

standard(s) (including but not necessarily limited to) ISO 14001:2004, BS8555:2003 and EMAS (Regulation
1221/2009). It is a requirement for program membership by IATA and is seen as an essential requirement for
successful implementation of the IEnvA Program.

MON 10.01 The Operator shall document and implement a procedure to monitor and measure the
environmental performance for all of its significant impacts.
Guidance
Step 1: Establishing a procedure for monitoring environmental performance
Where the Operator has a system in place for monitoring and measuring its environmental performance:
· Many Operators may have an established system to monitor its environmental impacts (or
environmental performance for example through their Environmental department or other
departments /management teams). However, Airline Operators will need to check the following
guidance to ensure that any existing monitoring process is compatible with the IEnvA
requirements.
Where the Operator does not have a system in place for monitoring and measuring its environmental
performance:
· Operators that do not have an established system for monitoring and measuring environmental
performance can follow the methodology provided.
Step 2: Identifying areas which require monitoring
When establishing monitoring and measuring processes, the Operator can consider what Aspects are
associated with their significant impacts. The Operator can identify the key characteristics of the
processes and activities related to these Aspects that can be measured and that provide the most useful
information relating to the impact.
The monitoring data obtained may be required for assessing performance against policy commitments,
objectives & targets, demonstrating legal compliance, or demonstrating continual improvement.
Monitoring and measuring objectives and targets by:
· The Operator should monitor the progress of its policy commitments and related objectives and
targets - refer to IEnvA Program - Objectives, Targets and Impact Management.
· The Operator needs to implement processes to adequately monitor its objectives and targets to
obtain accurate and reliable data for metrics or performance indicators related to these in order
to demonstrate continual improvement.
· Some Operators may track the progress of objectives and targets through an objective and
targets tracker sheet or Key Performance Indicator (KPI) sheet, (e.g. Microsoft Excel spread
sheet) or through a more sophisticated digital tracker system. It is important that the progress of
objectives and targets is monitoring on an on-going basis as described in Monitoring and
Measurement.
27
· It should be the responsibility of the Environmental Representative or Environmental Team to

track the progress of objectives and targets. Refer to IEnvA Program – Objectives, Targets and
Impact Management.
· Airline Specific Metrics
· The Operator should establish and evaluate other and existing airline specific performance
metrics. The IEnvA technical reference documents provide an overview of Airline Operators’ key
requirements and refer to best practice standards and guidance for monitoring and
measurement.
MON 10.02 For all of its monitoring procedures, the Operator shall include and define the type and
quality of information or data that is required to be collected.
Guidance
All monitoring and measuring procedures and data collected should be regularly reviewed and verified.
This should be undertaken periodically and scheduled using the Operator’s internal inspections or
internal assessments.
MON 10.03 For all of its monitoring procedures, the Operator shall include and define who is responsible
and how the monitoring and measuring of data is performed.
Guidance
It should be the responsibility of the Environmental Representative or Environmental Team to track the
progress of all monitoring and measurement data.
MON 10.04 For all of its monitoring procedures, the Operator shall include and define data verification
processes that are in place.
Guidance
The Operator must define if the monitoring data is being verified, for what purpose and by whom (N.B.
Assessors should avoid the deep vertical auditing of pre verified data).
MON 10.05 For all of its monitoring procedures, the Operator shall include and define any legal
requirements or limits that relate to the environmental performance monitoring.
Guidance
The Operator must define if the monitoring data is required under any legal or other requirement other
than the requirements of IEnvA.
MON 10.06 For all of its monitoring procedures, the Operator shall include and define if and how the
information is communicated and reported.
Guidance
The information must be reported to Operator staff including senior management and external
stakeholders. Reporting to staff can be done through the Operator’s intranet, poster campaigns,
newsletters, or staff briefings. Examples of reporting to external stakeholders include communication on
the Operator’s website, email campaigns, and/or sustainability reports.
MON 10.07 The Operator shall store information that results from its monitoring procedures as per DOC
6.11.
Guidance
The Operator must keep records of its progress against its legal compliance, operational controls,
objectives and targets alongside specific metrics.
The duration for retaining records will need to be specified by the Operator. This will need to consider
legal requirements for retaining records, internal procedures and ability to review previous performance.
MON 10.08 The Operator shall maintain records of any monitoring and measurement data including
calibration records.
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MON
Guidance
Record and data retention
It is recommended that the Operator retain the monitoring records for at least a 3 year period. The
retention of monitoring records will be necessary when performing temporal analysis.
Calibration of operational control equipment
Another element of evaluating whether controls are effective is ensuring the Operator calibrates its
equipment adequately. The Operator must have procedures for implementing and conducting monitoring
and measurements. This is required to provide consistency of measurements and enhance the
reliability of data provided.
Measurements should be conducted under controlled conditions with appropriate processes for assuring
the validity of results, such as adequate calibration or verification of monitoring and measurement
equipment, use of qualified personnel, and use of suitable quality control methods.
When necessary to ensure valid results, measuring equipment should be calibrated or verified at
specified intervals, or prior to use, against measurement standards traceable to international or national
measurement standards. If no such standards exist, the basis used for calibration should be recorded.
Examples include equipment used for monitoring air quality, noise quality, metering for electricity use.
MON 10.09 Results of monitoring and measurement data shall be formally reviewed by the Operator
and key findings shall be presented at Management Review meetings, held as a minimum on annual basis
(refer to IEnvA Program - Management Review).
Guidance
Trending Monitoring and Measurement Data
The results of measurement and monitoring should be analyzed and used to identify both successes
and areas requiring correction or improvement e.g. regarding operational controls, measurement
improvement or corrective actions. This may need to be integrated within the Objectives, Targets and
Programs to improve performance (refer to IEnvA Program - Objectives, Targets and Impacts
Management).
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Section 11 – Communication (COM)
Introduction
The Operator will need to have effective communications procedures in place to make sure that
communications regarding environmental issues associated with the Operator’s IEnvA Program are
consistent and appropriately managed.


COM 11.01 The Operator shall establish and implement an internal communication procedure that
identifies the IEnvA or other environmental information that shall be communicated to internal stakeholders.
defines who the internal stakeholders are.
includes tracking and responding to enquiries and questions and tracking from internal stakeholders.
defines the roles and responsibilities for undertaking internal communications.
Guidance
Internal Communication
Where the Operator has a system in place for managing internal communications
Many Operators may have an established system for managing internal communications (for example
through Safety Management System requirements or their Communications department). However,
Operators should check the following guidance to ensure that any existing communication process is
compatible with the IEnvA requirements.
Where the Operator does not have a system in place for managing internal communications
For Operators that do not have an established system for dealing with internal communications a
methodology is presented in the following section:
The Operator may develop a process for communicating internally on environmental issues to
employees and those who work on behalf of the Operator (e.g. handling agents, agency staff, and
contractors). These can be developed by the environmental representative working with corporate
communications teams and would need to be integrated into existing communications program if these
already exist. This procedure would also need to be agreed with the communication department.
· The procedure would need to include;
· Who is responsible for internal communication programs;
· The format of internal communication programs (e.g. via company intranet, posters, magazines
etc);
· Where internal information requests, suggestions or complaints will be recorded;
· How the environmental policy will be communicated internally;
· Controls on issuance/approvals.
30
COM
Step 2: Establishing internal communication channels

Internal Communications can be circulated through a number of different channels including (but not
limited to):
· Internal networks,
· Intranet portal,
· Toolbox talks,
· Normal management channels i.e. meetings where information flows from one management
level to the next,
· Senior Management presentations,
· Electronic message and e-mail,
· Memos, posters and circulars on notice boards,
· Internal newsletter,
· Training programs,
· Briefing sessions,
· Employee surveys to gauge responses on environmental issues,
· Management review meetings,
· Contributory information to the annual report/ sustainability report.
Step 3: Types of internal communication channels
The types of messages communicated will depend upon the respective locations, however as a
minimum the Operator should communicate on:
· Their Environmental Policy (in line with section 3)
· An overview of the IEnvA Program and its objectives and targets;
· Any environmental aspects that have significant environmental impacts (in line with sections 4
and 8);
· Relevant legal obligations e.g. EU ETS, carbon reporting and noise from aircraft during
emergency landing under no flight policy at an airport (as identified in line with section 7);
· Relevant operational control, mitigation and emergency response procedures;
· Their roles and responsibilities (as outlined in section 5).
The Operator should consider the most appropriate methods (e.g. electronic media) for communicating
with employees who travel or who are based in several locations. Employees may also need to be
aware of different environmental legislative or other requirements in different countries or locations.
Any employee with an environmental issue or concern can raise this with the team managing
environmental issues. This should be recorded and action taken in the same way as an external
communication.
COM 11.05 The Operator shall establish and implement an external communication procedure that
identifies the IEnvA or other environmental information that shall be communicated to external stakeholders.
defines who the external stakeholders are.
includes tracking and responding to enquiries and questions from external stakeholders.
defines the roles and responsibilities for undertaking external communications.
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Guidance
External communication
Where the Operator has a system in place for managing external communications:
Many Operators are likely to have an established system for managing external communications (for
example through Safety Management System Requirements or their Corporate Communications
department). However, Operators should check the following guidance to ensure that any existing
communication process is compatible with the IEnvA requirements.
Where the Operator does not have a system in place for managing external communications:
For Operators that do not have an established system for dealing with external communications the
following methodology in this chapter may be followed.
The Operator should develop a process for communicating externally on environmental issues. These
can be developed by the environmental representative working with communications teams and should
be integrated into existing communications programs if these already exist. This procedure should also
need to be agreed with the Corporate Communications department.
The procedure would need to include:
· Who is responsible for external communication programs;
· How this procedure is communicated to staff and those work on behalf of the Operator;
· The format of external communication programs e.g. via company intranet, posters, magazines
etc;
· Whether the Operator should communicate externally about its significant environmental
aspects - this must be documented;
· If the Operator choses to communicate its significant environmental aspects externally, the
Operator must establish methods for this communication (e.g. whether they should report this on
request or proactively in its sustainability/ annual reports).
· Where internal information requests, suggestions or complaints will be recorded;
· How the environmental policy will be communicated internally.
Step 2: Identifying the likely external parties / stakeholders who will be communicated with and the channels
to be used
Interested parties:
The Operator should communicate with interested parties through the provision of selected
environmental information. Interested parties include investors, aviation associations, governmental
bodies and local communities.
Types of external communications (outward, i.e. from the Operator to an external third party) include:
· Presentations at seminars and conferences;
· Operator Sustainability Reporting (including annual sustainability/ environmental reports);
· Reporting of environmental data (e.g. under EU ETS and reporting of data to IATA);
· Environmental policy and press releases;
· Web pages and company blogs;
· Interviews with media (e.g. press, radio, TV);
· Communication of benchmarking information to IATA;
· Participation in business organizations (e.g. Chambers of Commerce), participation in
community schemes;
32
COM
· Customer surveys.
Types of external communications (inward, i.e. from external parties to the Operator) may include:
· Complaints - can be received from external parties including communities around airports into
which Operators flies.
· Specific questions - can be received from any external party including academics, students and
the general public.
· Media enquiries - the media may inquire about a variety of topics including complaints or
pollution incidents.
· Legal enquiries or those which might result in legal advice being required- enquires from lawyers
· Requests for general information from the general public including students and academics
· Specific communication from interested parties
· Regulators – any monitoring information required by the regulator including noise complaints,
carbon emissions
· IATA, airline partners or stakeholders- monitoring information including regulatory compliance,
noise statistics and carbon emissions
Media Relations:
The environmental representative should be aware of any sensitivities associated with external
communications to ensure that the appropriate departments are consulted before any response is given
(this will usually be the Corporate Communications department). For example, it is generally advised
that media or legal enquiries be fielded to the appropriate communications or legal teams within the
Operator organization rather than responded to directly. \The external communications procedure should
reflect any rules already in place with regard to media communications. Awareness of internal
procedures may become particularly important in times of abnormal or emergency situations as
described in sections on Operational and Emergency Response. The Operator also needs to consider
any Codes of Practice or Guidelines for responding to external queries (e.g. internal guidelines
established by communications teams or those determined by best practice).
The Operator should deal with each external communication on an individual basis, but should appoint a
single point for communication to ensure responses are consistent and aligned to the Operator’s
Environmental Policy and any other relevant documents. Continuity also allows any trends to be
identified and to ascertain whether a different or more formal response may be required.
The Operator should make copies of the Environmental Policy available upon request, although this may
be through directing the interested party to the Airline Operator’s website.
The Operator should decide whether to make information relating to the Significant Environmental
Aspects available to interested parties. Where the Operator has decided to communicate information
with regards to their environmental aspects and impacts the Operator should establish a proactive
communication strategy. However, it is not a requirement of the IEnvA program to communicate this
information.
Complaint or incidents:
Any complaints or incidents can be logged and managed. These may be related to individual flights or
aircraft operations, particularly in the case of noise and the Operator should have a mechanism for
redirecting the complaint or incident where appropriate (e.g., redirecting noise complaints to the airport
operator where appropriate). The Operator should identify if there is a specific timeframe for responding
to complaints and how there are followed up. If the Operator has an existing system for handling
complaints then this can be used for environmental complaints. The Operator also needs to ensure that
complaints are followed up and tracked.
Suppliers and contractors:
The Operator should also communicate the Environmental Policy proactively to all suppliers and
contractors. These parties can be identified within the external communications policy. Contractors
should also be made aware of the need to conform to the Policy whilst undertaking work on behalf of the
33
Operator; which can be achieved through building compliance with the Environmental Policy into new
contract arrangements or providing existing contractors with a copy and requiring them to communicate
this to their teams working on behalf of the Operator if appropriate influence and control of the supplier
exists.
Government relations:
The environmental representative should identify any procedures in place for responding to government
enquiries and or regulatory obligations (e.g. EU ETS). For government owned airlines there may be
additional communication and reporting requirements. The approach for dealing with government
enquiries should be outlined in the external communications procedure. If there are no existing
procedures in place, the environmental representative should identify who is the most appropriate
person in the Operator to respond to government inquiries. This may be particularly important during
abnormal or emergency operations and the environmental representative should seek to identify any
specific information that might be needed by Governments or Government representatives at this time.
The environmental representative may need to consider:
· For government owned airlines, is there a delegation of authority? Is there a lag time for
responding to government inquires? etc.
· In the case of catastrophes is there any specific information required by governments?
· Freedom of Environmental Information - the Operator may be required to respond to this and
should include this in any procedures.
Sustainability Report:
Sustainability reporting (either standalone reporting or sustainability information included on web sites or
as part of Operator annual reports) is a useful tool for communicating progress to external audiences.
The Operator needs to ensure that progress on environmental performance is included in this reporting.
Ideally, quantified performance indicators measuring progress toward objectives and targets are
included where possible.
Step 3: Reviewing the effectiveness of communication:
The effectiveness of internal and external communication channels should be reviewed on an on-going
basis. The environmental representative must review communication in order to identify trends. In
addition, the effectiveness of the internal and external communication should be reviewed as a part of
the Management Review meeting (Management review – Section 17). For this, the environmental
representative should prepare a briefing document that can be used in the management review process.
This briefing document should include the following:
· Number and nature of internal communications and the documented response;
· Number and nature of external communications and the documented response;
· Any trends in communications (internal or external);
· Any subsequent changes to practices or procedures;
· Any relevant findings from internal assessment that relate to communications.
The Operator also needs to include communication information in any external sustainability reporting.
This needs to include as a minimum:
· Number and nature of any external complaints on significant aspects and the operator’s
response;
· Third parties engaged with in working towards improved environmental performance;
· Stakeholder engagement with CSR Reporting.
Recording internal and external communication
The Operator should have a process for recording all external communications.
34
COM
COM 11.09 Records of internal and external communication shall be kept by the Environmental
Representative or, if records are kept elsewhere, the Environmental Representative should keep a list of all
communications records and where they are held.
35
Section 12 – Training (TRA)
Introduction
The Operator needs to have effective training programs in place to make sure that all staff are aware of their
roles and responsibilities, have appropriate knowledge of environmental issues, and are competent to
undertake tasks that may or have significant environmental impacts. By developing training processes the
Operator will be able to demonstrate that it recognizes the need to ensure that all personnel and contractors
performing tasks which have the potential to cause significant impacts on the environment receive
appropriate training and are competent.


TRA 12.01 The Operator shall develop a training program that includes environmental related training.
TRA 12.02 The training program shall be developed from the tasks associated with the Aspects and
Impacts Register and the Significant Impacts.
TRA 12.03 All training needs identified shall be documented.
TRA 12.04 The training shall be planned and delivery commenced.
Guidance
Step 1: Identifying Training Needs
If the Operator has an existing procedure used to identify training needs and an established training or
capacity-development structure the framework should be used for environment-related training in order
to promote continuity.
There are two main training categories:
1. Training of staff conducting tasks that have (or have a potential to have) a significant
environmental impact; and
2. Training of staff in the IEnvA Program (including assessment if needed) and its importance to
the organization. The following guidance outlines the requirements of developing an effective
training program.
In the first instance, the Operator should use the Aspects and Impacts register to identify specific work
tasks associated with impacts determined to be significant..
The Environmental Representative, in cooperation with the human resources department, should then
identify employees that conduct these specific works tasks associated with the significance
environmental aspects and their impacts.
Staff conducting activities that have the potential for significant environmental impacts should be
deemed competent prior to conducting these tasks. The competence testing should use standardized or
accepted testing methods if available. Where standardized or accepted testing methods do not exist, the
Operator should use experts, industry bodies or persons with vast experience to develop their own
testing methods.
If existing training and competence programs are already in place, compare current performance to the
job expectations and identify the areas in which there are discrepancies (e.g., are cabin crew collecting
and disposing of waste as agreed / in accordance with legal requirements or are engineering staff at
corporate headquarters adhering to chemical storage requirements). Identify whether any discrepancies
36
TRA
are due to work process issues, such as not knowing how to complete a specific task, or personnel
issues, such as not wanting to complete a specific task. Work process issues can be addressed with
employee training, while personnel issues are better addressed by an employee review process.
Prioritize training needs, taking into account those that have an immediate effect on environmental
performance (for example, staff who may deal with tasks that have a significant environmental impact,
emergency situations or staff handling waste management). These employees/contractors are the most
important, particularly those linked to legal and other obligations. Discussing your environmental goals
with your employees can also be helpful in this process. Knowing the desired outcome can assist
employees in telling you what they need to know in order to help the company achieve its goals.
Training needs should be identified by the Environmental Representative or other persons competent to
undertake the task (i.e. they have an understanding of the training requirements and competencies
required). Typical training needs associated with significant aspects and operational controls are likely to
include:
· Waste Management and segregation and waste minimization needed by groups of staff who
handle waste.
· Climate change and carbon management required in departments that make purchasing
decisions, develop flight procedures and report on fuel performance.
· Carbon reporting needed by environmental representatives and communications staff.
· Spillage response training needed by those groups of staff handling chemicals such as
engineering staff.
· Sustainable / environmental procurement needed by those who make procurement decisions
and finance teams.
· Hazardous substances storage and chemical handling needed by engineering and maintenance
staff.
· Introduction to Environmental Management Systems needed by all staff
The level of awareness and training depends upon the tasks which are being carried out and the
associated environmental aspects and impacts, as well as the individuals’ roles and responsibilities
within the IEnvA Program.
Staff working for or on behalf of the Operator will receive training as a minimum:
· Operator’s Environmental policy,
· requirements of the IEnvA Program and significant aspects,
· individual roles and responsibilities within the IEnvA Program and the potential consequences of
departure from specified operating procedures.
This may be delivered through a variety of training methods, for example staff requiring training may be
provided a specific work instruction or procedure which they are required to review and sign to state they
have understood the requirements.
If undertaking work which could result in a significant impact upon the environment, the Operator shall
ensure that contractors and suppliers will be trained or made aware of the IEnvA Program and the
environmental policy.
In addition, the following training types will be needed:
· Environmental assessment needed by staff conducting internal assessments. Typically this
would cover auditing and assessment skills such as how to plan an assessment, who to speak
with, what to inspect, significant aspects, legal and other requirements specific to the Operator,
how to present non-conformances, and writing an assessment report. Those organizations using
assessors who already have assessment skills in other fields (for example, quality or health and
safety assessors) will only need to provide training that covers specific environmental
assessment requirements.
37
· Environmental representatives training needed by those who are going to be leading the IEnvA
program within the organization. Depending on existing skills this training will need to cover
knowledge about the IEnvA program as well as legal and technical environmental knowledge.
· Induction training required by all new starters. The induction training will follow the program set
out for all staff and will need to cover the environmental policy, significant aspects and the
consequences of departing from specific procedures.
Step 2 - Compile a Training Matrix
The Operator should have identified all of its environmental training needs upon completion of Step 1.
Once this is achieved, the Operator should develop a training needs matrix identifying the training
requirements for each group of employees or contractors and the type of training required. This will need
to be reviewed on an annual basis to reflect any changes in roles or business activities as part of the
management review.
Step 3 - Developing a Training Plan
Once the current status of training has been assessed and needs identified, an overall program of
environmental training is developed which meets the requirements of the organization and the needs of
the employees. For Operators, this will need to be flexible using a number of training tools that are
equally effective with staff who travel or who are based in multiple locations.
Many Operators will already have training departments and facilities for training staff. Where these exist,
training for the IEnvA program should be structured within these training departments and additional
courses or modules of courses provided to cover environmental requirements. The use of internal and
external training should be considered to ensure that the correct balance of expertise and cost
effectiveness is achieved. For example, some Operators may have extensive training programs, but
nothing that covers environmental issues. Others may be establishing training and this represents an
opportunity to streamline environmental training with other training requirements.
Training can be classroom training, on the job training or internet-based. The advantage of classroom
training is that it allows for any issues or questions to be dealt with immediately; however it can be
expensive and time consuming, taking employees away from their main task. On the job training gives
the trainee immediate practical experience of what is required, but is generally one-to-one or small
groups and is not appropriate where large numbers of staff need to understand the same key issue.
Web based or internet training can reach a large number of people quickly, but it is difficult to measure
effectiveness and obviously not appropriate for staff that have restricted access to computers. Training
plans and training needs assessments may be integrated with performance appraisal processes to help
document and formalize the training needs identification process.
Step 4: Competency of trainers
The person who delivers the training should be capable to deliver the specific training identified and
compliant with any legal or other requirements associated with the training requirements. Trainers may
be internally or externally sourced and materials for courses may be developed by either external or
internal parties. Training providers should be allocated or resourced depending on the type of course,
ensuring they have adequate knowledge of the competencies required by delegates on the training.
Examples of training credentials the trainer may require include:
· Environmental legal requirements training through approved national recognized training or
internal training programs or on-the-job training;
· Approved national / recognized environmental management implementation or auditor training;
· Internal environmental management implementation and maintenance programs; and
· Internal environmental risk and operational control training programs.
TRA 12.05 The Operator shall review the training program on an annual basis (as a minimum) to
identify any new or missing training requirements.
TRA 12.06 The Operator shall identify which tasks or actions require recurrent training and document
the frequency of the recurrent training.
38
TRA
TRA 12.07 The Operator shall demonstrate the ability to fulfil all of the training requirements within its
training program.
TRA 12.08 Training records shall be held and managed in line with the documentation and records
section of the IEnvA Program.
39
Section 13 – Non Conformity, Corrective Action and Preventive
Action (NCC)

The need for an approach to remediating actions when things “do not go as planned” is well known and
understood by most Operators. The Operator shall establish a consistent approach for systematically
identifying, managing and correcting non-conformities. Non-conformities can be raised as a result of an
assessment finding, when actions have deviated from documented systems, policies, procedures or
processes. Therefore when corrected, non-conformities can demonstrate an improvement in environmental
managementand / or performance..

successful implementation of the IEnvA Management System.

NCC 13.01 The Operator shall have a documented procedure or process for dealing with non-
conformities (whether actual or potential), this shall include the process for managing corrective and
preventive actions.
Guidance
A non-conformity procedure needs to be documented. This can be included in existing documented
procedures or processes, such as Safety or Quality non-conformity procedures or be a stand-alone
document; however it is likely that the Operator will already have some processes for rectifying issues.
Where the Operator has a system in place for dealing with non-conformities:
· Many Operators may have an established system for dealing with non-conformities (for example
Safety Management System Requirements). If systems are already in place, Operators will need
to check the following guidance to ensure that any existing non-conformity process is compatible
with the IEnvA Program requirements.
Where the Operator does not have a system in place for dealing with non-conformities:
· For Operators that do not have an established system for dealing with non-conformities, the
following methodology in this chapter should be followed.
In establishing documented procedures, the Operator should consider the following steps:
· When a non-conformity would be identified.
· How a non-conformity would be investigated.
· How a non-conformity would be actioned to rectify the non-conformity,
· How a non-conformity will be recorded,
· How a non-conformity will be reviewed.
· What are non-conformities?
The term “non-conformities” is used as a one term throughout this chapter to include reference to
“actual” and/ or “potential” non-conformities.
Actual non-conformities
40
NCC
· “Actual” non-conformities can be defined as a “finding” and include where a breach has actually
occurred (i.e. the breach of policy, legal requirement or procedure has already occurred). This
includes:
· A non-fulfilment of a IEnvA requirement through:
o deliberate/accidental breach/disregard of legal or other requirements,
o failure to manage an environmental risk,
o breach (deliberate or accidental ) /disregard of policy/ procedures,
o An Accident or Incident.
Potential non-conformities
· Potential non-conformities can be defined as an “Observation” where evidence states that there
is not a breach of a requirement i.e. there has not been a direct breach of the policy, but if this
continues to occur there may be.
· Potential non-conformities include:
o A near non-conformity (e.g. if waste bins are not accurately labelled, however, waste is still
being segregated correctly).
o A near miss/hit (e.g. where a drum falls over but it is empty and therefore there is no spillage
of oil or chemical, this time).
o An observation (e.g. a drum of oil stored precariously on shelf, it has not yet fallen over but it
is likely to in the near future).
o An opportunity for improvement (e.g. the policy is located on the internal website but
individuals are not informed where the policy can be found).
Defining roles and responsibilities

Roles and responsibilities for identifying and investigating non-conformities, establishing actions,
following up on actions and reviewing the effectiveness for actions need to be clearly defined within the
procedure. This needs to be undertaken in accordance with Section 5 Roles and Responsibilities.
Alignment of the procedure with other sections of IEnvA program
In the development of this procedure, any supporting documentation (such as forms and registers) and
records generated as a result of this procedure, will need to be undertaken in line with Section 6
Documentation and Records.
NCC 13.02 The Operator shall identify and document non-conformities as a result of internal
assessments, external certification assessments, through day to day activities or as a result of an incident.
Guidance
When might non-conformities be identified or raised?
Non-conformities can be identified through a number of different ways:
· On-going internal assessment (e.g. this may include cross departments assessments, internal
IEnvA assessments);
· External certification assessment (e.g. through external assessment against the IEnvA program
or \);
· Through staff identification (e.g. in undertaking their day to day activities, staff identify that there
is a non-conformity, e.g. that waste has not been appropriately segregated); or
· As a result of an incident or findings raised in an incident report.
Where non-conformity is identified in an internal assessment:
Internal assessors (e.g. during a cross departmental assessment) may identify non-conformities through
internal environmental assessments, this may include internal IEnvA assessments, or internal ISO
14001 audits.
41
Where a non-conformity is identified in an IEnvA assessment:

External assessors may identify non-conformities through external assessment against the IEnvA
program or.
Where a non-conformity is identified by a staff member:
The Operator should encourage feedback on the environmental management system and/or programs
from its staff and those working on behalf of the Operator. As detailed in section 11 (Communication) of
the IEnvA program, the Operator should inform its staff of the management system and how it affects
them. If this is done effectively, staff may be encouraged to report suggestions for improvement,
incidents and/or non-conformities that have occurred that are not in line with the requirements.
The following provides some examples of how staff could report instances of non- conformities to an
Operator:
· Staff can directly report instances of non-conformity to the representative(s) responsible for
Environmental Management such as the Environmental Manager or Environmental Team;
· The Operator may choose to establish an email address where staff can email suggestions
including instances of non-conformity. If this is the case, this email address will need to be
frequently monitored by relevant staff with environmental responsibilities; and/or
· Suggestions which allow staff to include details of non-conformity are made available to staff
either on an online database or via a physical suggestion box (staff will not have to include their
names in these forms - this may be appealing for anonymity reasons).
Where a non-conformity is raised as a result of an incident:
Where an incident occurs (i.e. a spillage of oil), this will result in the same process needing to be
followed as a non-conformity, (i.e. incident investigation), corrective action and follow up to ensure that
the actions have been rectified in a timely manner. Therefore, Operators will need to identify incidents as
non-conformities and ensure that the same process is followed.
Documenting non-conformities:
Once a non-conformity is raised, a non-conformity request or form needs to be formally completed.
Non-conformities can be initially raised by telephone or email directly to the environmental manager or
representative(s) who may than take responsibility for completing the non-conformity form.
The non-conformity form could include:
· The requirement against which the non-conformity has been raised
· A description of the non-conformity, which can be:
o factual,
o objective,
o clear and concise,
o traceable.
· Objective evidence should be gathered and included in the form.
The purpose of issuing a non-conformity request or form is to correct the non-conformity and prevent it
from reoccurring.
Non-conformities can also be raised directly on to a non-conformity log. An example of a non-conformity
log is included within section 7 below. However, there must be a process to establish actions and
effectiveness of those actions which will need to be appropriately signed off.
NCC 13.03 Non-conformities shall be analyzed by the Operator in order to identify the root cause of a
problem.
Guidance
The “root cause” of a problem is the underlying reason why a non-conformity has occurred. Root cause is
the fundamental reason for an issue and is the only way to determine actions to ensure issues do not re-
42
NCC
appear (i.e. preventive actions). Therefore in line with the procedure established above, the following actions
will need to be undertaken.
Where the Operator has a system in place for investigation process in place
Many Operators may have an established system for investigating non-conformities and observations
(for example through Safety Management System Requirements). However, the Operator will need to
check the following guidance to ensure that any existing investigation process is compatible with the
IEnvA Program requirements.
Where the Operator does not have a system in place for investigating with non-conformities
For Operators that do not have an established system for investigating non-conformities, the following
methodology is recommended. This will need to be managed in line with the procedure outlined in NCC
13.02 above.
Step 1: Problem solving
In determining corrective actions, the Operator will seek to determine the “root cause” of the non-
conformity. The purpose of identifying the “root cause” of a non-conformity is that it:
· requires identifying the root cause versus the symptom,
· eliminates problems effectively,
· uses a structured methodology.
Step 2: Root cause analysis methodologies
There are many reasons non-conformities may be identified. Examples of root-causes for Operators
may include:
· poor design, location and installation/ inappropriate facilities,
· breakdown/ wear and tear/poor maintenance,
· deliberate (disregarding procedure, vandalism),
· accidental (lack of awareness, lack of procedure, mistake).
In order to identify the specific root cause, the Operator needs to consider the complexity of the non-
conformity.
For less complicated non-conformities, discussions on the most appropriate methodologies to be applied
with key representatives and asking the “5 whys” can be used (see detail below).
For more complicated problems, the Operator may wish to assemble a team and use specific
methodologies stemming from more detailed team discussions (e.g. fishbone or Pareto analysis) to
identify suitable corrective and preventive actions.
The simplest method for identifying the root cause of a non-conformity is the ‘5 whys’ methodology, as
follows:
· Write down the specific problem
· Ask why the problem has taken place and then write down the answer
· If the answer provided doesn’t identify the cause of the problem then the Operator will ask again
why this happened and write down the answer
· The Operator will then go back to step 1 until the team is in agreement that the root cause(s) of
the problem/non-conformity is identified. This may be repeated several times and in majority of
cases 5 or less ‘whys’ will establish the root cause.
Examples of root causes include:
· poor communication,
· lack of understanding,
· inadequate investment,
43
· lack of resource,
· incomplete system,
· ineffective documentation,
· or a combination of the above.
Within the IEnvA Program - if a root cause requires a long-term investigation, the Operator will need to
set and develop a objectives and targets to deal with the non-conformity (refer to Section 9 Objectives,
Targets & Impact Assessment).
NCC 13.04 The Operator shall ensure action is undertaken to correct the non-conformity, mitigate
environmental impacts and prevent reoccurrence within a time fame that is determined by the airline
operator according to the significance of the non-conformity.
Guidance
Once the root cause of the non-conformity has been established, the Operator will establish a corrective
action (or a corrective action plan) to correct the non-conformity, ensure the environmental impacts are
minimized and prevent the non-conformity from reoccurring.
Corrective action:
A corrective action can be defined as action taken to correct a non-conformity and prevent it from
reoccurring. There may be more than one action that is required to be undertaken to both correct an
issue (more immediate action) and prevent it from happening again (longer term action). For example,
waste may have been stored in the incorrect location, for which the immediate corrective action (to
correct the nonconformity) is to move it back to the correct location. In order to prevent it from happening
again, it is important to understand the root cause of the problem, for example it may be that the
individuals do not know where waste needs to be stored (i.e. poor communication or lack of training).
The action required to address the root cause will take longer (and probably more resources) to rectify.
Preventive action:
A preventive action can be defined as taking proactive steps to ensure a potential non-conformity does
not occur (i.e. this may be to rectify a potential non-conformity or an observation).
The term Corrective action will be used throughout this chapter and is used to cover both corrective and
preventive action. Therefore where potential non-conformities (e.g. observations) are identified this
needs to be managed in the same manner as outlined above and within an appropriate timescale to
ensure that an actual non-conformity is not realized.
In implementing corrective action, the Operator will need to consider establishing:
· plans,
· time-scales,
· responsibilities,
· resources.
Actions taken need to be appropriate to the magnitude of the problems and the environmental impacts
encountered. For example, action to rectify a legal breach would expect to be resolved in a shorter time
scale than an action to rectify a lack of awareness of the procedure. The corrective action can be included
on the same form as the non-conformity form.
NCC 13.05 Corrective and Preventive Action taken shall be subject to review by the Operator to ensure
the effectiveness of the corrective and preventive action undertaken.
Guidance
In order to evaluate the effectiveness of corrective and preventive actions, the root cause of the non-
conformity needs to be considered and the action verified to ensure that the root cause of the problem
has been completely removed rather than just implementing a short term fix. This can be undertaken by
directly checking the effectiveness of the action and seeking evidence that the issue has been
addressed through further investigation, observation of a task, or documentation review before the
44
NCC
action can be truly closed off. Once it has been satisfied that the original problem has been removed the
corrective action plan can be signed off.
It does not have to be the original individual who raised the non-conformity who reviews the
effectiveness of the action taken this can be performed by another individual as long as they are
independent. Where action is found to not be effective, the person responsible for the Corrective Action
must initiate the corrective action cycle again to determine an adequate solution to the problem.
Trends
Trends of non-conformities should also be considered to ensure that the root cause of non-conformities
is being appropriately addressed. For example, trends may demonstrate whether the same issue is
occurring repeatedly in different areas of the business. Therefore, it may be of benefit to log all non-
conformities or actions on a single log or spreadsheet so that trends and outstanding actions can be
easily reviewed and identified.
Management review of findings
During management review meetings, corrective actions and preventive actions need to be evaluated to
ensure the measure of completion and whether these actions were effective. This will be undertaken in
line with Section 17 Management review of the IEnvA program.
45
Process Flow Chart for Non-Conformance Identification
Non-conformance identification Non-conformance identification

through internal audit / external through observation by staff /
audit programs incident reporting
Documentation of non-
conformance
Root cause analysis

identification and
documentation
Corrective / preventive action

identification and
documentation
Review and document trends
Review Not Effective
Effectiveness
Effective
Report effectiveness of
corrective and preventative
action in management review
meetings
46
Section 14 – Operational Control (OPC)
Introduction
Operators need to manage and control their significant environmental aspects and impacts through the
establishment and implementation of operational procedures and controls. Procedures and controls must
provide clear instructions and guidance for staff and those working on behalf of the Operator where there are
significant environmental aspects and impacts, and legal and other obligations.

This requirement has been made part of the IEnvA Management System as it is an essential component of
the standard(s) (including but not necessarily limited to) ISO 14001:2004, BS855:2003 and EMAS
(Regulation 1221/2009). It is a requirement for program membership by IATA and is seen as an essential
requirement for successful implementation of the IEnvA Program.

OPC 14.01 The Operator shall determine the level of control is has of the significant aspects and
document the results.
Guidance
Each significant aspect must be considered in terms of operational control or the ability of the Operator
to control or influence the significant aspect, the related activity and the resulting impacts (see section 8
for guidance on determining significance).
The Operator should establish the level of control over the activities (i.e. whether the Operator has direct
control, the ability to guide and/or the ability to influence activities):
· Direct Control: facilities, services, equipment and activities for which the Operator has control
and/or ownership;
· Guide: facilities, services, equipment and activities owned/controlled by subcontractors, close
partners and suppliers for which the Operator can provide detailed guidance; and
· Influence: facilities, services, equipment and activities owned/controlled by loose partner
tenants, partners, clients, government agencies etc. for which the Operator can only influence.
OPC 14.02 The Operator shall document and implement procedures for all of its significant aspects.
Guidance
Where the Operator has established its ability to controls the significant aspect and the related activity
For the significant aspects and impacts, the Operator should review any existing controls and where
required establish and implement controls in order to manage the activities appropriately.
Operational controls should assist the Operator in meeting its environmental policy commitments,
achieving objectives and targets, complying with applicable legal requirements and other requirements
(if applicable) to which the organization subscribes, and managing its significant environmental aspects.
In summary, the Operator should implement operational controls to:
· manage identified significant environmental aspects;
· assurance of compliance to legal requirements and other requirements; and
· achieve objectives and targets and ensure consistency with their environmental policy, including
the commitment to prevention of pollution and continual improvement, and avoiding or
minimizing environmental risks.
Establishing Operational Controls
47
There are various types of operational controls which an Operator may implement including:
· documented procedures,
· work instructions (e.g. flowcharts),
· pictures (often used to highlight waste disposal practices),
· use of trained personnel and training,
· physical control (e.g. sumps, bunds, aircraft alert systems),
· a combination of all of the above.
When developing and implementing operational controls, the Operator must consider all of its aspects
and the related activity, identified as significant.
The type of operational control may be based on the current skill and competency levels of staff, the
complexity of the environmental aspect and impacts and potential risk.
For example, waste operational controls may consist of:
· a written procedure for all waste streams, including all non-hazardous and hazardous waste,
storage, treatment and disposal routes;
· work instructions for managing specific waste streams or for specific departments i.e. for aircraft
waste or maintenance workshops; and
physical controls (i.e. signage on bins, different colored bags, labelling, bonded areas etc.).
Documenting Operational Controls:
The Operator should make sure that individual(s) involved in developing, writing and documenting
operational controls are competent and have an understanding of the Operator’s activities, related
environmental impacts and legal/other requirements. The Operator should review the roles and
responsibilities within the environmental management system or IEnvA Program.
As with other procedures, Operational Control procedures should include:
· Purpose/ Scope and Objective - the purpose of the procedure, the areas/activities to which the
procedure applies;
· Definitions - meaning of key terminology included in the procedure;
· References/Relevant Documentation - associated procedures, reference to guidance);
· Legal and Other Obligations- list of legislation and other requirements (where applicable);
· Requirements for operations - minimum legislative and other requirements, associated
operator’s standards for performance (in particular where no or little legislation is in place),
assessment measures and requirements, mitigation methods, and monitoring and
benchmarking as required, physical controls in place to manage its significant aspect;.
· Responsibilities - details of the persons responsible for ensuring the operational control is
adhered to, the responsibilities of all staff associated with managing the significant aspect and
impacts; and,
· Work Instructions/ Tasks - details of how the aspects and impacts should be controlled. This
may also include flowcharts and diagrams.
· Additional Forms - supporting checklists, posters, and assessment sheets.
In addition to the above, documented operational controls should align with the IEnvA Document Control
section and must include:
· a Title,
· authorization number,
· date,
48
OPC
· who the operational control is authorized by.

Implementing and Maintaining Operational Controls
Operational controls need to be implemented with appropriate communication and training to relevant
parties to ensure implementation.
The Operator should monitor the effectiveness and application of controls. This should be managed
through the Operator’s internal assessment process as detailed in the IEnvA Internal Assessment and
Monitoring and Measurement sections.
OPC 14.03 The Airline Operator shall communicate applicable procedures and requirements to relevant
staff (including contractors and suppliers) that perform tasks or activities that relate to the significant aspects.
Guidance
Once Operational Controls are established, the Operator should manage the implementation of the
operational controls and procedures through internal communication and training across the business.
This should be aligned with the Operator’s communication procedure and training program to ensure
that staff and anyone working on behalf of the Operator are aware of the requirements, adequately
trained and competent to undertake activities. This should be conducted in accordance with the IEnvA
Communication and Training standards and accompanying guidance.
For example, an Operator may provide a short training course on hazardous waste procedures and all
staff dealing with hazardous waste disposal could be required to sign a document declaring they have
read and understood the requirements.
Contractors and those working on behalf of the Operator
The Operator should also make sure that, prior to commencing work on site or on behalf of the Operator,
contractors and suppliers who are considered to pose a potential environmental risk or generate a
significant impact are appropriately informed of the Operator’s policy and environmental procedures.
Information provided to contractors and suppliers may include (see section 11 Communications):
· environmental policy,
· environmental questionnaire,
· environmental contractor form,
· operational controls.
For example, a maintenance contractor could pose a potential risk to the environment and may be
required to receive environmental induction training such as guidance on storage of hazardous materials
and waste management procedures when performing work on behalf of the Operator. After the
Operator’s training, the contractor may be asked to sign a copy of a form stating that they have read and
understood the contents of the information contained within the guidance material for the Operator’s
records and evidence.
All records of information provided to contractors should be retained and documented as part of the
training program.
The level of training on operational control procedures will relate to the types of activity being
undertaken. For example, a mail delivery contractor would not be required to undertake training on site
operational controls however they may be provided information on the Operator’s environmental policy.
OPC 14.04 Where the Operator does not have direct control, the Operator shall seek to work with
suppliers and contractors in order to control significant environmental aspects.
Guidance
The Operator should engage with suppliers and contractors to control significant aspects and impacts
where there is no direct control. A risk based approach should be used to identify areas which should be
prioritized.
Where the Operator does not have operational control:
49
If determination has be made and documented that the Operator does not have operational control, then
all efforts should be made to try to influence the significant aspect and to reduce the impact to as low as
practically possible.
Example:
It was determined that the Operator have limited operational control over a number of charter aircraft
that are operated for summer charters under a wet lease arrangement as all of the crew are supplied by
the lessor.
While there is very limited ability to control how the flight crew of the wet lease aircraft fly you should as
a minimum give the contract crew the ability to use your existing significant aspects control procedures
(assuming aircraft type and safety ratings are all in compliance) such as single engine taxi for fuel
conservation. Even if the contract crew or the lessor refuses to use any for your existing fuel
conservation procedures, the operator has shown that you have exercised your ability to influence the
significant aspect to its full capacity.
Where the Airline Operator does not have direct control:
The level of information provided to suppliers and contractors should be provided according to a risk-
based approach. Suppliers and contractors deemed to have a more significant impact on the
environment, or with little controls in place should receive more guidance or engagement.
For certain operations, it may be possible for the Operator may perform periodic checks with contractors
and suppliers through second party auditing of areas such as waste disposal/ hazardous waste
management. These contractors may be checked on a more frequent basis (e.g. annually or bi-
annually). In addition, larger suppliers and contractors to the Operator should be checked on a regular
basis. Further guidance is provided in IEnvA Internal Assessment section.
For further guidance, the IATA Environmental Best Practices Manual (IEBPM): Flight Operations and
Corporate Activities – Sustainable Procurement provides information on:
· Compliance, control/mitigation and monitoring best practice guidance that the Operator could
implement to ensure that third parties improve their environmental performance.
Records of all checks and engagement with suppliers and contractors should be retained.
OPC 14.05 The Operator shall review operational controls as a minimum on an annual basis through
their internal assessment or auditing process.
50
Section 15 – Emergency Preparedness (ERP)
Introduction
The Operator may experience environmental emergency situations which can have environmental impacts.
It is appropriate to consider environmental impacts from emergency situations when all potential safety
concerns have been dealt with. These situations can lead to pollution incidents including the contamination
of land, surface and ground water with effects which could lead to illness, harm to property and/or species
and/or protected habitats.


ERP 15.01 The Operator shall implement and maintain a procedure to identify potential emergency
situations and potential accidents that can have an impact(s) on the environment.
Guidance
Establishing a procedure for emergency response
Where the Operator has an emergency response procedure:
· Many Operators may have an emergency response procedure (for example through their
Environmental department or other departments /management teams such as health and safety
team). However, Operators will need to check the following guidance to ensure that any existing
emergency response process is compatible with the IEnvA requirements.
Where the Operator does not have an emergency response procedures:
· The Operator must implement and maintain a procedure for identifying emergency situations
and potential accidents - please refer to Significant Aspects and Impacts which details how
Operators can identify potential emergencies for environmental aspects and impacts.
The procedure(s) and associated controls should include, where appropriate, consideration of:
· accidental emissions to the atmosphere;
· accidental discharges to water and land; and,
· specific environment and ecosystem effects from accidental releases.
The procedure(s) should take into account potential consequences of abnormal operating conditions,
potential emergency situations and potential accidents.
The following details sections that Emergency Response Procedures may include:
· Company overview details:
This section of the procedures should include:
· details of the site: name, full postal address, national grid reference/location and any contact
details;
· a summary of the main business activities carried out on site;
· objectives of the plan;
· the date the plan was signed off, by whom and the version number;
51
· the person who is responsible for the plan’s review, distribution and implementation; and,
· a distribution list of staff and external organizations that hold copies.
External and internal contact lists
The external contacts list should contain 24-hour contact details for all those organizations or companies
that may need to be involved during or after an incident. For example:
· emergency services;
· the relevant environmental regulator;
· local authority;
· local water company/authority;
· the Health and Safety Executive;
· local health care providers/Health Protection Agency;
· specialist clean-up contractors; and
· sources of specialist advice (e.g. Government Decontamination Service).
Site chemical, product and waste inventory
The Operator must maintain an up-to-date record of all substances stored on-site, together with an
indication of the maximum quantity likely to be stored. Material Data Safety Sheet or equivalent for any
substances posing a risk to people and/or the environment should be attached to the emergency
response plan.
Pollution prevention equipment inventory
A record of the equipment and materials on site to deal with pollution incidents should be kept:
· absorbents,
· drain mats/covers,
· pipe blockers,
· booms,
· pumps,
· over drums,
ERP 15.02 The Operator shall document the potential emergency situations which have the potential to
cause environmental impacts for its operations.
Guidance
Examples of typical emergency operations for Operators include:
· Crashes
· Jettisoning
· Major spillages of > 1000 liters typically from:
o delivery and storage of hazardous materials;
o refueling;
o leaking of above ground or underground hazardous material storage tanks;
o aircraft on the ground activities such as taxiing engine start/run up;
o spillages from de-icing activities; and
o wastewater drainage and discharge.
· Minor spillages of < 1000 liters typically from:
52
EMP
o ground service vehicles;

o delivery and storage of hazardous materials;
o refueling;
o leaking of above ground or underground hazardous material storage tanks;
o aircraft on the ground activities such as taxiing engine start/run up;
o spillages from de-icing activities; and
o wastewater drainage and discharge.
Emergency situations should be identified through a risk based approach such as that detailed in the
Aspects and Impact Significance chapter.
For pollution to be considered an issue, there needs to be a:
· Source - Presence of hazardous substances, Gas, Liquid or Solid e.g. bulk oil or chemical
storage, spillages from vehicle;
· Pathway- Route by which receptor comes into contact with a pollutant e.g. water course; and,
· Receptor- Entity which is vulnerable to adverse effects of pollutants e.g. surface water, rivers,
lakes, sea, groundwater and land.
ERP 15.03 The Operator shall appropriately respond to environmental emergencies when they occur.
Guidance
Operators should respond to environmental emergencies according to the details in its Emergency
Response Plan.
The Emergency Response Plan should also detail how the Operator would deal with environmental
emergencies.
The process for responding to spillages, e.g. for oil/fuels, is detailed below:
PROCESS LAND/DRAINAGE SYSTEM WATER
IDENTIFY Where source is readily identifiable, wearing Where source is readily identifiable,
appropriate PPE prevent further release at source wearing appropriate PPE, prevent further
e.g. switch off tap/valve, correct leaking drum. release at source e.g. switch off tap/valve,
Switch off sources of ignition. correct leaking drum.
Where source is not readily identifiable action Where source is not readily identifiable
should be taken to notify and contain first. action should be taken to notify and contain
first.
NOTIFY Notify the relevant Environmental Manager or Notify the relevant Environmental Manager
equivalent. or equivalent.
PROTECT Protect nearby sensitive areas (e.g. drains, Create a temporary bund on the banks of
watercourses) using drain covers or by creating a the watercourse to prevent the spill entering
temporary barrier from sand or spill kit materials. the watercourse.
CONTAIN Contain the spillage by creating a temporary bund Deploy a boom across the watercourse to
using sand or spill kit materials to prevent it prevent migration of the spill further
migrating. downstream. Where the watercourse is
Apply absorbent granules or pads to soak up the narrow, shallow and slow flowing (i.e. a
oil. ditch) a temporary dam may be
constructed.
53
Apply absorbent pads to soak up oil.

DISPOSE Once the oil has been absorbed, place oil Once the oil has been absorbed, place oil
contaminated absorbents into heavy duty plastic contaminated absorbents into heavy duty
bags. Dispose of as Hazardous Waste. plastic bags. Dispose of as Hazardous
Waste.
REVIEW Review ground for residual contamination. Remove boom (or dam) once all signs of
Remove any contaminated ground where spill has visual contamination have gone.
reached non-hard standing areas. Remove temporary bunds on bank.
ERP 15.04 The Operator shall make sure that relevant employees and contractor are aware of the
emergency procedures and appropriately trained.
Guidance
The Operators should make sure that all relevant staff and/ or contractors are aware of the emergency
response procedures through programs such as those highlighted in the IEnvA Program training
chapter.
Once the emergency response plan has been written, the Operator should develop supporting
emergency procedures to check the plan works in the event of an incident. The Operator must make
sure all relevant staff and contractors are aware of these procedures and the plan.
Examples of information to include are:
· procedures for alerting key staff;
· standby/rota systems;
· clearly defined roles and responsibilities;
· names of staff and contractors trained in incident response;
· the types and location of emergency response equipment available and appropriate personal
protective equipment (PPE) to be worn;
· a system of response coordination; and
· off-site support.
Staff and contractor training should include:
· awareness of the potential for harm to people and the environment from the materials held on-
site;
· information on the sensitivity of the environment surrounding the site;
· the environmental responsibilities of the Airline Operator;
· use of the correct personal protective equipment and any appropriate and/or necessary health
and safety training;
· reporting procedures if there’s a risk of surface water, groundwater or land contamination;
· reporting to the local water/sewerage undertaker if a discharge to the foul or combined sewer is
involved;
· safe and correct use of all spill clean-up equipment or pollution prevention structures and/or
devices on site;
· safe handling and legal disposal of contaminated materials and wastes resulting from an
incident, including arrangements for using specialist contractors and services; and
· appropriate and safe decontamination.
Contractor Engagement
54
EMP
The Operator needs to make sure that key contractors and contractors whose activities can potentially
lead to an environmental emergency are suitability trained and engaged in the Operator activities.
Operators should do this by:
· Holding awareness sessions with relevant contractors on the Airline Emergency Response
Procedures to make sure that all contractors know the Airline Operator emergency procedures;
· Training contractors on Airline Emergency Response Procedures, these could include practical
sessions on spillage training; and,
· Reviewing contractor emergency response procedures - if the contractor also has emergency
response procedures, the Airline Operator should review these to make sure that they are
appropriate.
Ideally contractors should also retain copies of the Airline Operators emergency response procedures.
ERP 15.05 The Operator shall periodically test its emergency response procedures.
Guidance
Once the environmental emergency response plans are completed, the Operator should test them
regularly, for example testing major spill response procedures. Exercises are vital to:
· validate the whole plan – does it work?;
· develop staff’s and contractors’ competencies in emergency response; and
· test standard procedures.
The Operator could design exercises to be discussion based, table top or live. Either the entire plan or
critical elements within it could be tested such as:
· contacts lists;
· the activation process;
· equipment; and
· information management.
Where possible, the Operator should also include external partners/response units as this helps validate
the plan.
The frequency of testing and exercising should be related to the environmental risk , staff turnover, the
introduction of new processes or materials and conclusions from any previous exercises or incidents.
The test may be joined with general emergency response exercises if possible and practical to do so.
The testing of procedures may be performed in a physical simulation where by the simulation of an
environmental emergency is made as real as possible or tested in a desktop capacity where by the
stakeholders sit around a table and work through the procedure testing its effectiveness.
The purpose of the task is to ensure that the procedure works efficiently and that the intended outcomes
of the procedure are met.
The effectiveness of any site incident response plan will depend on staff training.
The Operator must make sure that all staff and contractors working on-site are aware of the plan which
should be made available electronically and in hard copy. All staff and those working on behalf of the
airline should know their role and responsibilities and the relevant procedures if an incident occurs.
As detailed in IEnvA Training chapter, records of staff training should be maintained and regularly
reviewed.
ERP 15.06 The Operator shall periodically review and where necessary revise its emergency
preparedness and response procedures, in particular, after the occurrence of accidents or emergency
situations.
55
Section 16 – Internal Assessment (INA)
Introduction
As part of any successful management system, the Operator need to evaluate how the management of their
IEnvA program is performing through periodic internal assessments. This shall be undertaken to
demonstrate whether the Operator’s Environmental Management System conforms to IEnvA Standards and
Recommended Practices and also any documented environmental management policies, procedures or
processes. The process will identify opportunities for improvement and also detect any material gaps in the
program, offering a place to rectify any non-conformity identified.

standard(s) (including but not limited to) ISO 14001:2004, BS8555:2003 and EMAS (Regulation 1221/2009).
It is a requirement for program membership by IATA and is seen as an essential requirement for successful
implementation of the IEnvA Management System.

INA 16.01 The Operator shall have conducted a complete internal assessment of its entire IEnvA
Program prior to the external assessment or at least once every two years.
Guidance
For Operators that already have an internal assessment process
Operators may already have established internal assessment processes or internal audit / surveillance
programs driven from the Safety Management System Requirements. Where this is the case Operators
may wish to integrate the IEnvA assessment process with existing systems. However, Operators should
check the following guidance to ensure that any existing internal assessment process is not less
rigorous than the requirements of IEnvA.
For Operators that do not have an internal assessment process
Step 1: Plan internal assessments to check the system conforms to the IEnvA program
This requires the Operator to check that the Environmental Management System they have developed
and implemented has been undertaken in line with all the IEnvA Program requirements.
The internal assessment requires all components of IEnvA to be assessed on a periodic basis. It is
recommended that initially each section of the IEnvA manual is assessed on an annual basis.
Step 2: Ensure internal assessments are conducted as planned and check that environmental requirements
have been correctly implemented and maintained.
The Operator can plan internal assessment throughout the year, focusing on both the system and any
operational procedures developed or incorporated as part of the IEnvA ESARP. This shall include not
only that the requirements of IEnvA have been fulfilled but that it has been implemented within the
organization.
Step 3: Develop an assessment schedule
An assessment schedule is vital document which enables assessments to be scheduled and delivered
systematically with the least possible disruption and facilitates resources management.
The Operator should develop an assessment schedule and make sure it conducts the assessments that
have been scheduled. Assessments can be planned according to the calendar year, the Operator’s
financial year or can be delivered during a specified timeframe; however, assessment schedules should
cover at least a 12 month period.
The Operator should recognize that some IEnvA requirements can be assessed together and it may be
beneficial to group them together. For example Section 3 Policy and Section 11 Communication can be
56
INA
assessed together on the same day at the same time, to facilitate resource management and assess
continuity between separate but interrelated IEnvA modules.
Assessment scope and objective
All elements of the IEnvA system should be assessed and included in the schedule. The schedule can
be further broken down per department, country or hub. For example, the assessment objective is to
determine compliance against Section 3 (POL) but the scope is that this will be assessed in the
corporate offices.
Assessment frequency
Assessments need to be scheduled on the basis of environmental status, importance of the activity, and
results from previous assessments.
For example, in the previous year’s assessments, there were 12 non-conformities outlined against IEnvA
system Section 12 Training, Competency and Awareness, however none raised against Section 11
communication. This will highlight that Training, Competency and Awareness needs to be assessed
twice in the 6 month period, whereas communication only needs to be assessed once.
In addition the assessors shall test the results of prior assessments to make sure that the solutions are
adequate.
INA 16.02 The Operator shall establish and implement a documented procedure or process for
managing internal assessments.
Guidance
The internal assessment procedure shall be documented. This can be included in existing documented
procedures or processes, such as Safety or Quality internal assessment procedures or in a stand-alone
document; however it is likely that the Operator will already have some processes for managing internal
assessments / audits.
For Operators that already have an internal assessment procedure documented
The Operator may already have established internal assessment procedures documented such through
their Quality systems or their Safety Management Systems. Where this is the case airline operators may
wish to integrate the IEnvA assessment process with existing systems. However, the operator shall
check the following guidance to ensure that any existing internal assessment process is compatible with
the IEnvA requirements.
For Operators that do not have an internal assessment process the documented procedure shall cover the
following
Step 1 Responsibilities and requirements for planning the assessment
Planning the assessment involves defining the objectives and scope, arranging the necessary
resources, and ensuring that the assessor and the individual/s involved in the assessment are prepared.
· The environmental manager or other representative shall be responsible for defining the
assessment schedule and also informing the assessor (and/or team) of the objectives and
scope
· The designated assessor shall be responsible for organizing the assessment at a respective
time with the individual involved in the assessment and also for preparing for the assessment.
Assessment preparation will include preparing an assessment plan and checklist to facilitate the
assessment.
· An assessment plan will include:
· assessment objectives and scope,
· assessment reference number (what is being assessed),
· date,
· start times and finish times, including opening and closing meetings, times expected to speak to
individuals or visit certain departments, break times, etc.
57
The assessment plan should then be discussed with the department to be assessed prior to the
assessment date.
An assessment checklist should be prepared prior to the assessment. If time allows the assessor should
review any documentation available prior to the assessment so that they can understand specific
features of the EMS that merit further examination and use this to further develop the checklist. The
purpose of a checklist is to act as an “aide memoir” for the requirements to be checked and also enables
the assessor to make notes against the requirements.
Essentially telling the assessor:
· what to look at,
· what to look for,
· who to speak to,
· what to ask them.
Step 2 Responsibilities and requirements for conducting the assessment

Conducting the assessment involves visiting the location or department to be assessed (i.e. where the
relevant activities outlined in the assessment scope are being undertaken), collecting objective
evidence, and verifying whether the system conforms to the assessment criteria. At the end of this
phase, the assessor will have recorded findings to report back.
· The designated assessor shall be responsible for conducting the assessment at a respective
time with the individual involved in the assessment.
· Those individuals responsible for the areas being assessed have a responsibility for ensuring
that the relevant staff are made available for the assessment.
Objective evidence is evidence that verifies that something is occurring as it should be. Objective
evidence may include documented records (e.g waste transfer documentation), visual observations (e.g.
a photograph of how things are stored) and collective responses to questioning. The objective evidence
is then catalogued and stored to support findings.
Conducting the assessment is broken down into the following:
Opening Meeting
The opening meeting is a brief meeting or call before the assessment with the person responsible for the
elements within the scope of the assessment. The meeting should be led by the assessor and should
include:
· introductions,
· an outline the objectives and the scope of the assessment,
· confirmation the timetable for the assessment,
· confirmation of who should be involved in the assessment,
· explanation of how objective evidence will be collected,
· explanation of the reporting process,
· an outline of what shall be included within the assessment,
Corporate activities and flight operations site walk around (visual assessment and questioning)
In addition to assessing the assessment objectives, assessors should aim to identify:
· environmental performance improvement,
· system procedures / controls improvement,
· shared best practice between sites / departments,
58
INA
· opportunities to highlight and celebrate good practice,

· new processes / best practical environmental options or best available techniques,
Visual site assessment for corporate activities and flight operations will differ. For corporate activities
visual site assessments include the Operator’s offices and buildings while flight operation walk around
will include aircraft.
The assessor should walk around the site to better understand the activities at the site for corporate
activities and flight operations including:
· Air emissions
· Noise
· Water
· Wastewater
· Resource consumption
· Other issues including:
o Biodiversity
o Biofuel and alternative fuel
o Oil storage and hazardous chemicals management
o Refrigerants in ground operations
o Procurement processes
Interviews:
The assessor should interview relevant staff on a variety of topics, dependent upon the assessment
topic, which may include the following:
· document review and system familiarization,
· environmental manual,
· resources, roles and responsibilities,
· systems and operational procedures
· environmental commitment and policy
· the scope of the boundaries
· aspects and impact register including significance
· roles and responsibilities of the EMS,
· documentation and records of the EMS,
· how activities are operated and practices adopted.
When talking to individuals this can also be used as an opportunity to pose hypothetical situations, such
as what the individual would do in the event of some spillage of oil to view their knowledge.
Records
· Assessors should also view as number of records. This may include (although not an exhaustive
list):
· legal review,
· training records,
· communication records,
· waste documentation,
59
· previous internal assessment documentation including assessment schedules, assessment

reports and non- conformities.
All records should be managed in accordance with section 6 of the IEnvA program.
Pollution Prevention Practices
As mentioned previously, all assessors should understand the risks of each Operator activity.
For pollution to be considered an issue, there needs to be a:
· Source - presence of hazardous substances (e.g. gas, liquid or solid)
· Pathway - route by which receptor comes in to contact with a hazardous substance (e.g. water
drainage); and
· Receptor - entity which is vulnerable to adverse effects of hazardous substances (e.g. surface
water drains, rivers, lakes, sea, groundwater and land).
Assessors should be vigilant of any evidence of pollution or potential risk of pollution for each activity
such as evidence of oil spillages from oil storage tanks at corporate sites.
Details of environmental risks are provided in the operational control and emergency operations
chapters of this document.
The internal assessor should seek to review the significant risks of each site in order to assess whether
these are appropriately managed:
Assessment of operational procedures:
The assessor will interview personnel and walk around the premises in order to determine whether the
Operator is managing its environmental risk according to:
· Environmental flight operational procedures (e.g. CDA approach, low power / low drag)
· Corporate operational procedures (e.g. waste management and segregation or sustainability
procurement policies).
Analysis and review of (but not limited to) the following:
· monitoring and measurement data,
· past assessments, non- conformities and assessment reports,
· training records,
· maintenance records,
· waste disposal records,
· any consents or approvals by the relevant Environmental authority,
· airport records,
· spillage records.
Closing meeting
After the assessment is completed the assessor should hold a closing meeting preferably with the same
attendees at the opening meeting; during which the assessor should present the findings including
observations and non–conformities.
Step 3 Responsibilities and requirements for reporting on the assessment
Following the assessment, a formal report of the assessment findings is presented, including non-
conformities
60
INA
· The assessor has responsibility for writing up the assessment findings and ensuring this is
communicated to the environmental manager or representative for quality review.
· The environmental manager or representative has responsibility to ensure that the assessment
report is communicated to the relevant departments and relevant senior managers.
The assessment report should include:
· assessment scope and objectives,
· assessment reference number,
· those parties involved in the assessment and their roles.
Summary and detail the key assessment findings which can include:
· Non–conformities identified as a result of:
· deliberate/accidental breach/disregard of legal or other requirements,
· failure to manage an environmental risk,
· deliberate/accidental breach/disregard of policy/ procedures.
Observations: Both Positive and Negative
· unplanned variation from intended process,
· opportunity to implement best practice,
· positive performance worth noting,
· possibility to share best practice,
Step 4 Responsibilities and requirements for retaining assessment records
Records of assessment shall be held and maintained in line with Section 6 Documentation and Records
IEnvA requirements.
Non-conformities shall be managed in line with Section 13
INA 16.03 The Operator shall assign trained, objective and impartial personnel to undertake the
assessment.
Guidance
Step 1 Choosing Assessment Teams
Environmental Internal Assessment teams can consist of either Operator staff members or other
identified professionals who have received appropriate training to conduct environmental or alternatively
assistance can be provided by external assessors if necessary.
Successful environmental assessors must have a good understanding of environmental risks including:
· environmental significance of activities in Section 8 (AIS),
· general compliance requirements,
· general pollution prevention / risk management measures.
It is important that the assessment does not overlook these issues irrespective of assessment subject.
If staff are not qualified to conduct internal environmental assessments, the Operator may wish to train
some staff. Training can be obtained from:
· on the job training through “shadowing” of existing trained assessors,
· internal assessor training programs (e.g. environmental teams provided in house assessment
training courses to individuals),
· external assessor training programs (e.g. allowing assessors to attend external courses).
Both internal and external training programs should cover:
61
· planning the internal assessments,

· assessing compliance and pollution prevention,
· assessment techniques,
· environmental risk assessment.
Records of assessor training and qualifications should be maintained in accordance with Section 6
(DOC), including training certificates, academic qualifications, signed training registers, training matrices,
resumes and copies of training presentations.
Step 2: Ensuring objectivity
All assessors should act in a manner that is free from bias and conflict of interest, so as not to sway the
outcome of the assessment and ensure the findings are based on facts or objective evidence.
Step 3: Ensuring independence
Where possible, internal assessors should be independent of the areas which they are assessing. This
means that they do not have a responsibility within the areas being assessed and are independent from
the operating managers of the function being assessed.
In small organizations it may not be possible to ensure complete independence but every effort must be
made to remove bias and conflict of interest. This may be resolved by working as a team or by samples
chosen as part of the assessment.
INA 16.04 Corrective actions shall be raised from any internal assessment findings.
62
Section 17 - IEnvA Management Review (MGR)
Introduction
The Operator will need to review the performance of their IEnvA Program to ensure that it continues to be
effective in meeting the Operator’s Objectives and Targets, adequately covers the desired operations and
business activities, and provides a framework for continual improvement. The IEnvA Program requires that
this review is undertaken through a formal and periodic management review.

This requirement has been made part of the IEnvA Management Program as it is an essential part of the
successful implementation of the IEnvA Management Program.

MGR 17.01 The Operator shall undertake a management review of its IEnvA Program on an annual
basis as a minimum.
Guidance
Step 1: Establishing the IEnvA management review processes
IEnvA Management reviews can be integrated with existing Safety or Quality management review
procedures or be a stand-alone management review, however it is likely that the Operator will already
have some processes for involving senior management in decision making of environmental issues.
Where the Operator has a process in place for undertaking management reviews
Many Operators may have an established management review process (for example Safety
Management System Requirements). However, the Operator will need to check the following guidance
to ensure that any management review process is compatible with the IEnvA requirements.
Where the Operator does not have a system in place for undertaking management reviews
For Operators that do not have an established system for undertaking management reviews, the
following methodology should be used as guidance.
Step 2: Establishing the frequency
For the purposes of the IEnvA program, a management review will need to be undertaken as a minimum
on an annual basis. Some Operators may wish to undertake management review on a more frequent
basis (e.g. every 6 months or every quarter). For the purposes of the IEnvA program, all topics outlined
below, will need to have been addressed as a minimum on an annual basis. This agenda can be
covered in a number of different management meetings or all in one meeting dependent upon the
Operators’ management structure.
For example, Operator X covers all the management review agenda items in one annual Board meeting.
Whereas Operator Y covers different management review agenda items in each quarterly Board
meeting, with all items covered on an annual basis. Both approaches are acceptable under IEnvA.
Step 3: How to undertake a management review
As outlined above, the management review can be amalgamated with other management meetings;
however, the Operator needs to ensure that the relevant topics are included, as outlined below.
For example Operator X may wish to discuss some Environmental Management Review items in an
Annual General Meeting (AGM) of executives. However, any other items that were not addressed in the
AGM could be considered during senior departmental management meetings, if more appropriate.
However, Operator Y may wish to discuss all relevant topics during the AGM to keep the process
concise.
63
The Terms of Reference of the management review need to be defined, the areas that need to be
covered and who should attend as detailed below.
Some Operators may wish to provide some of the results from management review meetings in the
Operator’s annual and sustainability reports. In such cases management review meeting could occur in
advance of or concurrently with the sustainability/annual reporting cycles so that information can be
provided within these reports.
Furthermore Operators may require certain figures (e.g. fuel consumption) to be reported to every
quarterly board meeting. This would mean that when other topics are discussed the senior departmental
management meetings this topic does not to be discussed.
However to be confident that all IEnvA requirements are covered it would be of benefit to document what
topics are discussed at which meetings. This can be included in the Terms of Reference for example.
MGR 17.02 The Operator shall ensure that relevant senior managers attend the management review.
Guidance
The individuals that take part in management review meetings should ideally be “the decision makers”
and those that can influence change within the Operator.
Typically employees that make up an environmental management review will need to include:
· Board member or representative,
· Senior IEnvA executive (as defined in IEnvA Program - Roles and Responsibilities),
· Relevant Management representatives of various departments across the business,
· Relevant Senior operational managers.
The topics covered within the Management review may also be discussed at a variety of meetings and
at different levels within the Operator; however, it is a requirement that senior management is
represented at the management review meeting.
The structure of the management review may differ between Operators and may include the following
scenarios:
Airline Operator ‘a’
The management review committee is made up entirely of the CEO and Board members who discuss
the relevant IEnvA outputs and areas. This information would be developed as a board report prior to the
meeting and presented to the board during the meeting by the Senior IEnvA executive. Any outcomes
from the meeting would be contained within the minutes of the meeting and addressed or delegated as
required by the Senior IEnvA Representative.
Airline Operator ‘b ’
The management review meeting is made up of Departmental Management who reports the outcomes
of the review directly to the board. The meeting is chaired by the Senior IEnvA executive.
Airline Operator ‘c’
The management review meeting is made up of different individuals who are stakeholders within the
environmental management system (this group may be members of an Environmental committee), along
with top operational and departmental managers (decision makers) who may also be board members.
The meeting is chaired by the Senior IEnvA executive and where necessary some agenda items are
discussed at Board Level.
MGR 17.03 The Operator shall conduct a review of its legal and other requirements to which the airline
operator subscribes at least annually.
MGR 17.04 The Operator shall conduct a review of its compliance status against the legal and other
requirements to which the airline operator subscribes at least annually.
MGR 17.05 The Operator shall conduct a review of its communication(s) from external interested parties
including complaints at least annually.
64
MGR
MGR 17.06 The Operator shall conduct a review of the extent to which objectives and targets have been
met and establishing new objectives/targets if required.
MGR 17.07 The Operator shall conduct a review of any changing circumstances e.g. changes to
activities, changes to significant aspects, legal or other changes, views of interested parties, changes in
technology, lessons learnt from any emergencies or incidents, review of Environmental Policy at least
annually.
MGR 17.08 The Operator shall conduct a review of its IEnvA related training to ensure that all training
requirements are being covered and are still relevant at least annually.
MGR 17.09 The Operator shall conduct a review, at least annually, of its environmental performance
and its environmental management performance to ensure continual improvements are being made.
MGR 17.10 The Operator shall conduct a review of any follow-up actions from previous management
reviews (if applicable).
MGR 17.11 The Operator shall conduct a review of any non-conformances identified from internal
assessments.
Guidance
The following details the minimum requirements that should be discussed during management review
meetings:
· Results of internal audits and evaluations of compliance with legal requirements and with other
requirements to which the organization subscribes
o Internal audits
§ Operator must discuss the results of any internal audits and the status of closing out
any non- conformances.
§ The Operator should also discuss the results of legal compliance assessments and
other compliance reviews.
§ Fines, warnings or legal action.
· Status of non-conformances from internal assessments

o The Operator must also discuss the status of any corrective and preventive actions and
whether these were effective or not. This will need to be prepared in advance so that a
summary and/ or trends of issues can be discussed.
· Communication(s) from external interested parties including complaints
o The Operator should discuss whether there was any communication from external
interested parties. This information could be obtained from various sources including the
communication log highlighted in the IEnvA Program Communication requirements.
o This would include only significant communications and may include for example
§ Operator Sustainability Reporting (including annual sustainability/ environmental
reports),
§ communication of benchmarking information to IATA,
§ complaints,
§ legal enquiries or those which might result in legal advice being required,
§ communication of environmental requirements from other or partner airlines,
· Specific communication from interested parties, including regulators, IATA, service partners or
stakeholders.
· The environmental performance of the organization:
o Whether the Operator is complying with legal requirements and other obligations, achieving
its goals and incorporating its environmental policy into its daily activities.
o This will be linked to the monitoring and measurement in the IEnvA program.
65
· This could also include more general environmental performance such as progress in procuring
Chapter 4 Aircraft or compliance with CDA.
· The extent to which objectives and targets have been met and establishing and setting new
targets and/or objectives
o The Operator must discuss whether they have achieved their targets and objectives. If
targets have not been achieved they can discuss why targets and objectives had not been
achieved and what can be done to realize these targets in the future.
o New targets may need to be set and agreed at the meeting, and may also require new
objectives to be set for the business.
· Follow-up actions from previous management reviews
o The status of any actions from previous management review meeting must be discussed.
o Changing circumstances. Some examples of this may include:
§ Changes in relevant Environmental Legislation and Other Requirements and the
Registers of Environmental Legislation
§ Changes to IATA reporting requirements
§ Changing to airport requirements, new routes and changes in partner airlines
§ Changes in significant Environmental Aspects and the Registers of Environmental
Aspects as a result of changing circumstances
§ New technological advances regarding flight operations
§ New fleet or operational changes
§ Changes to the business including the acquisition of new businesses or divestment
of businesses
· Recommendations for improvement

o Any recommendations for improvement could be discussed. Some examples of this include:
o shared best practice across the industry (e.g. regarding taxiing activities to reduce fuel
consumption or changes to the IEnvA Best Practices Manual);
o new objectives and targets;
o improvements to the reporting system (e.g. an online system where required information
[e.g. water, carbon, spillages] can be uploaded locally);
o training requirements for employees;
o specific Improvements to communication programs or more proactive communication;
o the suitability, adequacy and effectiveness of Environmental Training;
o the contents of the IEnvA Manual;
o the effectiveness of Document Controls;
o the effectiveness of Operational Controls
o the continuing suitability of Emergency Response Planning;
o the potential for any additional accidents and emergency situations;
o additional resources;
o additional budget requirements;
o marketing benefits;
· Outcomes
o The IEnvA management review should focus on opportunities for improvement and top
management should be involved in the evaluation of the suitability, adequacy and
effectiveness
66
MGR
MGR 17.12 The Management review meetings shall be documented and records maintained in
accordance with the Operator’s Documentation and Records procedure.
Guidance
Documenting the IEnvA Management Review
Once the management review is completed the Operator needs to ensure that the results of the review
are documented and held as a record, in accordance with Section 6 (DOC). Management reviews can
be recorded through minutes of meetings or a board report that has been approved by senior
management. There may presentation materials and handouts which are provided.
The Operator must make sure that the any decisions and/or actions related to possible changes to the
environmental policy, objectives, targets and other elements of the management system, consistent with
the commitment to continual Environmental Management improvement are recorded.
For example, Operator’s environmental policy was identified as needing updating during the
Environmental Management review meeting this should be recorded and an action assigned.
- End of Standards -
67
68
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IATA Environmental Assessment

Standards Manual (IESM)

© International Air Transport Association. All

Senior Vice President

IATA Environmental Assessment Standards Manual (IESM)

Step Name Date

Stephen Causby, Manager – IEnvA

Jon Godson, Assistant Director Best

Michael Gill, Director, Aviation

EDITION NUMBER REVISION NUMBER ISSUE DATE EFFECTIVE DATE

Edition 1 0 1 June 2014 1 June 2014

Edition 2 0 1 February 2014 1 February 2014

IESM Ed. 2 Revision Details

Description of Significant Changes

Introduction and Purpose

Background and Basis

Requirements and Guidance

Introduction and Purpose

Background and Basis

Requirements and Guidance

Introduction and Purpose

Background and Basis

Requirements and Guidance

iii) Internal audit,

Introduction and Purpose

Background and Basis

Requirements and Guidance

Introduction and Purpose

Background and Basis

Requirements and Guidance

Introduction and Purpose

Background and Basis

Requirements and Guidance

Document Name Environmental Policy Date of 20-08-13

Document Environmental Policy FINAL

Introduction and Purpose

Background and Basis

Requirements and Guidance

Introduction and Purpose

Background and Basis

Requirements and Guidance

Does the Environmental Aspect of an Operator’s activity have an

This is not yet categorized as

i) Aspects with a high financial implication can be considered significant.

Aspects with a high stakeholder / reputational concern will be considered significant.

Likelihood Guidance Score

Very rare Highly improbable event. Once in every 10 to 25 years 1

Consequence Guidance Score

Insignificant Minor effects on biological or physical environment. There are no lasting 2

Stakeholder Concern / Reputational Concern

Example Airline Scoring Methodology:

Background and Basis

Requirements and Guidance

Step 4: Establishing detailed targets

· Objective: Reduce carbon emissions

· Objective: Improve aircraft noise management

Background and Basis

Requirements and Guidance

· It should be the responsibility of the Environmental Representative or Environmental Team to

Background and Basis

Requirements and Guidance

Step 2: Establishing internal communication channels

Background and Basis