Environmental aspects are basic elements in an Environmental Management System (EMS). The identification of environmental aspects is, however, recognized as one of the most complicated parts in establishing an EMS and has been subject to criticism concerning, e.g., lack of transparency and reproducibility. This paper evaluates the Swedish National Rail Administration's (Banverket) current practice for the identification of environmental aspects. A better link between activity, aspect and impact is needed. A more stringent identification procedure would improve Banverket's environmental management. The paper proposes a structured framework for the identification of environmental aspects at Banverket.