EMP09. Continuous Review

System Revision ID ASEMS Document Version Effective From State
5024 3.6 21/05/2024 - 14:30 Extant

9.1. Summary

9.1.0.1.

Continuous review should ensure that POEMS outputs are kept up to date with overall project and other developments. A review should be part of a planned process of revision as the project progresses in order to incorporate improved or amended information, or as the result of audit findings. This procedure assists the Delivery Team in continuous review and improvements to their projects

9.2. Procedural Overview

9.2.0.1.

Continuous review is the key mechanism that ensures the POEMS remains up to date, relevant and demonstrates continual improvement. 

The POEMS is a continuous management system cycle that is live throughout the lifecycle of the project.

As projects evolve and change, and as new information comes to light, the outputs produced from all EMPs must be reviewed and modified.

9.2.0.2.

This will ensure that POEMS outputs are kept up to date with overall project and other developments.  Reviews can be triggered by a number of factors for example, changes to equipment design or service, a change in a relevant standard, or a change in the customer requirements. A review will also be part of a planned process of the revision of outputs as the project progresses in order to incorporate improved or amended information, or as the result of audit findings.

9.3. Procedure

9.3.0.1.

All EMPs should be applied at all life cycle phases, Concept, Assessment, Demonstration, Manufacture, In-Service and Disposal/Termination (CADMID/T)  for continual improvement.

9.3.0.2.

Most of the outputs from the procedures will require periodic review and possibly modification as the project progresses. When an output (for instance a completed form or report) is produced from following Procedures EMP01 –EMP09, its details should be entered into Form EMP09/F/01 – Review Record.  At this point a date or stage for review of the output should also be entered into Form EMP09F/01.

9.3.0.3.

Wherever possible, periodic reviews of outputs should be organised to coincide with the major stages and hold points of the CADMID/T cycle. This will increase the likelihood that the most complete and up to date information is available for decisions at the hold points.

9.3.0.4.

Reviews shall also be undertaken before major information deliverables are released to stakeholders.

9.3.0.5.

The following list summarises some of the potential triggers for ad hoc reviews of procedure outputs, which could occur at any time in the project’s life:

  1. Change to relevant project stakeholders;
  2. Change to project stakeholders’ requirements or concerns;
  3. Change to the information available from project stakeholders;
  4. Change to planned project activities (in any stage of the project life cycle);
  5. Change to relevant environmental standards;
  6. Change to equipment or service specification;
  7. Change to operational environment or use;
  8. Change in project responsibilities;
  9. Change in information available on the environmental impacts associated with the project, i.e. type, frequency or severity of impact;
  10. Change in impact priority evaluation methodology;
  11. The occurrence of an environmental incident;
  12. Non-achievement of objective and/or target;
  13. The identification of a non-conformance.

9.3.0.6.

Note that any of the above ‘triggers’ may also cause another trigger to apply, for example a change in equipment use or operational domain could cause a change in relevant stakeholders.

9.3.0.7.

Most triggers are unlikely to require an immediate and complete review of the POEMS and outputs. Therefore, in some cases it will be possible to schedule an ad-hoc review to coincide with one of the planned periodic reviews.

9.3.0.8.

However, there will be a small number of strategic changes and triggers which will cause the Delivery Team to instigate an immediate and thorough review irrespective of the overall review plan. In such cases it is probably wise to bring the planned periodic review forward as opposed to duplicating review effort.

9.3.0.9.

Any significant changes to POEMS outputs will require the amendment and re-issuing of the relevant output. For instance, if new or improved information becomes available on certain impacts it may be necessary to carry out a new Assessment, or at least prepare an addendum to the Report produced under Procedure EMP07 - Environmental Reporting. Keeping EMP02 forms up to date in respect of stakeholder contact details and a communication plan will help and greatly simplify the re-issuing process.

9.3.0.10.

As part of any review the implications of changes must be followed through the whole Environmental Management System. So for instance, a change to the Environmental Feature Matrix is likely to necessitate changes to the Environmental Objective and Target Register which will likely cause changes to the Environmental Management Plan.

9.3.0.11.

If a change is identified as required to a procedure output which is also a controlled document then this must be completed and recorded by following GMP04 Document and Record Control

In addition to continual improvement of environmental management processes, EMP09 provides an opportunity for sustainable procurement learning from experience capture and sharing.

It is the communication of this experience that will enable continual improvement for the project and inspire similar acquisition programmes to build upon known success and avoid pit falls.

9.4. Responsibilities

9.4.0.1.

The Senior Environmental Responsible (SER) individual, the Delivery Team Leader (or equivalent), is responsible for ensuring adequate resources are dedicated to environmental management activities within their area of responsibility, and for facilitating appropriate arrangements to successfully exercise and discharge their overarching responsibilities to ensure the product, system or service delivers sound environmental performance.  The responsibility for ensuring the product, system or service delivers sound environmental performance, may be formally delegated in writing to a named, competent individual(s), identified as Environmental Responsible (ER), within the team.

9.4.0.2.

The SER individual, the Delivery Team Leader (or equivalent), is also responsible for facilitating appropriate arrangements to discharge responsibilities relating to this procedure in an efficient and effective manner. Responsibility for ensuring those arrangements are implemented, and achieve outputs which fully satisfy legislative and departmental requirements for environmental management (including compliance with this procedure), may be formally delegated in writing to a named, competent individual(s), identified as ER, within the team.

9.5. Procedure Completion

9.5.0.1.

The Delivery Team is responsible for ensuring that the procedure is completed. However, completion may be carried out by a third-party contractor. Any suggested revisions produced as part of this procedure should be agreed with the Delivery Team and endorsed by the Environmental Committee. 

9.6. When

9.6.1. Initial Application

9.6.1.1.

This procedure applies through life of the project.

9.7. Required Inputs

9.7.0.1.

The ‘Common Documents’

  1. User Requirement Document;
  2. JSP 418 (UK legislation and MOD policy);
  3. DSA01.1 Defence Policy for Health, Safety and Environmental Protection;
  4. Outputs from all preceding EMPs;
  5. When available, outputs from Procedures within Part3 Assurance.

9.8. Required Outputs

9.8.0.1.

Conformance with the standard will be demonstrated by completing the following required outputs:

  1. Completed Form EMP09/F/01 – Continuous Review Record – (plus amended outputs as required).
9.8.1. Records and Project Documentation

9.8.1.1.

This procedure could cause any of the outputs produced from Procedures EMP01 to EMP08 to be viewed and amended:

A copy of the information produced from following this procedure must be stored in the project’s Environmental Case.

9.9. Further Guidance

9.9.0.1.

ISO 14001 and the ISO 14000 series of standards generally, are helpful in understanding how to manage continuous environmental improvement through an Environmental Management System. This concept also underlies all Quality Management Systems and approaches as well as systematic management approaches to Health and Safety risks. Therefore, general guidance on continuous improvement may also be found in standards dealing with any management system approaches.

9.9.1. Aligning Safety and Environment

9.9.1.1.

The key alignment opportunity in EMP09 should be to undertake reviews of safety and environmental records dealing with common issues at the same time, and to ensure that changes introduced by the review process are assessed for both environmental and safety implications.

9.9.2. Guidance for Different Acquisition Strategies

9.9.2.1.

The objectives for this procedure shall apply to all acquisition strategies. It is MOD policy that the same standards are met, and that assurance that these standards have been met shall be demonstrated for all projects.

9.9.3. Legacy Systems

9.9.3.1.

For legacy systems reviews may require greater frequency as the system moves towards disposal phase, or if there are other major changes such as modifications, changes to the operating geography or new legal and policy requirements.

9.9.4. Warnings and Potential Project Risks

9.9.4.1.

If this procedure is not completed in a timely manner there will be an increase in risk that the Environmental Case will not evolve with equipment or service developments and decisions. If the Environmental Case lags too far behind the development of the equipment or service then there are increased risks of the Delivery Team not being suitably prepared for approvals and permissions within the CADMID/T approach. It is also possible that any new or changed environmental liabilities brought about by changes in other project work streams may go unrecognised and therefore be uncontrolled. The consequences of this could be increased cost, however it might also include limitations to operational envelopes and delays for bringing the equipment system or capability into service.

9.10. Version Control

9.10.1. Version 2.3 to 3.0 uplift

9.10.1.1.

Major uplift from the Acquisition System Guidance (ASG) to online version. POEMS has undergone major revision. Refer to the POEMS Transition Document for details.

9.10.2. Version 3.0 to 3.2 uplift

9.10.2.1.

Additional SP content added to para 9.3.0.11 as part of the SP Tool release. 

9.10.3. Version 3.2 to 3.3 Uplift

9.10.3.1.

Minor text changes to align with ASP taxonomy.

9.10.4. Version 3.3 to 3.4 Uplift

9.10.4.1.

Text change replacing Project Team with Delivery Team.

9.10.5. Version 3.4 to 3.5 Uplift

9.10.5.1.

Amended wording to align with S&EP Leaflet 18/2023.

9.10.6. Version 3.5 to 3.6 Uplift

9.10.6.1.

Updated to remove a reference to the obsolete sustainable procurement toolkit.

Subject to Policy Clauses

1.5

Data and Record Format

Data shall be maintained in a format which satisfies the reporting requirements of senior management within DE&S. Auditable records shall be made and kept under review in accordance with relevant legislation.

1.7

Learning From Experience

Operating Centres, Delivery Teams or equivalents shall ensure accidents and incidents are investigated to identify opportunities to reduce the likelihood and impact of recurrence. Lessons learned shall be shared amongst all relevant stakeholders to maximise benefit. Lessons learned (i.e. Audit Reports and LfE Artifacts) shall be shared amongst all relevant stakeholders and stored on the BMS/SharePoint as appropriate.

3.7

Monitoring

Operating Centres, Delivery Teams or equivalents shall establish, implement and maintain a suitable and sufficient procedure to monitor and measure safety and environmental performance of their safety and environmental management system on a regular basis.

3.8

Audit Frequency

Compliance with the documented safety and environmental management system shall be verified via audit at planned intervals according to a published schedule, and as required.

3.9

Internal Audit

At planned intervals commensurate with the risk: i) Operating Centres shall audit their Delivery Teams, or equivalents, safety and environmental management systems. ii) Delivery Teams or equivalents shall audit the safety and environmental management systems of their projects. iii) The DE&S Quality, Safety and Environmental Protection Team or their representative, shall audit the safety and environmental management systems of Operating Centres and Delivery Teams.

3.10

Review

Operating Centres, Delivery Teams or equivalents shall review their safety and environmental management systems, at planned intervals commensurate with the risk, to ensure their continuing suitability, adequacy and effectiveness.

4.8

Accident and Incident Records

Operating Centres, Delivery Teams or equivalent shall monitor and record accidents, incidents and near misses where the performance of their Product, Systems or Services results in harm to individuals or damage to the environment and use this information to keep their risk assessments valid.

4.9

Assessment Approval

Safety and/or environmental case reports shall be personally approved by the individual with formally delegated authority to confirm their acceptance with the progress of the safety and/or environmental case/assessment and of the risks and impacts associated with the project.

4.10

Independent Assurance

Independent review of the Safety and Environmental Management System shall be ensured, as appropriate and commensurate to the risk, by the individual with formally delegated authority for safety and environmental protection. Information/findings arising from independent assurance shall be stored on the BMS/SharePoint as appropriate.

5.2

Change Management

Operating Centres, Delivery Teams or equivalents are to ensure that all new or increased safety risks arising from changes to Products, Systems or Services or to their operating environment are managed appropriately

5.6

Environmental Impact

A proportionate systematic approach shall be utilised to minimise negative environmental impacts and maximise positive impacts so far as is reasonably practicable.

5.7

Non-compliance Reporting

In circumstances where the ability of the Delegation Holder to achieve compliance with the requirements of ASEMS may have been compromised, Operating Centres, Delivery Teams or equivalents shall take immediate steps to correct the situation. Actions required could include improving the clarity of the authority, instructions or responsibilities provided, increasing resources or correcting deficiencies in practices or procedures. Where resolution of the problem lies outside the control of the Delegation Holder, the issue is to be referred through the line management chain. This requirement is to be applied to any further levels of delegation as necessary.

Process Maps

EMP C1
Project Initiation

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EMP A1
Environmental Stages

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EMP DM1
Assess Environmental Stages

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EMP I1
Review Changes - Provide Training

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EMP I3
Plan & Prepare for Service Disposal / Sale

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EMP D1
Selling or Scrapping of Equipment

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Covered by Audit Question Sets

1.5

Audit Question Set Section 1.5 Data and Record Format

The Audit Question Set used as assurance in order to adhere to the policy described in policy clause 1.5.

1.7

Audit Question Set Section 1.7 Learning From Experience

The Audit Question Set used as assurance in order to adhere to the policy described in policy clause 1.7.

3.7

Audit Question Set Section 3.7 Monitoring

The Audit Question Set used as assurance in order to adhere to the policy described in policy clause 3.7.

3.8

Audit Question Set Section 3.8 Audit Frequency

The Audit Question Set used as assurance in order to adhere to the policy described in policy clause 3.8.

3.9

Audit Question Set Section 3.9 Internal Audit

The Audit Question Set used as assurance in order to adhere to the policy described in policy clause 3.9.

3.10

Audit Question Set Section 3.10 Review

The Audit Question Set used as assurance in order to adhere to the policy described in policy clause 3.10.

4.8

Audit Question Set Section 4.8 Accident and Incident Records

The Audit Question Set used as assurance in order to adhere to the policy described in policy clause 4.8.

4.9

Audit Question Set Section 4.9 Assessment Approval

The Audit Question Set used as assurance in order to adhere to the policy described in policy clause 4.9.

4.10

Audit Question Set Section 4.10 Independent Assurance

The Audit Question Set used as assurance in order to adhere to the policy described in policy clause 4.10

5.2

Audit Question Set Section 5.2 Change Management

The Audit Question Set used as assurance in order to adhere to the policy described in policy clause 5.2.

5.6

Audit Question Set Section 5.6 Environmental Impact

The Audit Question Set used as assurance in order to adhere to the policy described in policy clause 5.6.

5.7

Audit Question Set Section 5.7 Non-Compliance Reporting

The Audit Question Set used as assurance in order to adhere to the policy described in policy clause 5.7.