Iso 14001 Significant Aspects Matrix

  1. Iso 14001 Aspects And Impacts
  2. Iso 14001 Environmental Aspects
  3. Iso 14001 Significant Aspects Matrix Examples

Life Cycle Perspective in ISO 14001: 2015 ISO Standard provides a succinct definition of “Life Cycle Assessment” A perspective for assessing the environmental aspects and potential impacts associated with a product including ˃ Compiling an inventory of relative inputs and outputs of a product system. ISO 14001 key requirements that refers to life cycle perspective are: ' 6.1.2 Environmental aspects Within the defined scope of the environmental management system, the organization shall determine the environmental aspects of its activities, products and services that it can control and those that it can influence, and their associated environmental impacts, considering a life cycle perspective. ISO clause: ISO requirements: Organization’s responsibility: Auditor’s responsibility: 4 Context of the organization: The organization shall determine external and internal issues that are relevant to its purpose and that affect its ability to achieve the intended outcomes of its environmental management system. ISO DEFINING RISK RISK = THE EFFECT OF UNCERTAINTY 1. An effect is a deviation from the expected —positive or negative 2. Uncertainty is the state, even partial, of deficiency of information related to understanding or knowledge of an event, its consequence or likelihood 3. As ISO 14001 states, “The organization shall establish a procedure to identify environmental aspects and determine those aspects that have or can have a significant impact on the environment.” You should also keep a register of the environmental aspects, which is kept up to date and takes into account planned new or modified activities, products, or services.

ENVIRONMENTAL RISKS AND OPPORTUNITIES

ISO 14001:2015 Clause 6 Planning ensures the organization has the building blocks in place to determine that the EMS can achieve its intended outcome(s) through the inclusion of specific requirements around risk identification and analysis. This builds on and extends much existing practice related to ISO 14001:2004’s requirements about the identification and evaluation of aspects and impacts. However, even here, the extent of the required working practice changes depends on the nature and extent of existing evaluation techniques. The new ISO 14001 standard are grouped around five key areas: leadership, strategic context, interested party analysis and communication, risks and opportunities and life cycle perspective. These changes are designed to increase corporate resilience and competitive advantage. Risk management is vital for every organization in every sector. It is intrinsic to compliance, reputation, growth, and profitability and its proper handling within the health, safety, and environmental arena can be a major contributor to overall success. Now, organizations not only need to think about the impact they have on the environment and people, but also consider the impact that a changing environment, for example, climate change and resource scarcity, will have on them. In addition, organizations will need to consider other internal and external issues that can help or hinder them having successful management systems. These could be related to the organization’s own internal systems and processes, for example, finance or procurement, or external factors such as government policy and incentives. While on the one hand it can be considered more onerous, this broader approach will help organizations better pinpoint the success (or otherwise) of their management systems and their impact on the business as a whole.

ISO 14001:2015 identifies three possible sources that present risks and opportunities to the business 1) environmental aspects, 2) compliance obligations and 3) issues and requirements from the context review. One of these is the new requirement that the organization determine the risks and opportunities that need to be addressed to give assurance that the environmental management system can achieve its intended outcomes so as to prevent, or reduce, undesired effects, including the potential for environmental external conditions to affect the organization; and achieve continual improvement. These are all laid out with the aim of ensuring the EMS can meet its intended expectations, reducing the risk of any external conditions affecting the EMS, and ensuring continual improvement is seen and that any emergency situations are assessed and action is taken to address them.

Iso 14001 Significant Aspects Matrix
  • Risks may turn into problems. We can reduce or avoid future problems by reducing their consequences or their probabilities. This can be done by changing the way we work to replace a high-risk activity with a low-risk activity and remove the risk if possible. Also, we can add remove the risk by adding risk avoidance activities to the way we work. It is defined by two parameters
    The consequences(C). What will happen if the risk becomes a problem?
    The probability( p). What is the probability that the risk will become a problem?
    The risk(R) is R = C*p
  • Opportunities may turn into benefits. We can increase future benefits by increasing their probabilities. This can be done by changing the way we work i.e replace a low opportunity activity with a high opportunity activity and adding opportunity enabling activities to the way we work. It is defined by two parameters
    The value(V). What will happen if the opportunity becomes a reality?
    The probability(p). What is the probability that the opportunity will be realized?
    The opportunity(O) is O = V*p
  • Both risk and opportunity is defined by probability. Experience and data are important for two reasons. They can be used to estimate values and probabilities. They serve as an anchor for assessment – e.g. “How bad can it get?”. Remember the “opportunity” element and give it due importance. Every risk presents an opportunity to improve and, in effect, if you can mitigate risk before it turns into an incident, then you will guarantee continual improvement for the EMS.
  • Examples of possible risks could be the threat of increasing energy prices due to carbon taxation, making a company uncompetitive – or an organization being noncompliant with legislation which could lead to a loss of custom due to negative publicity. A risk to the success of the management system could be presented from an organization’s own financial processes that do not allow easy investment in emerging technologies.
  • Examples of an opportunity might be an organization capitalizing on energy efficiency measures which cut production costs, leading to an increase in competitiveness – or positive publicity surrounding environmental initiatives which result in new customers. Stakeholder perceptions, financial impact or potential prosecution are all vital and the best systems truly get to the heart of what the business is and what it needs.
  • The standard now requires that documented information shall be kept of the risks and opportunities and the processes required to ensure that the process meets expectations; therefore, it may be good practice to create a formal Risk Register within the EMS where identification, discussion, actions, outcome, and monitoring can all be listed and results clearly evaluated.
  • Ensure there is both leadership commitment and employee involvement. Both parties may well have unique views of what constitutes environmental risk within the business, to ensure both are sought and considered and that the communication channel up and down exists.
  • Consider establishing a “risk and opportunity” forum or monthly meeting. Given that businesses change swiftly, it is important that focus is kept on the environmental risk and the resulting action required to mitigate that risk. Document the outcome as suggested above.
  • Ensure your monitoring, measuring, analysis, and evaluation are accurate and frequent. This process forms the basis for assigning values to the effectiveness of your risk and opportunity process and can provide you with the foundation for improving future performance.

“Risks and opportunities” is defined in ISO 14001:2015 as potential adverse effects (threats) and potential beneficial effects (opportunities). The rationale behind this definition is to have organizations primarily focus their attention on the results related to risk determinations, including both positive and negative effects, rather than simply the uncertainty related to the occurrence of events. The key thing to remember about these new requirements is that not every risk (that is, threat) and opportunity an organization faces is required to be included in this risk determination. First, there must be a nexus, or connection, to the environmental management system. For example, hazardous waste disposal risks would have a nexus to the EMS; credit card fraud risks would not. According to ISO 14001, the organization needs to consider the relationship a particular risk has to:

  • the organization’s important environmental issues that are its “context”.
  • the organization’s EMS requirements, including its compliance obligations
  • the defined scope of the organization’s environmental management system.

This determination of risk (threats and opportunities) is intended to be subjective. It is to be based on the opinions, interpretations, and judgment of those within the organization. It does not have to be an objective determination. It does not have to be based on numbers, calculations, or spreadsheets—although it can be if an organization so chooses. The determination of which risks and opportunities will be addressed in the EMS is the organization’s decision. It is not required to be based on what any particular interested party or management system auditor thinks the decision should be.

Planning process

It is a perspective of construction principles including guidance to processes and, where appropriate, associated design. The content is not exemplar and neither does it attempt to be prescriptive. Construction

The “Planning” clause has two sub-clauses i.e.

  • Clause 6.1 Actions to address risks and opportunities
  • Clause 6.2 Environment Objectives and Planning to Achieve Them

6.1 Actions to address risks and opportunities

6.1.1 General

The organization should establish, implement and maintain the processes needed to meet the requirements of Clause 6.1 (Actions to address risks and opportunities). When planning for the environmental management system, the organization shall consider issues referred to in Understanding the organization and it context (4.1), the requirements referred to in Understanding the needs and expectations of interested parties(4.2) and the scope of its environmental management system; The organization should also determine the risks and opportunities, related to its environmental aspects, compliance obligations, and other issues and requirements,issues referred to in Understanding the organization and it context (4.1), the requirements referred to in Understanding the needs and expectations of interested parties(4.2) so as to assure that the environmental management system can achieve its intended outcomes; It can prevent or reduce undesired effects, including the potential for external environmental conditions to affect the organization and achieve continual improvement. Within the scope of the environmental management system, the organization shall determine potential emergency situations, including those that can have an environmental impact. The organization should maintain documented information about its risks and opportunities that need to be addressed. Documented information is also to be maintained to the extent necessary to have confidence that the process has been carried out as planned.

As per Annex A (Guidance on the use of ISO 14001:2015 standard) of ISO 14001:2015 standard it further explains:

The overall intent of the processes established in 6.1.1 is to ensure that the organization is able to achieve the intended outcomes of its environmental management system, to prevent or reduce undesired effects, and to achieve continual improvement. The organization can ensure this by determining its risks and opportunities that need to be addressed and planning action to address them These risks and opportunities can be related to environmental aspects, compliance obligations, other issues or other needs and expectations of interested parties. Environmental aspects can create risks and opportunities associated with adverse environmental impacts, beneficial environmental impacts, and other effects on the organization. The risks and opportunities related to environmental aspects can be determined as part of the significance evaluation or determined separately. Compliance obligations can create risks and opportunities, such as failing to comply (which can damage the organization’s reputation or result in legal action) or performing beyond its compliance obligations (which can enhance the organization’s reputation). The organization can also have risks and opportunities related to other issues, including environmental conditions or needs and expectations of interested parties, which can affect the organization’s ability to achieve the intended outcomes of its environmental management system, e.g.
a) environmental spillage due to literacy or language barriers among workers who cannot understand local work procedures;
b) increased flooding due to climate change that could affect the organization’s premises;
c) lack of available resources to maintain an effective environmental management system due to economic constraints;
d) introducing new technology financed by governmental grants, which could improve air quality:
e) water scarcity during periods of drought that could affect the organization’s ability to operate its emission control equipment.
Emergency situations are unplanned or unexpected events that need the urgent application of specific competencies, resources or processes to prevent or mitigate their actual or potential consequences. Emergency situations can result in adverse environmental impacts or other effects on the organization. when determining potential emergency situations (e.g. fire, chemical spill, severe weather), the organization should consider:

  • the nature of onsite hazards (e.g. flammable liquids, storage tanks, compressed gasses);
  • the most likely type and scale of an emergency situation;
  • the potential for emergency situations at a nearby facility (e.g. plant, road, railway line).

Although risks and opportunities need to be determined and addressed, there is no requirement for formal risk management or a documented risk management process. it is up to the organization to select the method it will use to determine, its. risks and opportunities. The method may involve a simple qualitative process or a full quantitative assessment depending on the context in which the organization operates. The risks and opportunities identified are inputs for planning actions and for establishing the environmental objectives.

Explanation:

To conform to the ISO 14001 standard, an organization simply needs to be able to show that it considered the nexus factors listed above when it made its EMS risk determinations. Just as the determination of the organization’s context, its aspects, and its compliance obligations are inputs into its determination of risks and opportunities, the determination of risks and opportunities is input into other EMS processes. The requirements in clause 6.1.1 are expressly linked to the additional planning requirements in clause 6.1.4. The planning requirements are then linked to operational control requirements in clause 8.1. Taken together, these clauses require the organization to plan and then take action to address the risks and opportunities that have been identified. In other words, clause 6.1.1 requires a risk determination; clause 6.1.4 requires the development of risk action plans, and clause 8.1 requires that these risk action plans be implemented. ISO 14001:2015 also requires that organizations check whether the management system processes they have established to address risk are effective. Clause 6.1.4 requires the organization to plan how it will evaluate the effectiveness of the actions taken to address risk. Clause 8.1 requires the organization to establish operating criteria for its risk control processes. Clause 9.1.1 requires the organization to monitor, measure, analyze, and evaluate its environmental performance. In summary, the plan-do-check-act (PDCA) focuses on addressing significant aspects that were embedded in ISO 14001:2004 now applies to environmental risks and opportunities as well. Assessing risk and opportunity within an EMS is of crucial importance, with prevention being better than cure in environmental terms, where there is often no way of repairing the damage an incident does after the occurrence. Having a team that is focused on risk and prevention can go a long way towards mitigating environmental risk, but only supported by the correct processes within the EMS. Ensure compliance terms are always met and a great portion of risk will be reduced. Ensure that all risk assessments are recorded, actioned, measured, and improvement action is taken. Make risk and opportunity a staple of the mindset of the team. A team that is focused on risk and opportunity is a team that can preside over continual improvement, and that result will be of benefit to your organization and the EMS.

It’s tempting to want to capitalize on or mitigate all possible opportunities and risks identified, but by doing so the most important will lack the attention they require – a risk assessment process is therefore required. Under ISO 14001: 2015, organizations are free to choose the process used to assess the risks and opportunities that need to be addressed. The standard just requires that there is an approach in place to address risks and opportunities in order to ensure a successful EMS and that the intended outcomes of the EMS are achieved – with unintended effects either avoided or reduced.

6.1.2. Environmental aspects

Within the defined scope of the environmental management system, the organization should determine the environmental aspects and their associated environmental impact of its activities, products, and services that it can control and also those that it can influence. While determining environmental aspects and their associated environmental impact the organization must take into consideration a life cycle perspective.
When determining environmental aspects, the organization should take into account:
a) change, including planned or new developments. and new or modified activities, products, and services;
b) abnormal conditions and reasonably foreseeable emergency situations.
The organization should determine those aspects that have or can have a significant environmental impact, i.e. significant environmental aspects. by using established criteria. The organization shall communicate its significant environmental aspects among the various level and functions of the organization. as appropriate. The organization should maintain documented information of its environmental aspects and associated environmental impacts. The organization also should maintain documented information of the criteria used to determine its significant environmental aspects and
significant environmental aspects. Significant environmental aspects can result in risks and opportunities associated with either adverse environmental impacts (threats) or beneficial environmental impacts (opportunities).

As per Annex A (Guidance on the use of ISO 14001:2015 standard) of ISO 14001:2015 standard it further explains:

Iso 14001 Aspects And Impacts

An organization determines its environmental aspects and associated environmental impacts and determines those that are significant and, therefore, need to be addressed by its environmental management system. Changes to the environment, either adverse or beneficial, that result wholly or partially from environmental aspects are called environmental impacts. The environmental impact can occur at local, regional and global scales, and also can be direct, indirect or cumulative by nature. The relationship between environmental aspects and environmental impacts is one of cause and effect. When determining environmental aspects, the organization considers a life cycle perspective. This does not require a detailed life cycle assessment: thinking carefully about the life cycle stages that can be controlled or influenced by the organization is sufficient. Typical stages of a product (or service) life cycle include raw material acquisition, design. production, transportation/delivery, use, end-of-life treatment, and final disposal. The life cycle stages that are applicable will vary depending on the activity, product or service.
An organization needs to determine the environmental aspects within the scope of its environmental management system. it takes into account the inputs and outputs (both intended and unintended) that are associated with its current and relevant past activities, products and services; planned or new developments; and new or modified activities, products, and services. The method used should consider normal and abnormal operating conditions, shutdown and start-up conditions. as well as the reasonably foreseeable emergency situations identified in 6.1.1. Attention should be paid to prior occurrences of emergency situations. An organization does not have to consider each product, component or raw material individually to determine and evaluate their environmental aspects; it may group or categorize activities, product, and services when they have common characteristics. When determining its environmental aspects, the organization can consider:

  • emissions to air
  • releases to water
  • releases to land
  • use of raw materials and natural resources
  • use of energy
  • the energy emitted e.g. heat, radiation, vibration (noise), light),
  • generation of waste and/or by-products;
  • use of space.

In addition to the environmental aspects that it can control directly, an organization determines whether there are environmental aspects that it can influence. These can be related to products and services used by the organization which is provided by others, as well as products and services used by the organization which is provided by others, including those associated with outsourced processes. With respect to the organization provides to others, it can have limited influence on the use and end-of-life treatment of the products and services. in all circumstances, However, it is the organization that determines the extent of control it is able to exercise, the environmental aspects it can influence, and the extent to which it chooses to exercise such influence. Consideration should be given to environmental aspects. related to the organization’s activities, products, and services, such as:

  • design and development of its facilities, processes, products, and services,
  • acquisition of raw materials, including extraction
  • operational or manufacturing processes, including warehousing
  • operation and maintenance of facilities, organizational assets, and infrastructure
  • environmental performance and practices of external providers,
  • product transportation and service delivery, including packaging,
  • storage, use and end-of-life treatment of products;
  • waste management, including reuse, refurbishing, recycling, and disposal.

There is no single method for determining significant environmental aspects, however, the method and criteria used should provide consistent results. The organization sets the criteria for determining its significant environmental aspects. Environmental criteria are the primary and minimum criteria for assessing environmental aspects. Criteria can relate to the environmental aspect (e.g. type, size, frequency, etc) or the environmental impact (e.g. scale, severity, duration, exposure). Other criteria may also be used. An environmental aspect might not be significant when only considering environmental criteria. It can, however, reach or exceed the threshold for determining significance when other criteria are considered. These other criteria can include organizational issues, such as legal requirements or interested party concerns. These other criteria are not intended to be used to downgrade an aspect that is significantly based on its environmental impact. A significant environmental aspect can result in one or more significant environmental impacts, and can, therefore, result in risks and opportunities that need to be addressed to ensure the organization can achieve the intended outcomes of its environmental management system.

Explanation:

Identification and evaluation of significant environmental aspects, especially in the planning phase, is the most fundamental part of ISO 14001. To understand the environmental aspects and impacts is one of the key success factors of implementing an ISO 14001 EMS. In the language of ISO 14001, “an environmental aspect is an element of an organization’s activities, products, or services that has or may have an impact on the environment.”An environmental aspect is a way your activity, service, or product impacts the environment. The activity can be defined as “A Task or Operation general occurring within the Organization. Environment impact can be defined as “Any change to the environment, whether adverse or beneficial, wholly or partially resulting from an organization’s activities, products, or services.”An environmental impact is a change in the environment. Environmental impacts are caused by environmental aspects. In the following steps, you will find a basic, systematic approach to identifying, evaluating and managing environmental aspects.

1.Definition of the EMS scope

Before you start dealing with environmental aspects and impacts, you should first define the scope of the EMS. You can choose to apply ISO 14001 to the entire organization, or only to a specific unit, location, or product. Once you have made this decision you have defined the EMS scope. Henceforth, all activities, services, and products that fall within your defined scope have to be taken into consideration when you identify environmental aspects and impacts.

2. Identification of environmental aspects

First, let’s explain the terms activity, service, and product. An activity is a part of the core business (e.g., production process steps). Service means an auxiliary service that supports core activities (e.g., boilers, heating & cooling, maintenance). A product is the goods you offer for the market. An environmental aspect of the product could be, e.g., excessive packaging of the product, or level of recyclability of the product at the end of its lifecycle. As ISO 14001 states, “The organization shall establish a procedure to identify environmental aspects and determine those aspects that have or can have a significant impact on the environment.” You should also keep a register of the environmental aspects, which is kept up to date and takes into account planned new or modified activities, products, or services. Aspects can be divided into direct and indirect. Direct environmental aspects are associated with activities, products, and services of the organization itself, over which it has direct management control (e.g., how you manage waste on your site). However, for non-industrial organizations, the focus will often be on indirect environmental aspects of their activities (e.g., how your subcontractor manages waste on your site, chain controlled aspects, customer controlled aspects). In order to identify the environmental aspects, you need to study how your organization’s activities, products, and services affect the environment. The identification of environmental aspects often considers, e.g., emissions to air, releases to water and land, use of raw material, waste, and natural resources, impacts on biodiversity, etc. When identifying environmental aspects, all parts of the company’s operations in the defined scope have to be considered, not just the obvious core manufacturing or service activities. For example, most facilities have a maintenance department, offices, a canteen, heating and cooling systems, vehicle parking, and contractor and supplier activities – each of which may have an impact on the environment. Various techniques can be used to compile a comprehensive listing of environmental aspects and impacts at a facility – e.g., Value chain method, Process flow method, materials identification, method of compliance with legal requirements, etc. A good practice is to involve a cross-functional team from key areas of the operation. For each type of activity, product, or service, you need to list your unique environmental aspect – this will result in an overall list or matrix of aspects and impacts.

3. Evaluation of significant environmental aspects

The purpose of the evaluation of environmental aspects is focusing on what matters the most (e.g., 20-80 rule). You do not need to manage all environmental aspects – only the ones that are, according to your own criteria, declared significant. Significant environmental aspects are the main focus of your organization’s environmental management system. Depending on type, nature, and complexity of an organization, there are many techniques available for conducting an evaluation to determine the significance of environmental aspects. In assessing the significance you should consider potential to cause environmental harm, importance to the stakeholders of the organization, requirements of relevant environmental legislation, size and frequency of the aspect. Each organization must establish its own criteria for significance based on a systematic review of its environmental aspects and their actual and potential impacts.

4. Managing significant environmental aspects

Every significant aspect should be brought under control by establishing one or more of the following controls: responsible person, training plan, or procedure, checklist and/or maintenance schedule. Level of control should be appropriate to the nature and risk of the significant aspect. Each of the above is a part of the everyday work routine. An EMS can often be more complicated than needed. The key to any effective EMS is getting the environmental aspects right at the very beginning. Identifying the environmental aspects properly will not only save you time but also enable you to achieve great benefits with your EMS once it is implemented.

Example of Relation between Activity, aspects, and Impact

ActivityAspectsImpacts
Changing Oil
  • Air Emissions
  • Use of Oil, Absorbents
  • Recycling of Oil
  • Spills
  • Degrade Air Quality
  • Consumption of Natural Resources
  • Increase Landfill Space
  • Degrade Water Quality
Operation of Equipment
  • Dust Generations
  • Air Emissions
  • Use of Raw materials
  • Degradation of Air Quality
  • Degradation of Air Quality
  • Use of Natural resources.
Central Air ConditioningEnergy ConsumptionUse of Natural Resources
LandfillingDisposal Contamination of land
Storm Water ManagementWater Flow Erosion
ExcavationSoil disturbanceErosion
Generation of Solid Waste Land Usage Aesthetics and Community environment
Toilet flushing and Hand Washing Water Usages Use of natural resources
flaring air emissions Air degradation
Processing of composting Water quality Water degradation
Farming Tillage
  • Erosion,
  • sediment Loading

To plan for and control its significant environmental impacts, an organization must first know what these impacts are. But knowing what the impacts are is only part of the challenge, you also should know where these impacts come from. The identification and management of environmental aspects can (1) have positive impacts on the bottom line and (2) provide significant environmental improvements. The relationship between aspects and impacts is one of cause and effect. The term “aspects” is neutral, so keep in mind that your environmental aspects could be either positive such as making a product out of recycled materials or negative such as discharge of toxic materials to a stream. Your organization is not expected to manage issues outside its sphere of influence. For example, while your organization probably has control over how much electricity it uses, it likely does not control the way in which the electricity is generated. Once you have identified the environmental aspects of your products, activities, and services, you should determine which aspects could have significant impacts on the environment. These environmental aspects should be considered when you set your environmental objectives and define your operational controls.

In identifying aspects and impacts, you should look at activities including activities controlled by applicable laws and regulations. But because many of your aspects/impacts may be addressed by legal requirements, your compliance program might yield some valuable information. Permits, audit reports, and other such documents can serve as useful inputs. Beyond regulations, look at issues such as land, energy, and other natural resource use. Once you have identified environmental aspects and related significant impacts, use this information in setting your objectives and targets. This does not mean that you need to address all of your impacts at once. There may be good reasons such as cost, availability of technology, and scientific uncertainty for addressing some impacts now and deferring action on others. Keep in mind that managing environmental aspects could have positive business impacts. Remember to look at services as well as products. While the need to examine your on-site operations might be obvious, you should also consider the potential impacts of what you do off-site such as servicing equipment at customer sites. Similarly, the environmental aspects of the products, vendors, and contractors you use may be less obvious, but should still be considered. Identifying significant environmental aspects is one of the most critical elements of the EMS and can be one of the most challenging. Decisions you make in this task can affect many other system elements such as setting objectives and targets, establishing operational controls and defining monitoring needs. Careful planning and conduct of this activity will pay dividends in later steps.

To understand your environmental aspects, it helps to understand the processes by which you generate products and services. A flow chart of your major processes might help you understand the inputs and outputs of your processes and how materials are used. You may also want to consider the views of interested parties — some organizations have found external parties to be a good resource to help you identify your organization’s environmental aspects. There are many readily-available sources of information to help you perform your assessment. For starters, look at your permits, various regulations that apply to your operations, audit reports, and monitoring records. Trade associations, regulatory agencies, your customers and suppliers also might provide useful information to support your assessment.

Things to Consider in Evaluating Environmental Aspects:

  • Air Emissions
  • Water Effluents
  • Solid and Hazardous Wastes
  • Land Use
  • Contamination of Land Raw Material
  • Resource Use
  • Local Issues Normal and Abnormal Conditions such as noise, odor, dust, traffic, appearance, etc.

6.1.3 Compliance obligations

Matrix

Compliance obligation is a separate article, For more on Compliance obligations click here

6.1.4 Planning action

The organization should plan to take actions to address its significant environmental aspects, compliance obligations, and its identified risks and opportunities. The organization must integrate and implement the actions into its environmental management system processes, or other business processes. The organization evaluates the effectiveness of these actions. While planning these actions, the organization shall consider its technological options and its financials, operational and business requirements.

As per Annex A (Guidance on the use of ISO 14001:2015 standard) of ISO 14001:2015 standard it further explains:

“The organization plans, at a high level, the actions that have to be taken within the environmental management system to address its significant environmental aspects, its compliance obligations, and its identified risks and opportunities identified that are a priority for the organization to achieve the intended outcomes of its environmental management system. The actions planned may include establishing environmental objectives (see 6.2) or may be incorporated into other environmental management system processes, either individually or in combination. Some actions may be addressed through other management systems, such as those related to occupational health and safety or business continuity, or through other business processes related to risk, financial or human resource management. When considering its technological options, an organization should consider the use of best available techniques, where economically viable, cost-effective and judged appropriate. This is not intended to imply that organizations are obliged to use environmental cost-accounting methodologies.”

HOW TO IDENTIFY AND EVALUATE RISKS AND OPPORTUNITIES

Approach to evaluate risk and opportunities:

Option 1: Single path Approach

This process begins by identifying the context of the organization, taking into account environmental conditions and issues (4.1), and needs and expectation of interested parties (4.2) according to the scope of the Environmental Management System (4.3). After this step, the criteria are applied to assess risks and opportunities associated with environmental aspects by considering the likelihood and severity of impacts, environmental conditions and issues, and requirements of interested parties. The results of the risks and opportunities assessments are significant environmental aspects that can be addressed by the organization through actions such as setting an objective and environmental improvement program, operational control, emergency plan or other plans as appropriate.

Option 2: Dual Aspect Approach

After applying the same process of addressing the context of the organization, option 2 uses the criteria to assess “organizational” aspects (aspects of environment interacting with the organization) and environmental aspects (aspects of organization interacting with the environment). From both these processes, a list of significant organizational aspects and significant environmental aspects will be created. From the identified significant “organizational” aspects and environmental aspects, the next process is to assess risks and opportunities that need to be addressed that are relevant to the EMS. These risks and opportunities are then followed up by the organization through actions such as setting an objective and environmental improvement program, operational control, emergency plan or other plans as appropriate as in option 1.

Option 3: Parallel process Approach

Option 3 utilizes information on business risks and opportunities identified through an enterprise risk management system/process. Depending on the organization this process may or may not exist. Business risks and opportunities relevant to EMS are then compiled with significant environmental aspects generated from the process similar to option 1 to determine actions that need to be planned by the organization in the EMS such as setting an objective and environmental improvement program, operational control, emergency plan or other plans as appropriate.

Example: A family-owned company, manufacturing wooden outbuildings for domestic and commercial use. The organization’s purpose is to provide to both retail and bespoke sectional buildings to individuals and organizations. (same example as taken previously from Clause 4.1 Understanding the Organization and its context )

1. Risk /Opportunities for internal Issues

#Issues (Internal)Potential uncertainties (Risk)H/M/L (Risk)Potential uncertainties (Opportunities )H/M/L (Opportunities)
1Transport and site erection costs/ serviceHabitat damage on siteMResource savingsL
2The culture within the Organization /governance and succession issuesFamily differences adversely affect environmental projectsLIncreased personal commitment to long term environmental projectsM
3Opportunities to move from product to service e.g. leasing and maintenance of buildingsAn opportunity not taken up (positive risks not realized)MDecreased use of natural resources/extended product life for the userM
4Relationship with supply chain (timber traceability etc.)Unsustainable timber usedHBigger market/ more sales opportunitiesL
5Potential sustainable material replacement program (products/ packaging)An opportunity not taken up (positive risks not realized)MGreater cooperation/ improved relationships in the supply chainM
6Material consumption (recycled, durable, reusable, recyclable, biodegradable)High waste disposal costs/lack of market growthMCost savings/new product development/market differentiationM
7Energy managementFailure to realize savingsHIncreased savings/less use of finite resourcesH
8Wastage of raw material/waste disposal/developing market for by-productsInefficient planning process leads to high waste levelsHMaterials cost recovery due to sales of wood by-products (sawdust, offcuts, etc.)H

2. Risk /Opportunities for External Issues

#Issues (External)Potential uncertainties (Risk)H/M/L (Risk)Potential uncertainties (Opportunities )H/M/L (Opportunities)
9Political, economic, social, technological, legal and regulatoryChange of government disrupts the economic recoveryLChange of government accelerates economic recoveryM
10Supply chain resilienceChain of custody initiatives reduces the number of potential new suppliersMChain of custody initiative promotes stronger partnershipsM
11Market sensitivity to habitat loss and biodiversity issuesChain of custody not effective; rare hardwoods discovered in storesHTraceability work provides more evidence of well-managed timber habitatsH
12Overall economic performance in the countrySlow market growthMAccelerating market growthM
13Economic plans for futureIncreased interest rates slow capital investment in energy saving plansHCost of servicing loans stays low and increases opportunities to put money into environmental projectsM
14Customer expectationMarket buys on price onlyMMarket willing to pay a higher price for premium/ethical productL
15Standardization and certification within the industryCompetitor get the certificate but do less (loss of differentiation)HSeen as industry sector leaders by being an early adopterH
16Impacts of climate volatilityUncertainty of supply levels/maintenance of raw material costsMMarket opportunity due to resilience and easy repair of productH

3. Risk /Opportunities for Compliance obligations

#Compliance obligationsPotential uncertainties (Risk)H/M/L (Risk)Potential uncertainties (Opportunities )H/M/L (Opportunities)
17Air emission legislationNoncompliance, fineMLess solvent used, cheaper alternatives sourcedL
18Waste legislationNoncompliance, fineM
19Water legislationNoncompliance, fineH
20Pressure groupsForest Standards Council has seen as ‘greenwash’ by pressure groupsHPotential to work with the group to come of up with a better solution/productM
21Neighbors/Local communityThe high number of complaints on noise and odorMThe greater level of understanding about company operations and more local
support for future growth plans on site
M
22ContractorsContractor-related environmental incidents lose customers/incur increased costsMImproved contractor partnerships and shared environmental initiatives help
increase sales
M
23Suppliers (1st, 2nd, and 3rd tier)Competitor get the certificate but do less (loss of differentiation)HSeen as industry sector leaders by being an early adopterM

4. Risk /Opportunities for Significant Aspect

#Significant AspectPotential uncertainties (Risk)H/M/L (Risk)Potential uncertainties (Opportunities )H/M/L (Opportunities)
24Spillage (Potential)Not sure where drainage goesMRemove harmful substance through process redesignL
25Sawing/millingComplaint from neighborMNot know at the time of review
26Water usage (Cooling)Large water footprint/High costHNot know at the time of review
27Timber sourcingChain of custody not established /contribution to biodiversity and habitat lossHMarketing and differentiation opportunity against competitorsH
28Electricity useAre we monitoring energy useHReduced utility costL
29Gas useAre we monitoring energy useMReduced utility costL
30Diesel storageLeak causes contaminated land/watercourseL
31TransportAre we maximizing route planningMMore efficient logistical planning/better use of staff timeM

6.2 Environmental objectives and planning to achieve them

6.2.1 Environmental objectives

The organization should establish environmental objectives at relevant functions and levels, taking into account the organization’s significant environmental aspects and associated compliance obligations and considering its risks and opportunities. The environmental objectives should be consistent with the environmental policy, measurable (if practicable) and monitored. The environmental objectives should be communicated and updated as appropriate. The organization should maintain documented information on environmental objectives.

6.2.2 Planning actions to achieve environmental objectives

When planning how to achieve its environmental objectives, the organization should determine what will be done, what resources will be required, who will be responsible, when it will be completed and how the results will be evaluated, including indicators for monitoring progress toward achievement of its measurable environmental objectives. The organization should consider how actions to achieve its environmental objectives can be integrated into the organization’s business processes.

As per Annex A (Guidance on the use of ISO 14001:2015 standard) of ISO 14001:2015 standard it further explains:

Top management may establish environmental objectives at the strategic level, the tactical level or the operational level. The strategic level includes the highest levels of the organization and the environmental objectives can be applicable to the whole organization. The tactical and operational levels can include environmental objectives for specific units or functions within the organization and should be compatible with its strategic direction. Environmental objectives should be communicated to persons working under the organization’s control who have the ability to influence the achievement of environmental objectives. The requirement to “take into account significant environmental aspects” does not mean that an environmental objective has to be established for each significant environmental aspect, however, these have a high priority when establishing environmental objectives. “Consistent with the environmental policy” means that the environmental objectives are broadly aligned and harmonized with the commitments made by top management in the environmental policy, including the commitment to continual improvement.
Indicators are selected to evaluate the achievement of measurable environmental objectives. “Measurable” means it is possible to use either quantitative or qualitative methods in relation to a specified scale to determine if the environmental objective has been achieved. By specifying “if practicable”, it is acknowledged that there can be situations when it is not feasible to measure an environmental objective, however, it is important that the organization is able to determine whether or not an environmental objective has been achieved.

Explanation:

The Standard requires that the organization shall establish and maintain documented environmental objectives at each relevant functions and levels within the organization. Objectives help you translate purpose into action — they should be factored into your strategic plan and can facilitate the integration of environmental management with other business management processes. Objectives should be the longer-term goals derived naturally from the environmental policy. It should be understood that each identified significant aspect will have an associated objective or objectives in some cases. Quantification can take place through measurement in order to meet such goals. You determine what objectives and targets are appropriate for your organization. These goals can be organization-wide or applied to individual units or activities. Of course, all objectives should be realistic. Objectives should be related to significant environmental impacts and can be couched in fairly broad terms i.e. to reduce energy use. Each objective should have a measurable target to demonstrate that the objective is being attained. Targets are more specific, more easily measurable detailed performance requirements which evolve from the objectives and allow an organization to verify whether the stated objectives will be achieved. Early warning mechanisms for targets not being met should be in place. The process of regular reviews and audits should address this adequately. In setting objectives to consider your environmental policy, significant environmental aspects, from its compliance obligations including applicable legal and other requirements, the views of interested parties, your technological options, and financial, operational, and other business requirements. There are no “standard” environmental objectives that fit all organizations. Your objectives should reflect what your organization does and what it wants to achieve.

Objectives should be set by the people in the functional area involved — they will be best positioned to establish, plan for, and achieve these goals. Involving people in the area will help to build commitment. Objectives should be consistent with your overall business mission and plan and the key commitments established in your policy (pollution prevention, continual improvement, and compliance). Be flexible in your objectives. Define the desired result and let the people responsible determine how to achieve the result. Keep your objectives simple initially, gain some early successes, and then build on them. Communicate objectives (as well as your progress in achieving them) across the organization. Consider a regular report on progress at staff meetings. To obtain the views of interested parties, consider holding an open house or establishing a focus group with people in the community. These activities can have other payoffs as well. Make sure your objectives and targets are realistic. Determine how you will measure progress towards achieving them. Keep in mind that your supplier’s service or materials) can help you in meeting your objectives and targets (e.g., by providing more environmentally friendly products).

Setting of Objectives

Some objectives will be dictated by the requirements of its compliance obligations and therefore are set from outside of the organization. That apart if an organization has identified that solid waste to landfill is a significant impact, what should be the target to aim for to reduce this amount of waste? First and foremost, quantification of what is actually sent to landfill needs to be obtained. As stated above this could probably be obtained from weighbridge tickets, waste transfer notes, and other records. If, from these records, it is discovered that in the previous year 100 tonnes were sent to landfill, how does the organization derive a meaningful figure for reduction? Is 1%, 10% or 50% reduction a reasonable figure? Upon examination of these options, an improvement of 1% is meaningless as far as environmental significance is concerned. It will probably be difficult to measure this ‘amount’ with confidence. There is also the fact that the costs of the controls for this small reduction may outweigh any financial considerations – always an issue in any organization. The improvement of 50% would appear at first glance to be commendable and worthy of environmental attention, however, on closer examination, it is probably somewhat unrealistic. Thus 10% appears to be a starting point and an achievable target – with measurable associated cost savings. If, as the system matures, this proves to be too difficult, then it could be adjusted to 8% or 9% as appropriate. Obviously, only running a production line at 50% capacity, due to poor customer demand, will reduce waste by a roughly corresponding amount. Unless this is taken into consideration in the calculations, errors in the figures will occur.

Some Examples of Objectives

  • Reduce electricity use by 10% Target date March 2016
  • Reduce natural gas use by 10% Target date March 2015
  • Eliminate the use of CFC’s by March 2015
  • Reduce use of high-VOC paints by 25% in 2015
  • Reduce chrome wastes in the plating area by 50% in 2015
  • Zero permit limit violations by March 2015
  • Train 100% of employees to improve employee awareness of environmental issues by end of year

ISO 14001: 2015 – Risks and Opportunities from IEMA on Vimeo.

If you need assistance or have any doubt and need to ask any question contact me at preteshbiswas@gmail.com or call Pretesh Biswas at +919923345531. You can also contribute to this discussion and I shall be happy to publish them. Your comment and suggestion are also welcome.

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ISO 14000 is a family of standards related to environmental management that exists to help organizations (a) minimize how their operations (processes, etc.) negatively affect the environment (i.e., cause adverse changes to air, water, or land) (b) comply with applicable laws, regulations, and other environmentally oriented requirements, and (c) continually improve in the above. ISO 14000 is similar to ISO 9000 quality management in that both pertain to the process of how a product is produced, rather than to the product itself. ISO 14001:2015 sets out the criteria for an Environmental Management System (EMS). It does not state requirements for environmental performance, but maps out a framework that a company or organization can follow to set up an effective EMS. It can be used by any organization that wants to improve resource efficiency, reduce waste, and drive down costs. Using ISO 14001:2015 can provide assurance to company management and employees as well as external stakeholders that environmental impact is being measured and improved. ISO 14001 can also be integrated with other management functions and assists companies in meeting their environmental and economic goals. ISO 14001 is voluntary, with its main aim to assist companies in continually improving their environmental performance, while complying with any applicable legislation. Organizations are responsible for setting their own targets and performance measures, with the standard serving to assist them in meeting objectives and goals and in the subsequent monitoring and measurement of these. The standard can be applied to a variety of levels in the business, from organizational level, right down to the product and service level. Rather than focusing on exact measures and goals of environmental performance, the standard highlights what an organization needs to do to meet these goals. ISO 14001 is known as a generic management system standard, meaning that it is relevant to any organization seeking to improve and manage resources more effectively. This includes:

  • single-site to large multi-national companies
  • high-risk companies to low-risk service organizations
  • manufacturing, process, and the service industries, including local governments
  • all industry sectors including public and private sectors
  • original equipment manufacturers and their suppliers.

Plan Do Check Act Methodology of EMS

  1. Plan–establish objectives and processes required

    Prior to implementing ISO 14001, an initial review or gap analysis of the organization’s processes and products is recommended, to assist in identifying all elements of the current operation and, if possible, future operations, that may interact with the environment, termed “environmental aspects” . Environmental aspects can include both direct, such as those used during manufacturing, and indirect, such as raw materials. This review assists the organization in establishing their environmental objectives, goals, and targets, which should ideally be measurable; helps with the development of control and management procedures and processes; and serves to highlight any relevant legal requirements, which can then be built into the policy .

  2. Do–implement the processes

    During this stage, the organization identifies the resources required and works out those members of the organization responsible for the EMS’ implementation and control . This includes establishing procedures and processes, although only one documented procedure is specified related to operational control. Other procedures are required to foster better management control over elements such as documentation control, emergency preparedness and response, and the education of employees, to ensure that they can competently implement the necessary processes and record results . Communication and participation across all levels of the organization, especially top management, is a vital part of the implementation phase, with the effectiveness of the EMS being dependent on active involvement from all employees.

  3. Check–measure and monitor the processes and report results

    During the ‘check’ stage, performance is monitored and periodically measured to ensure that the organization’s environmental targets and objectives are being met. In addition, internal audits are conducted at planned intervals to ascertain whether the EMS meets the user’s expectations and whether the processes and procedures are being adequately maintained and monitored.

  4. Act–take action to improve performance of EMS based on results

    After the checking stage, a management review is conducted to ensure that the objectives of the EMS are being met, the extent to which they are being met, and that communications are being appropriately managed; and to evaluate changing circumstances, such as legal requirements, in order to make recommendations for further improvement of the system . These recommendations are incorporated through continual improvement: plans are renewed or new plans are made, and the EMS moves forward.
    PDCA cycles at strategic and operational levels

Continual Improvement Process

The core requirement of a continual improvement process (CIP) is different from the one known from quality management systems. CIP in ISO 14001 has three dimensions:

  1. Expansion: More and more business areas get covered by the implemented EMS.
  2. Enrichment: More and more activities, products, processes, emissions, resources, etc. get managed by the implemented EMS.
  3. Upgrading: An improvement of the structural and organizational framework of the EMS, as well as an accumulation of know-how in dealing with business-environmental issues.

Overall, the CIP concept expects the organization to gradually move away from merely operational environmental measures towards a strategic approach on how to deal with environmental challenges.

Concepts of environmental control:

We all have an impact on the environment by the mere act of living from day-to-day. An EMS, in its simplest form, asks us to control our activities so that any environmental impacts are minimized.However unstructured approach may lead us to improve in the wrong direction or, indeed, may leave us without any clear direction at all. It is tempting to control and minimize those impacts we feel we can tackle easily. Our attitude towards environmental issues is influenced by a topical environmental event, and therefore, we can be influenced to act without thoroughly understanding some of the more complex issues. We may focus on, and minimize, environmental impacts which are trivial in nature compared with other impacts which are far more significant and require more considered thought processes. Unless a structured approach is taken the organization may focus on what it believes to be its environmental impacts, a belief based upon ‘gut feel’ and ease of implementation. In reality, this does not address real issues but promotes a ‘green’ feel-good factor or perceived enhancement of image – both internal and external to the organization – which is not justified. For example, a company engaged in the extraction of raw materials by mining may have an environmental objective to save energy. By implementing a ‘save energy by switching off lights’ campaign in its site offices it may feel it has achieved ‘green’ status and may proudly boast of such an environment friendly approach. There will be some energy saved by administration personnel switching off lights and heating when they are not being used for long periods. However, such savings in energy are trivial compared to the massive impact that the mining industry has on the environment: the visible impact of the site and surrounding land, the associated increased noise levels from the operation of such a site, the high use of energy both in extraction technology and transport activities, the use of chemicals in the purification process and of course, the use of non-renewable resources (the raw material that is being mined). Unless the mining company considers the relative scale and significance of environmental impacts, then by claiming to be ‘green’ it has really missed the whole point of environmental control and impact minimization.An organization must move away from this ‘gut feel’ approach to a structured system that demands as a minimum from the organization, an understanding of the concepts behind and strong linkages between:

  • Identifying all environmental aspects of the organization’s activities.
  • Using a logical, objective (rather than subjective) methodology to rank such aspects into order of significant impact upon the environment.
  • Focusing the management system to seek to improve upon and minimize such significant environmental impacts.

Benefits of ISO 14001

ISO 14001 was developed primarily to assist companies with a framework for better management control that can result in reducing their environmental impacts. In addition to improvements in performance, organizations can reap a number of economic benefits including higher conformance with legislative and regulatory requirements by adopting the ISO standard. By minimizing the risk of regulatory and environmental liability fines and improving an organization’s efficiency, benefits can include a reduction in waste, consumption of resources, and operating costs. Secondly, as an internationally recognized standard, businesses operating in multiple locations across the globe can leverage their conformance to ISO 14001, eliminating the need for multiple registrations or certifications. Thirdly, there has been a push in the last decade by consumers for companies to adopt better internal controls, making the incorporation of ISO 14001 a smart approach for the long-term viability of businesses. This can provide them with a competitive advantage against companies that do not adopt the standard ). This in turn can have a positive impact on a company’s asset value. It can lead to improved public perceptions of the business, placing them in a better position to operate in the international marketplace . The use of ISO 14001 can demonstrate an innovative and forward-thinking approach to customers and prospective employees. It can increase a business’s access to new customers and business partners. In some markets it can potentially reduce public liability insurance costs. It can serve to reduce trade barriers between registered businesses. There is growing interest in including certification to ISO 14001 in tenders for public-private partnerships for infrastructure renewal.

Conformity Assessment

ISO 14001 can be used in whole or in part to help an organization (for-profit or not-for-profit) better manage its relationship with the environment. If all the elements of ISO 14001 are incorporated into the management process, the organization may opt to prove that it has achieved full alignment or conformity with the international standard, ISO 14001, by using one of four recognized options. These are:

  1. make a self-determination and self-declaration, or
  2. seek confirmation of its conformance by parties having an interest in the organization, such as customers, or
  3. seek confirmation of its self-declaration by a party external to the organization, or
  4. seek certification/registration of its EMS by an external organization.

ISO does not control conformity assessment; its mandate is to develop and maintain standards. ISO has a neutral policy on conformity assessment. One option is not better than the next. Each option serves different market needs. The adopting organization decides which option is best for them, in conjunction with their market needs.

Option 1 is sometimes incorrectly referred to as “self-certify” or “self-certification”. This is not an acceptable reference under ISO terms and definitions, for it can lead to confusion in the market. The user is responsible for making their own determination. Option 2 is often referred to as a customer or 2nd-party audit, which is an acceptable market term. Option 3 is an independent third-party process by an organization that is based on an engagement activity and delivered by specially trained practitioners. The fourth option, certification, is another independent third-party process, which has been widely implemented by all types of organizations. Certification is also known in some countries as registration. Service providers of certification or registration are accredited by national accreditation services such as NABCB in INDIA or UKAS in the UK.

Structure of ISO 14001:2015

ISO 14001 was revised in 2015 to bring it up to date with the needs of modern businesses and the latest environmental thinking. It’s based on Annex SL, the new high level structure (HLS) which is a common framework for all ISO management systems. This helps keep consistency, align different management system standards, offer matching sub-clauses against the top-level structure and apply common language across all standards. It makes it easier for organizations to incorporate their environmental management system, into core business processes, make efficiencies, and get more involvement from senior management.Perhaps the biggest difference between the old and the new standard is the structure. This is because the new edition uses the new Annex SL template. According to ISO, all future management system standards (MSSs) will use this new layout and share the same basic requirements. As a result, all new MSSs will have the same look and feel.A common structure is possible because basic concepts such as management, requirements, policy, planning, performance, objective, process, control, monitoring, measurement, auditing, decision making, corrective action, and nonconformity are common to all management system standards. A common structure should make it easier for organizations to implement multiple standards because they will all share the same basic language and the same basic requirements.

There have been changes in clause structure and some of the terminology in the new ISO 14001:2015 standard to be in align with other standards such as ISO 9001:2015 and ISO 27001:2013. This, however, does not mean that the organization has to change its organization’s environmental management system documentation. There is no requirement to replace the terms used by an organization with the terms used in the new this international Standard. Organizations can choose to use terms that suit their business, e.g. “records”, “documentation”, or “protocols”, rather than “documented in formation”.

Layout of ISO 14001:2015

1 Scope
2 Normative References
3 Terms and definitions
4 Context of the organization
4.1 Understanding the organization and its context
4.2 Understanding the needs and expectations of interested parties
4.3 Determining the scope of the Environmental management system
4.4 Environmental management system
5 Leadership
5.1 Leadership and commitment
5.2 Environmental policy
5.3 Organizational roles, responsibilities and authorities
6 Planning
6.1 Actions to address risks and opportunities
6.2 Environmental objectives and planning to achieve them
7 Support
7.1 Resources
7.2 Competence
7.3 Awareness
7.4 Communication
7.5 Documented information
8 Operation
8.1 Operational planning and control
8.2 Emergency preparedness and response
9 Performance evaluation
9.1 Monitoring, measurement, analysis and evaluation
9.2 Internal audit
9.3 Management review
10 Improvement
10.1 General
10.2 Nonconformity and corrective action
10.3 Continual improvement

1. Scope

This section explains the scope of the standard – i.e. what it is for and what it encompasses. It introduces the requirements of an environmental management system which supports the fundamental ‘environmental pillar’ of sustainability, together with the key intended outcomes of a management system including:

  • enhancement of performance;
  • conforming to compliance obligations;
  • fulfilment of objectives

This section also makes clear that any organization claiming compliance with the revised standard should have incorporated all requirements of the standard within their environmental management system.

2. Normative references

As with ISO 14001:2004 there are no normative references associated with ISO 14001:2015. The clause is included simply in order to maintain consistent alignment with the ISO High Level Structure (HLS).

3. Terms and definitions

This clause lists the terms and definitions that apply to the standard – these are referenced where necessary back to other ISO 14001 standards (e.g. ISO 14031:2013). The ISO 14001:2015 standard extends the list of terms and definitions from the ISO 14001:2004 standard, combining the mandated HLS terms and definitions together with the more specific terms and definitions associated with environmental management systems.

Some of the core concepts of ISO 14001:2015 are:

Concept
Comment
Context of the organizationThe range of issues that can affect, positively or negatively, the way an organization manages its environmental responsibilities.
IssuesIssues can be internal or external, positive or negative and include environmental conditions that either affect or are affected by the organization.
Interested partiesMuch more detail about considering their needs and expectations, then deciding whether to adopt any of them as compliance obligations.
LeadershipRequirements specific to top management who are defined as a person or group of people who directs and controls an organization at the highest level.
Risk and opportunitiesRefined planning process replaces preventive action. Aspects and impacts now part of risk model
CommunicationThere are explicit and more detailed requirements for both internal and external communications.
Documented InformationReplaces documents and records
Operational planning and controlGenerally more detailed requirements, including a consideration of procurement, design and the communication of environmental requirements ‘consistent with a life cycle perspective’
Performance evaluationCovers the measurement of EMS, operations that can have a significant environmental impact, operational controls, compliance obligations and progress towards objectives.
Nonconformity and corrective actionMore detailed evaluation of both the nonconformities themselves and corrective actions required.

Clarification of concepts

The use of the word “any” implies selection or choice. We cannot interchange the words “appropriate” and “applicable”. are not interchangeable. “Appropriate” means suitable (for. to] and implies some degree of freedom, while “applicable” means relevant or possible to apply and implies that if it can be done, it needs to be done.The word “consider” means it is necessary to think about the topic but it can be excluded; whereas “take into account” means it is necessary to think about the topic but it cannot be excluded. “Continual” indicates duration that occurs over a period of time, but with intervals of interruption (unlike “continuous” which indicates duration without interruption). “Continual” is therefore the appropriate word to use when referring to improvement. The word “effect” is used to describe the result of a change to the organization. The phrase “environmental impact” refers specifically to the result of a change to the environment. The word “ensure” means the responsibility can be delegated, but not the accountability. The term “interested party”; the term “stakeholder” is a synonym as it represents the same concept.

Some new terminology used in ISO 14001:2015 and not available in ISO 14001:2004 are

  1. The phrase “compliance obligations” replaces the phrase “Legal requirements and other requirements at to which the organization subscribes” used in ISO 14001:2004. The intent of this new phrase does not differ from that of the previous edition.
  2. “Documented information” replaces the nouns “documentation”, “documents” and “records” used in ISO 14001:2004 . To distinguish the intent of the generic term “documented information”, ISO 14001:2015 now uses the phrase “retain documented information as evidence of….” to mean records, and “maintain documented information” to mean documentation other than records. The phrase “as evidence of….’’ is not a requirement to meet legal evidentiary requirements; its intent is only to indicate objective evidence needs to be retained.
  3. The phrase “external provider” means an external supplier organization (including a contractor) that provides a product or a service.
  4. The change from “identify” to “determine” is done to harmonize with the standardized management system terminology. The word “determine” implies a discovery process that results in knowledge. The intent does not differ from that of previous editions.
  5. The phrase ‘intended outcome” is what the organization intends to achieve by implementing its environmental management system. This includes enhancement of environmental performance, fulfilment of compliance obligations and achievement of environmental objectives. Organizations can set additional intended outcomes for their environmental management system. For example, consistent with their commitment to protection of the environment, an organization may establish an intended outcome to work towards sustainable development.
  6. The phrase “person[s) doing work under its control” includes persons working for the organization and those working on its behalf for which the organization has responsibility (e.g. contractors). It replaces the phrase “persons working for it or on its behalf” and “persons working for or on behalf of the organization” used in ISO 14001:2004. The intent of this new phrase does not differ from that of the previous edition.
  7. The concept of “Target” used in ISO 14001:2004 in now termed “environment objective”

4. Context of the organization

This is a new clause that establishes the context of the EMS and how the business strategy supports this. ‘Context of the organization’ is the clause that underpins the rest of the standard. It gives an organization the opportunity to identify and understand the factors and parties that can affect, either positively or negatively, the EMS. Unlike the old standard, the new one expects you to understand your organization’s external context and its internal context before you establish its environmental management system (EMS).This means that you need to identify and understand the external issues and the external environmental conditions that could influence your organization’s EMS and the results that it intends to achieve. It also means that you need to identify and understand the internal issues and internal environmental conditions that could influence your EMS and the results in intends to achieve. The new ISO 14001: 2015 standard also expects you to identify the interested parties that are relevant to your EMS and to identify their needs and expectations. Once you’ve done this, it expects you to study these needs and expectations and to figure out which ones have become compliance obligations. But why is all this necessary? It’s necessary because your EMS will need to be able to manage all of these influences. Once you understand your context, you’re expected to use this knowledge to help you define your EMS and the challenges it must deal with.

4.1 Understanding the organization and its context

This clause requires the organization to consider a wide range of potential factors which can impact on the management system, in terms of its structure, scope, implementation and operation. The areas for consideration including;

  1. environmental conditions related to climate, air quality, water quality, land use, existing contamination, natural resource availability and biodiversity, that can either affect the organization’s purpose, or be affected by its environmental aspects;
  2. the external cultural, social, political, legal, regulatory, financial, technological, economic, natural and competitive circumstances, whether international, national, regional or local;
  3. the internal characteristics or conditions of the organization, such as its activities, products and services, strategic direction, culture and capabilities (i.e. people, knowledge, processes, systems).

4.2 Understanding the needs and expectations of interested parties

Clause 4.2 requires the organization to determine the need and expectations of “interested parties”, both internal and external. Interested parties could include;

  • Employees
  • Contractors
  • Clients/Customers
  • Suppliers
  • Regulators
  • Shareholders
  • Neighbours
  • Non-Governmental Organizations (NGOs)
  • Parent organizations

What is clear is that whilst the consideration of context and interested parties needs to be relevant to the scope and the standard, the assessment needs to be appropriate and proportionate.What is also clear is that the output from clauses 4.1 and 4.2 is a key input to the assessment and determination of risks and opportunities required in clause 6. There are various methods and approaches which can be used to capture these inputs. As with any significant revision to standards, hopefully there will be the development of a range of methods and examples for this. Some current examples include;

Internal and External Issues

  • Key economic and market development which can impact an organization. Your organization is probably acutely aware of what is happening in its markets but this may be undertaken in a very ad-hoc way,
  • Technological innovations and developments is also an area critical to your business success and is also probably being monitored and discussed at numerous levels,
  • Regulatory developments – there is a whole range of external regulations being monitored by your organization; if you miss them then it could seriously damage your business, or if you capture early intelligence on them you can more effectively manage any risks,
  • Political and other instabilities – if for example you rely on raw materials from one particular country which experiences major instability, your whole business could be jeopardized; or if there are major environmental concerns regarding a source of materials or goods this could have significant reputational consequences,
  • Organizational culture and attitudes – an effective and motivated workforce will give you positive impacts, and many organizations canvas feedback from employees.

Internal and External Parties

  • Stakeholder engagement exercises are already widely used to consult with interested parties and map out concerns and issues. More often used by larger organizations engaging with corporate social responsibility initiatives,
  • Consultation meetings with neighbourhoods and NGOs on environment, planning and development issues are often used by major industrial plants with significant HSE risks,
  • Meetings and other interactions with regulators can encompass, for example, critical issues on product specifications and conformity from an environmental perspective, as well as issues with regulators on compliance and developing compliance against emerging requirements and standards,
  • Employee meetings, consultations and feedback activities – this should be happening already, but maybe this will prompt more efforts to improve an area which has been at risk of “lip service” to ISO 14001:2004,
  • Supplier reviews and relationship management- many organizations are trying to get much more mutual benefit from the supplier-client relationships which are critical to mutual success.
  • Client/customer reviews and relationship management – of course this is a fundamental pillar of all standards and a key to success.

It may be that when you reflect on how you capture key issues, and how many interested parties you engage with already, you may be pleasantly surprised. It may be that you only engage with a limited number of internal and external parties, but now is the time to start thinking about whether that is enough, and whether you are missing some good opportunities. There will be many ways in which to capture this – and hopefully some improved and new approaches might emerge as this part of the standard is considered. Approaches could include;

  • Summary information from the range of existing approaches used as listed above (e.g. a brief report),
  • Information summarised as part of inputs to risk and opportunity registers (e.g. for ISO 14001 this could be an additional process in the identification of environmental aspects and impacts),
  • Recorded in a simple spreadsheet,
  • Logged and maintained in a database,
  • Captured and recorded through key meetings.

These clauses are asking organizations to think clearly and logically about what can internally and externally affect their management systems, and to be in a position to show that this information is being monitored and reviewed. It also requires organizations to elevate the discussions to the highest levels, since capturing the above range of information is hard to achieve without a high level approach.

4.3 Determining the scope of the environmental management system

This clause should be familiar to most organizations, since ISO 14001:2004 clause 4.1 clearly requires the definition of the scope of the management system. For ISO 14001:2015 the scoping requirements have become clearer, stronger and require the organization to consider the inputs from 4.1 and 4.2, along with the products and services being delivered. This should encourage a clearer and more logical approach to scoping, driven by external and internal requirements – it should not be used to exclude activities, processes or locations which have significant environmental aspects and impacts and should not be used to avoid areas with clear compliance obligations. The scope should be clearly documented and made publicly available. These clearer requirements on scoping will drive clarity in the thinking of organizations in scoping the management system. Certification bodies will, as before, look at how an organization has defined its scope, ensuring that this is both appropriate and is reflected accurately by the management system and also in the scope of any certificate issued.

4.4 Environmental management system

This clause basically states that the organization needs to establish, implement, maintain and continually improve a management system in order to achieve its intended outcomes, including enhancement of environmental performance. This should also be familiar to organizations which implement management systems in order to deliver compliance and improvement. This clause is also more focused in requiring organizations to understand more about the range of processes relevant to the scope of the management system. The term process is defined as; “a set of interrelated or interacting activities which transforms inputs into outputs”.
For those who are committed to a management system which is at the core of your business then this will probably be an integral part of your management system. You may however need to review how effectively you connect those processes and understand the influence and impact of those processes on each other and on the business. This should also elevate the system in terms of its importance and value to the business, because it should drive more meaningful analysis of the key business processes and critical aspects of those processes. In practical terms it will require an organization to more fully analyse its processes and ensure that there is good understanding of how they interact with each other – and not operate as isolated procedures without overlap.
Clause 4 introduces some significant innovations to the management system world, and could represent a challenge to some organizations who have not viewed the management system as essential to the business, focused as it is on raising management systems to a higher level and to be more central to the way an organization works – an approach which is entirely correct and logical.

5 Leadership

This clause is all about the role of “top management” which is the person or group of people who directs and controls the organization at the highest level. The purpose is to demonstrate leadership and commitment by integrating environmental management into business processes. Top management must demonstrate a greater involvement in the management system and need to establish the environmental policy, which can include commitments specific to an organization’s context beyond those directly required, such as the ‘protection of the environment’. There is greater focus on top management to commit to continual improvement of the EMS. Communication is key and top management have a responsibility to ensure the EMS is made available, communicated, maintained and understood by all parties. Finally, top management need to assign relevant responsibilities and authorities, highlighting two particular roles concerning EMS conformance to ISO 14001 and reporting on EMS performance.

5.1 Leadership and commitment

This clause encompasses a range of key activities which top management need in order to “demonstrate leadership and commitment with respect to the management system”. Therein lies one of the innovations delivered by the common HLS – top management must show leadership of the management system rather than just demonstrate commitment to it. The standard is driving the oversight of the management system to the highest level of management and making it a key component of the organization and its core business processes and activities. It doesn’t mean that the leadership has to be able to regurgitate the policy or recite the objectives and targets – what it means is that an internal or external interested party should feel entitled to have a discussion with leadership about core and critical aspects of the business, because these are at the heart of the management system. This sub-clause is a significant innovation to the structure of management systems, but should be viewed as a ‘positive challenge’ to organizations and an opportunity to enhance the role of the environmental management system and place it at the centre of the business.

5.2 Environmental policy

The Environmental Policy is an important document because it acts as the driver for the organization. It provides the direction and formally establishes goals and commitment. Top management should ensure that the policy is appropriate, compatible with the strategic direction and not a bland statement that could apply to any business. It should provide clear direction to allow meaningful objectives to be set that align with it.The new standard focuses on commitment to ”protection of the environment” rather than solely addressing “prevention of pollution” in the 2004-edition. This indicates a broader environmental view and more in line with current and future environmental challenges. Commitments to protect the environment can, in addition to prevention of pollution, also include climate change mitigation and adaptation, sustainable resource use and protection of biodiversity and ecosystems. The policy needs to be communicated to all employees and they need to understand the part they have in its deployment. The policy must be documented and available externally.

5.3 Organizational roles, responsibilities and authorities

For a system to function effectively, those involved need to be fully aware of what their role is. Top management must ensure that key responsibilities and authorities are clearly defined and that everybody involved understands their roles. Defining roles is a function of planning, ensuring awareness can then be achieved through communication and training. It is common for organizations to use job descriptions or procedures to define responsibilities and authorities. In ISO 14001:2015 top management are more directly identified as being responsible for ensuring that these aspects of the system are properly assigned, communicated and understood. The specific role of a Management Representative has been removed – the standard still contains all of the key activities and responsibilities of that previously identified role, but these now lie more directly within the core structure of the organization – including top management. This has a positive implication for the environmental management system- there is a clear expectation for consistent and appropriate ownership from top-to-bottom within an organization.
Clause 5 contains much familiar content, but with greater emphasis on leadership and commitment, and the expectation that top management will be more actively engaged with the management system.

6 Planning

Unlike the old standard, the new ISO 14001 standard expects you to determine risks and opportunities. So what does this mean and what does the new standard expect you to do? It expects you to start by establishing a risk planning process. It then expects you to use this process to identify risks and opportunities related to your organization’s unique context, its interested parties, its compliance obligations, and its environmental aspects. It then expects you to define actions to address all of these risks and opportunities. And to make sure that these actions will actually be carried out, it asks you to make these actions an integral part of your EMS , and then to implement, control, evaluate, and review the effectiveness of these actions and these processes. While risk planning is now an integral part of the new ISO 14001 standard, it does not actually expect you to implement a formal risk management process.

In basic terms, this clause requires the organization to;

  • Consider in planning the EMS the context of the organization and the scope of the system 6.1.1;
  • Determine risk and opportunities relating to environmental aspects 6.1.2, compliance obligations 6.1.3 and other issues and requirements identified in 4.1 and 4.2. (6.1.1);
  • Also consider potential emergency situations which could arise and constitute risk (6.1.1)
  • In addition, and as required already by ISO 14001:2004, determine the range of environmental aspects and
    impacts and determine those impacts which are of significance to the organization within the defined scope (6.1.2);
  • Consider all compliance obligations applicable to the organization and how these may present threats or opportunities (6.1.3);
  • The organization then needs to consider appropriate actions to address the significant aspects/impacts (6.1.2), compliance obligations (6.1.3) and risks and opportunities identified (6.1.1).

Risks and Opportunities

The ISO 14001 standard also introduces the concept of “considering a life cycle perspective” for its products, services and activities. This makes the previous concepts of the upstream and downstream aspects clearer, and also introduces language now in common use across other standards as well as Corporate Social Responsibility (CSR) and product assessment standards. The overall strength of this clause lies in both introducing the principles of risk and opportunity to management systems standards via the HLS, and by connecting it very clearly to the processes defined under Clause 4. A well-established approach to managing this range of inputs, risk analysis and prioritisation already implemented by many organizations is the use of risk registers, which if properly managed and implemented can effectively identify and assess risks and opportunities across a wide range of areas and issues. There will also be other approaches which result from the various relevant clauses
of 14001 (e.g. the results from clause 4.1 and 4.2 and the requirements of 6.1.1, 6.1.2, 6.1.3 and 6.1.4) along with management of change, with an overall analysis and review resulting in objectives, targets and plans. The depth and complexity of approach will depend significantly on the size and complexity of the organization, as well as other factors which could include level of external regulation, existing requirements for public reporting, shareholder interests, public profile, numbers and types of customers, range and types of suppliers. Hence there will be a range of approaches that will be appropriate for the wide spectrum of organizations.

6.2 Environmental objectives and planning to achieve them

This clause requires the organization to establish environmental objectives and plans, ensuring that these are clear, measurable, monitored, communicated, updated and resourced. As part of the planning process, top management needs to set environmental objectives driven by the outputs from the analysis of risks arising from threats and opportunities (i.e. the range of activities undertaken in 6.1), with the aim of delivering compliance, performance improvement and effective risk management. Objectives should be consistent with the Environmental Policy and be capable of being measured. Documented information needs to kept in relation to objectives and there will need to be evidence regarding monitoring of achievement.

Preventive action
The new ISO 14001 standard no longer uses the term preventive action. We’re now expected to use risk planning concepts and to think of the entire EMS as a system of preventive action. ISO 14001 2015 section A.10.1 says there is no longer a single clause on preventive action because “One of the key purposes of an environmental management system is to act as a preventive tool. This concept of preventive action is now captured in 4.1 (i.e., understanding the organization and its context) and 6.1 (i.e., actions to address risks and opportunities).” So, according to the new standard, these two sets of requirements cover the old concept of preventive action. Evidently, once we realize that the entire EMS can be used to manage risks and opportunities, we no longer need a separate clause on preventive action. It’s redundant.

7 Support

This clause is all about the execution of the plans and processes that enable an organization to meet their EMS. Simply expressed, this is a very powerful requirement covering all EMS resource needs. Organizations will need to determine the necessary competence of people doing work that, under its control, affects its environmental performance, its ability to fulfil its compliance obligations and ensure they receive the appropriate training. In addition, organizations need to ensure that all people doing work under the organization’s control are aware of the environmental policy, how their work may impact this and implications of not conforming with the EMS. Finally, there are the requirements for ‘documented information’ which relate to the creation, updating and control of specific data.

7.1 Resources

The main intention behind this general requirement is that the organization must determine and provide the resources needed for the establishment, implementation, maintenance and continual improvement of the environmental management- covering all aspects of people and infrastructure. Whilst not contained in the ISO 14001 standard, the ISO 9001 standards contains a very interesting additional requirement termed “organizational knowledge”, which relates to ensuring that the organization understands internal and external knowledge needs and can demonstrate how this is managed. This could also include knowledge management of resources, and ensuring that there is effective succession planning for personnel, and processes for capturing individual and group knowledge. It isn’t a documented requirement of ISO 14001 but it is relevant and useful as a general principle.

In order to determine competence, competence criteria needs to be established for each function and role relevant to the environmental management system. This can then be used to assess existing competence and determine future needs. Where criteria are not met, some action is required to fill the gap.Training or reassignment may even be necessary. Retained documented information is required to be able to demonstrate competence. Recruitment and induction programmes, training plans, skills tests and staff appraisals often provide evidence of competence and their assessment. Competency requirements are often included in recruitment notices and job descriptions. The standard is clear that documented information is required as evidence of competence.

7.3 Awareness

Personnel need to be made aware of the environmental policy, significant aspects and impacts of relevance to their activities, how they contribute to the environmental objectives, environmental performance and compliance obligations, and the implications of failures in compliance.

7.4 Communication

Effective communication is essential for a management system. Top management need to ensure that mechanisms are in place to facilitate this. It should be recognised that communication is two-way and will not only need to cover what is required, but also what was achieved. With ISO 14001:2015 the importance of internal communications and external communications are emphasized. This is a natural legacy of the existing ISO 14001:2004 and the importance of interested parties in environment issues. This sub clause also makes very clear the importance of ensuring in relation to environmental reporting and associated communications that the organization shall “ensure that environmental information communicated is consistent with information generated within the environmental management system, and is reliable”. This is an excellent addition and consistent with other corporate reporting standards. It also emphasizes the need to plan and implement a process for communications along the familiar ‘who, what, when how’ principles.

7.5 Documented information

The new ISO 14001 2015 standard has also eliminated the long standing distinction between documents and records. Now they’re both referred to as “documented information”. Why ISO chose to abandon two common sense concepts and replace them with one that is needlessly awkward and esoteric is not entirely clear. According to ISO’s definition, the term documented information refers to information that must be controlled and maintained. So, whenever ISO 14001 2015 uses the term documented information it implicitly expects you to control and maintain that information and its supporting medium. However, this isn’t the whole story. An annex to the new ISO 14001 2015 standard (A.3) further says that “this international standard now uses the phrase ‘retain documented information as evidence of’ to mean records, and ‘maintain documented information’ to mean documentation other than records.” So, whenever the new ISO 14001 standard refers to documented information and it asks you to maintain this information, it is talking about what used to be referred to as documents, and whenever it asks you to retain this information, it is talking about what used to be called records. So sometimes documented information must be maintained and sometimes it must be retained (contrary to what ISO’s official definition says). So, while the official definition of the term documented information abandons the distinction between documents and records, through the use of the words “maintain” and “retain” and because of what this means (according to Annex A), the main body of the standard actually restores this distinction. In other words, while documents and records were officially kicked out the front door, they were actually allowed back in through the back door.
Procedures
The old ISO 14001 standard asked organizations to establish a wide range of procedures. These included an environmental aspects procedure, a legal requirements management procedure, an awareness procedure, a communications procedure, a documents procedure, an operational procedure, an emergency preparedness and response procedure, a monitoring and measurement procedure, a compliance evaluation procedure, a nonconformity management procedure, a record keeping procedure, and an audit procedure. Now, only one procedure is left. The new ISO 14001 2015 standard asks you to establish an emergency preparedness and response procedure in section 8.2, and that’s the only one. Instead of asking you to write procedures, the new standard expects you to maintain and control a wide range of documents (i.e., documented information). Since the new standard doesn’t tell you what to call these documents, you can call them procedures if you like. And, of course, you still need to have documents except that now they’re called “documented information”. So, while on the surface this looks like a radical change, it probably isn’t.

Mandatory documents and records required by ISO 14001:2015

Here are the documents you need to produce if you want to be compliant with ISO 14001:

  • Scope of the EMS (clause 4.3)
  • Environmental policy (clause 5.2)
  • Risk and opportunities to be addressed and processes needed (clause 6.1.1)
  • Criteria for evaluation of significant environmental aspects (clause 6.1.2)
  • Environmental aspects with associated environmental impacts (clause 6.1.2)
  • Significant environmental aspects (clause 6.1.2)
  • Environmental objectives and plans for achieving them (clause 6.2) Operational control (clause 8.1)
  • Emergency preparedness and response (clause 8.2)

And, here are the mandatory records:

  • Compliance obligations record (clause 6.1.3)
  • Records of training, skills, experience and qualifications (clause 7.2)
  • Evidence of communication (clause 7.4)
  • Monitoring and measurement results (clause 9.1.1)
  • Internal audit program (clause 9.2)
  • Results of internal audits (clause 9.2)
  • Results of the management review (clause 9.3)
  • Results of corrective actions (clause 10.1)

Non-mandatory documents

There are numerous non-mandatory documents that can be used for ISO 14001 implementation. However, I find these non-mandatory documents to be most commonly used:

  • Procedure for determining context of the organization and interested parties (clauses 4.1 and 4.2)
  • Procedure for identification and evaluation of environmental aspects and risks (clauses 6.1.1 and 6.1.2)
  • Competence, training and awareness procedure (clauses 7.2 and 7.3)
  • Procedure for communication (clause 7.4)
  • Procedure for document and record control (clause 7.5)
  • Procedure for internal audit (clause 9.2)
  • Procedure for management review (clause 9.3)
  • Procedure for management of nonconformities and corrective actions (clause 10.2)

8 Operation

This clause deals with the execution of the plans and processes that enable the organization to meet their environmental objectives. There are specific requirements that relate to the control or influence exercised over outsourced processes and the requirement to consider certain operational aspects ‘consistent with a life cycle perspective’. This means giving serious consideration to how actual or potential environmental impacts happening upstream and downstream of an organization’s site-based operations are influenced or (where possible) controlled. Finally, the clause also covers the procurement of products and services, as well as controls to ensure that environmental requirements relating to design, delivery, use and end-of-life treatment of an organization’s products and services are considered at an appropriate stage.

8.1 Operational planning and control

The overall purpose of operational planning and control is to ensure that processes are in place to meet the environmental management system requirements and to implement actions identified in 6.1 and 6.2. There are some clearer and stronger requirements relating to outsourced processes and control of changes. In addition, requirements around the life cycle perspective approach are defined in more detail, covering the key elements of:

  • Environmental requirements for procurement of products and services
  • Establishing controls to ensure environmental requirements are addressed in the design and development phase
  • Communicating environmental requirements to providers (including suppliers, contractors and others)
  • Providing key environmental information on products and services in the context of the life cycle (e.g. end-of life information).

The organization needs to determine and evaluate the level of control and influence over the different life cycle elements, based on the context of the organization and the consideration of significant environmental aspects, compliance obligations and risks associated with threats and opportunities. Overall ISO 14001:2015 requires a structured approach to all aspects of the products and services with a strong reference point to life cycle perspective. As discussed under Clause 7.5, there is no specific requirement for documented procedures in ISO 14001:2015, but there is a clear requirement for ensuring that there is documented information to provide assurance that the processes are in place and implemented effectively. That requirement could cover process maps, procedures, specifications, forms, records, data and other information across any media.

8.2 Emergency Preparedness and Response

This clause is clear in requiring the organisation to establish, implement and maintain processes needed to handle potential emergency situations identified in 6.1.1. The more detailed requirements cover the need to ensure:

  • That the organization plans actions to mitigate or prevent environmental consequences;
  • The organization responds to actual emergency situations;
  • Takes action to prevent or mitigate the consequences of emergency situation;
  • Periodic testing of any procedures, plans and response mechanisms;
  • Periodic reviews and updates of procedures and plans based on experience;
  • Provision of relevant information and training to relevant interested parties.

9 Performance Evaluation

This is all about measuring and evaluating your EMS to ensure that it is effective and it helps you to continually improve. You will need to consider what should be measured, the methods employed and when data should be analysed and reported on. As a general recommendation, organizations should determine what information they need to evaluate environmental performance and effectiveness. Internal audits will need to be carried out, and there are certain “audit criteria” that are defined to ensure that the results of these audits are reported to relevant management. Finally, management reviews will need to be carried out and “documented information” must be kept as evidence.

9.1 Monitoring, measurement, analysis and evaluation

This sub-clause encompasses two key areas:

  • Monitoring, measurement, analysis and evaluation of environmental performance and the effectiveness of the system;
  • Evaluation of compliance with all legal and other obligations.

The range of monitoring and measurement required needs to be determined for those processes and activities which relate to significant environmental aspects/impacts, environmental objectives, key areas of operational control and processes, and also for evaluating the meeting of compliance obligations. For the monitoring and measurement determined as required, the organization also needs to determine key criteria and requirements, including:

  • Methods for monitoring, measurement, analysis and evaluation;
  • Key performance indicators and performance evaluation metrics;
  • When, where, how and by whom the monitoring, measurement, evaluation and analysis is carried out;
  • Specification, management and maintenance of key monitoring equipment and data handling processes.

The output from these activities provide key inputs for a range of other elements of the environmental management system, including management review, and in determining the internal and external communications required on the environmental management system and its performance.
The other key aspect of this sub-clause is the organization will need to demonstrate how it evaluates compliance with other requirements. Most organizations fulfil this clause via their internal audit processes, but other compliance audits, checks and reviews can be used. The organization should define its processes for evaluating compliance with legal and other requirements and must maintain documented information relating to these activities. The process must cover:

  • Frequency of evaluation
  • Evaluation approach
  • Maintain knowledge on compliance status

This area is similar to the requirements under ISO 14001:2004, but with clearer and more detailed requirements. As with ISO 14001:2004, this is not about reviewing which compliance obligations are applicable to the organization, it is about evaluating actual compliance with the range of compliance obligations applicable to the organization.

Relationship of elements of ISO 14001:2015 standard relevant for compliance management.

9.2 Internal audit

Internal audits have always been a key element of ISO 14001 in helping to assess the effectiveness of the environmental management system. An audit programme needs to be established to ensure that all processes are audited at the required frequency, the focus being on those most critical to the business. To ensure that internal audits are consistent and thorough, a clear objective and scope should be defined for each audit. This will also assist with auditor selection to ensure objectivity and impartiality. To get the best results, auditors should have a working knowledge of what is to be audited, but management must act on audit results. This is often limited to corrective action relating to any nonconformities that are found, but there also needs to be consideration of underlying causes and more extensive actions to mitigate or eliminate risk. Follow up activities should be performed to ensure that the action taken as a result of an audit is effective. This clause is largely the same as ISO 14001:2004.

9.3 Management review

The main aim of management review is to ensure the continuing suitability, adequacy and effectiveness of the quality management system. Only through conducting the review at sufficient intervals (remember, management review does not have to be just one meeting, held once per year), providing adequate information and ensuring the right people are involved can this aim be achieved. The standard details the minimum inputs to the review process. Top management should also use the review as an opportunity to identify improvements that can be made and/or any changes required, including the resources needed. The input to management review should include information on;

  • Status of previous actions from management reviews;
  • Changes in internal/external inputs, significant aspects/impacts and compliance obligations;
  • Achievement and progress on environmental objectives;
  • Information on environmental performance;
  • Communications from external interested parties;
  • Opportunities for continual improvement;
  • Adequacy of resources for the environmental management system.

The output from the management review should include any decisions and actions related to;

  • Conclusions on the suitability, adequacy and effectiveness of the system;
  • Continual improvement opportunities,
  • Changes to the environmental management system, including resources;
  • Actions relating to objectives not achieved;
  • Implications for the strategic direction of the organization.

Documented information pertaining to the management review is required to be retained.
This clause is largely the same as ISO 14001:2004, but with some broader topics and alignment with the new language of risks and opportunities, and the context of the organization.

10 Improvement

Iso 14001 Environmental Aspects

This clause requires organizations to determine and identify opportunities for continual improvement of the EMS. The requirement for continual improvement has been extended to ensure that the suitability and adequacy of the EMS—as well as its effectiveness—are considered in the light of enhanced environmental performance. There are some actions that are required that cover handling of corrective actions. Firstly organizations need to react to the nonconformities and take action. Secondly they need to identify whether similar nonconformities exist or could potentially occur.This clause requires organizations to determine and identify opportunities for continual improvement of the EMS. There is a requirement to actively look out for opportunities to improve processes, products or services; particularly with future customer requirements in mind.

10.1 General

This states that the organization shall determine opportunities for improvement and implement necessary actions to achieve intended outcomes.

10.2 Nonconformity and corrective action

The main aim of the corrective action process is to eliminate the causes of actual problems so as to avoid recurrence of those problems. It is a reactive process, in that it is triggered after an undesired event (e.g. a pollution event). In essence, the process uses the principles of root cause analysis. A basic approach to problem solving is “cause” and “effect”, and it is the cause that needs to be eliminated. Action taken should be appropriate and proportionate to the impact of the nonconformity. As part of the corrective action process, the effectiveness of action taken must be checked to ensure it is effective. For this clause on nonconformity and corrective action, much of the content is familiar and similar to ISO 14001:2004 but the term “preventive action” has now been completely deleted from the standard. This is because the new HLS is built on the fundamental principles of risk management, which embodies the need to identify risk and manage those risks, with the ultimate goal of risk elimination. The overall approach is one of mitigating and where possible eliminating risk, with the use of corrective action to deal with the impacts of realised risks.

10.3 Continual improvement

This sub-clause of ISO 14001:2015 effectively summarises the key aim of an environmental management system: to continually improve the suitability, adequacy and effectiveness of the environmental management system to enhance environmental performance. This was also embodied in ISO 14001:2004 but is separately stated in ISO 14001:2015. Improvement does not have to take place in all areas of the business at the same time. Focus should be relevant to risks and benefits. Improvement can be incremental (small changes) or breakthrough (new technology). In reality both methods will be used at some point in time.

Other clarifications and modifications

The old ISO 14001 standard asked you to “define and document the scope of its environmental management system” (4.1), but it didn’t say anything about how this should be done. The new ISO standard clarifies how this ought to be done (4.3). It now asks you to consider your compliance obligations, your corporate context, your physical boundaries, your products and services, your activities and functions, and your authorities and abilities when you define the scope of your EMS. And it asks you to include all products, services, and activities that have significant environmental aspects. The new term “compliance obligation” has replaced the rather cumbersome phrase: “legal requirements and other requirements to which the organization subscribes”. However, the meaning is the same. There are two kinds of compliance obligations: mandatory compliance obligations and voluntary compliance obligations. Mandatory compliance obligations include laws and regulations while voluntary compliance obligations include contractual commitments, community and industry standards, ethical codes of conduct, and good governance guidelines. A voluntary obligation becomes mandatory once you decide to comply with it. The new standard no longer refers to environmental targets. According to section A.6.2, “The concept of “target” used in prior editions of this International Standard is captured within the definition of “environmental objective”. You can, of course, still set targets and call them targets if you wish. The only real difference is that the new ISO 14001 standard thinks of a target as a type of objective.

Management of change is an important part of maintaining the environmental management system that ensures the organization can achieve the intended outcomes of its environmental management system on an ongoing basis. Management of change is addressed in various requirements in ISO 14001:2015 Standard, such as

  • maintaining the environmental management system (4.4);
  • environmental aspects (6.1.2);
  • internal communication (7.4.2);
  • operational control ( 8.1);
  • internal audit programme (9.2.2) and
  • management review(9.3).

As part of managing change, the organization should address planned and unplanned changes to ensure that the unintended consequences of these changes do not have a negative effect on the intended outcomes of the environmental management system. Examples of change include:

  • planned changes to products, processes, operations, equipment or facilities;
  • changes in staff or external providers, including contractors;
  • new information related to environmental aspects, environmental impacts and related technologies;
  • changes in compliance obligations.

ISO 14001:2015 has introduced the requirement for a “life cycle perspective” in environmental management systems (EMS). The new standard does not require a formal life cycle analysis, or quantification, but does require organisations to look upstream and downstream of the processes performed on-site and try to reduce environmental impacts. Specifically, the life cycle perspective is related to the organisation’s environmental aspects and impacts. It requires careful consideration of the life cycle stages that the organisation can control or influence, including acquisition of raw materials, production and transportation, use and maintenance, and recycling or disposal. In doing this, the organisation needs to create records as evidence that they have considered each lifecycle stage. The standard also requires the organisation to provide information to its external service providers and contractors about the potentially significant environmental impacts of its products and services. It must also consider the need to provide this information to transporters, end-users and disposal facilities. By providing this information, the organisation can potentially prevent or mitigate adverse environmental impacts during these life cycle stages.

The life cycle perspective can be applied in choosing, for example:

  • raw materials (environmental impacts of their production, distance transported and mode of transport)
  • products to manufacture and offer for sale (same considerations as well as disposal or recycling options at end-of-life)
  • services used by organisation (environmental credentials, chemicals used, waste generated)
  • equipment purchases (distance transported, options for recycling at end-of-life, waste generated in their use).

Why has this life cycle requirement been added to the standard? The introduction to the new standard explains that a life cycle perspective can be used to benefit the environment in areas where the organisation has “control or influence” and also “prevents environmental impacts from being unintentionally shifted elsewhere within the life cycle”. Life cycle considerations were largely ignored by the old standard. Now they’re central. ISO 14001 now expects you to use a life cycle perspective to “identify the environmental aspects and associated environmental impacts of its activities, products and services that it can control and those that it can influence”. The term “management representative” has been officially dropped. The management duties and responsibilities that were previously assigned to someone called a “management representative” may now be assigned either to one person or to many. Of course, you may continue to use this job title if you wish.

Mapping ISO 14001:2015 and ISO 14001:2004

Iso 14001 Significant Aspects Matrix Examples

ISO 14001:2015
ISO 14001:2004

Clause number

Clause titleClause number

Clause title

0Introduction0Introduction
1Scope1Scope
2Normative references2Normative references
3Terms and definitions3Terms and definitions
4Context of the organization (title only)4Environmental management system requirements (title only)
4.1Understanding the organization and its context
4.2Understanding the needs and expectations of interested parties
4.3Determining the scope of the environmental management system4.1General requirements
4.4Environmental management system4.1General requirements
5Leadership (title only)
5.1Leadership and commitment
5.2Environmental policy4.2Environmental policy
5.3Organizational roles, responsibilities and authorities4.4.1Resources, roles, responsibility and authority
6Planning (title only)4.3Planning (title only)
6.1Actions to address risks and opportunities (title only)
6.1.1General
6.1.2Environmental aspects4.3.1Environmental aspects
6.1.3Compliance obligations4.3.2Legal and other requirements
6.1.4Planning action
6.2Environmental objectives and planning to achieve them (title only)4.3.3Objectives, targets and programme(s)
6.2.1Environmental objectives
6.2.2Planning actions to achieve environmental objectives
7Support (title only)4.4Implementation and operation (title only)
7.1Resources4.4.1Resources, roles, responsibility and authority
7.2Competence4.4.2Competence, training and awareness
7.3Awareness
7.4Communication (title only)4.4.3Communication
7.4.1General
7.4.2Internal communication
7.4.3External communication
7.5Documented information (title only)4.4.4Documentation
7.5.1General
7.5.2Creating and updating4.4.5Control of documents
4.5.4Control of records
7.5.3Control of documented information4.4.5Control of documents
4.5.4Control of records
8Operation (title only)4.4Implementation and operation (title only)
8.1Operational planning and control4.4.6Operational control
8.2Emergency preparedness and response4.4.7Emergency preparedness and response
9Performance evaluation (title only)4.5Checking (title only)
9.1Monitoring, measurement, analysis and evaluation (title only)4.5.1Monitoring and measurement
9.1.1General
9.1.2Evaluation of compliance4.5.2Evaluation of compliance
9.2Internal audit (title only)4.5.5Internal audit
9.2.1General
9.2.2Internal audit programme
9.3Management review4.6Management review
10Improvement (title only)
10.1General
10.2Nonconformity and corrective action4.5.3Nonconformity, corrective action and preventive action
10.3Continual improvement

Guidance Matrix

ISO 14001:2015 clause
ISO 14001:2015 requirements
Organization’s responsibility
Auditor’s responsibility
4 Context of the organizationThe organization shall determine external and internal issues that are relevant to its purpose and that affect its ability to achieve the intended outcomes of its environmental management system. Such issues shall include environmental conditions being affected by or capable of affecting the organization.Evaluate their position with respect to trade associations, customer requirements, Climate change agreements, compliance schemes. Local issues with air quality for example, Sensitive receptors nearby e.g. Godavari riverSee evidence that an evaluation has been carried out on their current issues
4.1 Understanding the organization and its context

The organization shall determine:

  1. the interested parties that are relevant to the environmental management system;
  2. the relevant needs and expectations (i.e. requirements) of these interested parties;
  3. which of these needs and expectations become its compliance obligations.
This is not a new requirement but is now more explicit -stakeholder concerns. A stakeholder could be a packaging waste compliance scheme how does the company ensure their obligations fulfilled in the collection of data (and indeed its accuracy)Auditors must check there is evidence that the company have evaluated what are the needs of interested parties particularly important are where there are legal obligations such as the submission of data to the Environment Agency for Pollution prevention and control(PPC)
4.2 Understanding the needs and expectations of interested partiesThe organization shall determine the boundaries and applicability of the environmental management system to establish its scope.
When determining this scope, the organization shall consider:
a) the external and internal issues referred to in 4.1;
b) the compliance obligations referred to in 4.2;
c) its organizational unit(s), function(s), and physical boundaries;
d) its activities, products and services;
e) its authority and ability to exercise control and influence
Again not new but better defined;
Make sure you have a site plan
External issues may be movement of goods, Impact on local community noise nuisance
That processes are understood in manufacture and the effect on emissions discharges (internal issues)
Compliance: Pollution prevention and control (PPC) department permit conditions for example
Activities-processes again
Products-life cycle issues see later
Upstream and downstream influence e.g. customers and suppliers
The auditor should check the scope of activity covers things like permit conditions for a site eg for a waste management licence
It should cover buildings such as on an industrial estate the unit numbers it applies to.
If the company has delivery on its scope then it should cover its logistics operation.
Please note this scope is NOT the scope that appears on the ISO 14001 certificate but is the scope of controls to be covered under the documented ems
4.3 Determining the scope of the environmental management systemThe organization shall determine the boundaries and applicability of the environmental management system to establish its scope.
When determining this scope, the organization shall consider:
a) the external and internal issues referred to in 4.1;
b) the compliance obligations referred to in 4.2;
c) its organizational unit(s), function(s), and physical boundaries;
d) its activities, products and services;
e) its authority and ability to exercise control and influence
Once the scope is defined, all activities, products and services of the organization within that scope need to be included in the environmental management system.
The scope shall be maintained as documented information and be available to interested parties
Scope now should be determined usually in a top tier policy document or in preparatory environmental review (PER)
See 4.1
Needs to be documented hence suggestion to put in a top tier manual or similar
Auditor will need to review the documented information and see that it has been circulated or made available to their interested parties
4.4 Environmental management systemTo achieve the intended outcomes, including enhancing its environmental performance, the organization shall establish, implement, maintain and continually improve an environmental management system, including the processes needed and their interactions, in accordance with the requirements of this International Standard.
The organization shall consider the knowledge gained in 4.1 and 4.2 when establishing and maintaining the environmental management system.
Reference to processes now explicit and the recognition the part they play e.g. have you a process for waste management
Intended outcome for example to maintain your waste hierarchy and meet the duty of care
And achieve your targets on recycling (improvement)
i.e. remember the extent and scope of your system which may include supplier development e.g. transport/logistics reducing journeys choosing routes that avoid congestion zones
Auditor must evaluate the processes needed to manage the ems
5 Leadership
5.1 Leadership and commitment Top management shall demonstrate leadership and commitment with respect to the environmental management system by:
a) taking accountability for the effectiveness of the environmental management system;
b) ensuring that the environmental policy and environmental objectives are established and are compatible with the strategic direction and the context of the organization;
c) ensuring the integration of the environmental management system requirements into the organization’s business processes;
d) ensuring that the resources needed for the environmental management system are available;
e) communicating the importance of effective environmental management and of conforming to the environmental management system requirements;
f) ensuring that the environmental management system achieves its intended outcomes;
g) directing and supporting persons to contribute to the effectiveness of the environmental management system;
h) promoting continual improvement;
i) supporting other relevant management roles to demonstrate their leadership as it applies to their areas of responsibility.
NOTE Reference to “business” in this International Standard can be interpreted broadly to mean those activities that are core to the purposes of the organization’s existence.
More involvement from people at the top
Reviews (these don’t have to be one meeting any more mentioned in guidance)
Policy should align with group policy for example if the company is a member of a trade group do they have any special direction similarly could have an annual report to shareholders
Integration is now easier so consider processes that control quality and health safety information security etc.
Resources should be allocated budgets, manpower, etc.
Transparency that the system is effective
Noticeboards, newsletters etc.
Target setting (now much more prescriptive)
No longer a management rep but recognition it may be a team of people
Again transparency
E.g. with example earlier support of procurement for choice of logistics company
The auditor must ensure any objectives and targets link up to strategic objectives
Auditors cannot demand there is a management rep
There should be evidence that the system is supported with allocation of resources BUT there is no requirement for this to be documented!
During an audit it is expected that the auditor will interview Directors/Senior Management
5.2 Environmental PolicyTop management shall establish, implement and maintain an environmental policy that, within the defined scope of its environmental management system:
a) is appropriate to the purpose and context of the organization, including the nature, scale and environmental impacts of its activities, products and services;
b) provides a framework for setting environmental objectives;
c) includes a commitment to the protection of the environment, including prevention of pollution and other specific commitment(s) relevant to the context of the organization;
NOTE Other specific commitment(s) to protect the environment can include sustainable resource use, climate change mitigation and adaptation, and protection of biodiversity and ecosystems.
d) includes a commitment to fulfil its compliance obligations;
e) includes a commitment to continual improvement of the environmental management system to enhance environmental performance.
The environmental policy shall:
be maintained as documented information;
be communicated within the organization;
be available to interested parties;
Main change here is protection of the environment not just prevention of pollution
Requirement to commit to any other business requirements related to the environment
Policy should documented and auditor therefore should review this against 5.2
And note in his audit trail its current status (issue date etc)
5.3 Organizational roles, responsibilities and authoritiesTop management shall ensure that the responsibilities and authorities for relevant roles are assigned and communicated within the organization.
Top management shall assign the responsibility and authority for:
a) ensuring that the environmental management system conforms to the requirements of this International Standard;
b) reporting on the performance of the environmental management system, including environmental performance, to top management.
Now no specific management rep but can split the roles and responsibilitiesAuditor should check evidence of allocation of responsibility and evidence of reporting mechanisms being in place
6 Planning
6.1 Actions to address risks associated with threats and opportunities
6.1.1 GeneralThe organization shall establish, implement and maintain the processes needed to meet the requirements in 6.1.1 to 6.1.4.
When planning for the environmental management system, the organization shall consider:
a) the issues referred to in 4.1;
b) the requirements referred to in 4.2;
c) the scope of its environmental management system; and determine the risks and opportunities, related to its:
d) environmental aspects (see 6.1.2);
e) compliance obligations (see 6.1.3);
f) other issues and requirements, identified in 4.1 and 4.2; that need to be addressed to:
g) give assurance that the environmental management system can achieve its intended outcomes;
h) prevent, or reduce, undesired effects, including the potential for external environmental conditions to affect the organization;
i) achieve continual improvement.
Within the scope of the environmental management system, the organization shall determine potential emergency situations, including those that can have an environmental impact.
The organization shall maintain documented information of its:
a) risks and opportunities that need to be addressed;
b) processes needed in 6.1.1 to 6.1.4, to the extent necessary to have confidence they are carried out as planned.
The aspects table always did look at potential to pollute now needs to look at protecting the environment more generally e.g. climate change
Now mentions opportunities e.g. an insulation company selling its product is in fact encouraging energy conservation so there is recognition there are positives to consider as well as negatives
Any stakeholder concerns needs to be addressed
Always did have to look at emergencies but now specifically mentions ‘potential emergencies’ that could be external issues like a train crash or river flooding most companies usually look currently only at fire and spillage.
External conditions here again could be flooding the affect on a local neighbourhood with traffic congestion etc.
This small paragraph has potentially the most significance BUT like the quality standard the company must decide on the level of documentation required based on knowledge and competence of people and the degree of control currently
Auditor needs to see Risks and opportunities have been identified and documented Processes needs to have been identified e.g. Compliance schemes, consent to discharge/treatment processes, scrubbers/afterburners maintenance and monitoring
6.1.2 Environmental AspectsWithin the defined scope of the environmental management system, the organization shall determine the environmental aspects of its activities, products and services that it can control and those that it can influence, and their associated environmental impacts, considering a life cycle perspective.
When determining environmental aspects, the organization shall take into account:
a) change, including planned or new developments, and new or modified activities, products and services;
b) abnormal conditions and reasonably foreseeable emergency situations.
The organization shall determine those aspects that have or can have a significant environmental impact, i.e. significant environmental aspects, by using established criteria.
The organization shall communicate its significant environmental aspects among the various levels and functions of the organization, as appropriate.
The organization shall maintain documented information of its:
a) environmental aspects and associated environmental impacts;
b) criteria used to determine its significant environmental aspects;
c) significant environmental aspects.
NOTE Significant environmental aspects can result in risks and opportunities associated with either adverse environmental impacts (threats) or beneficial environmental impacts (opportunities).
Life cycle perspective is a significant change so company must show they have considered this e.g. what about the ultimate disposal of their product –for example WEEE directive and the effect this has had on disposal of PCBs
Upstream and downstream influences need to be considered.
Any new processes could seriously affect impact on the environment
Normal abnormal and emergency conditions was in the original BS7750 and now its back more transparently
Clear that you have to have a documented process and an aspects table
This was always a requirement but the need for positive aspects was not highlighted
E.g. a company remanufacturing toner cartridges for printers is reducing the amount of product reaching end of life.
6.2.1 Environmental objectives
The organization shall establish environmental objectives at relevant functions and levels, taking
a) determine and have access to the compliance obligations related to its environmental aspects;
b) determine how these compliance obligations apply to the organization;
c) take these compliance obligations into account when establishing, implementing, maintaining and continually improving its environmental management system.
The organization shall maintain documented information of its compliance obligations.
NOTE Compliance obligations can result in risks and opportunities to the organization.
This whole area is now much more prescriptive and requires SMART targets legal register this recognizes the information could be more remote i.e. as long as you can access the information this is OK
b) this is to stop standard lists of legal statutes which doesn’t actually state what you have to do to comply
c) is to take into account where legal obligations are required e.g. waste packaging regulations requirement for reducing and recycling waste where permit conditions require improvements
Auditors should check for evidence of documented objectives that the company has evaluated its legal obligations and stated what they are and show how they tie up with its aspects (not a new requirement)
6.2.2 Planning actions to achieve environmental objectives When planning how to achieve its environmental objectives, the organization shall determine:
a) what will be done;
b) what resources will be required;
c) who will be responsible;
d) when it will be completed;
e) how the results will be evaluated, including indicators for monitoring progress toward achievement of its measurable environmental objectives (see 9.1.1).
The organization shall consider how actions to achieve its environmental objectives can be integrated into the organization’s business processes.
Self explanatory prescriptive much clearer requirements
KPI approach familiar to many.
Encourages integrated objectives e.g. reduce scrap-reduce waste
The auditor should check for documented information on how the planning of meeting objectives is stated
7 Support
7.1 ResourcesThe organization shall determine and provide the resources needed for the establishment, implementation, maintenance and continual improvement of the environmental management system.Level of resource applied to the system needs to be determinedAuditor should check for adequate resourcing (can be by interview)
7.2 CompetenceThe organization shall:
a) determine the necessary competence of person(s) doing work under its control that affects its environmental performance and its ability to fulfil its compliance obligations;
b) ensure that these persons are competent on the basis of appropriate education, training or experience;
c) determine training needs associated with its environmental aspects and its environmental management system;
d) where applicable, take actions to acquire the necessary competence, and evaluate the effectiveness of the actions taken.
NOTE Applicable actions can include, for example, the provision of training to, the mentoring of, or the re- assignment of currently employed persons; or the hiring or contracting of competent persons.
The organization shall retain appropriate documented information as evidence of competence
This is saying you need to go through the process of formally looking at key tasks and work out the competence required and where necessary provide training to ‘raise the bar’ to the required level.But it does recognise the role of the consultant!
Records of competence have to be on file
Auditor needs to check for Competence evaluations
7.3 AwarenessThe organization shall ensure that persons doing work under the organization’s control are aware of:
a) the environmental policy;
b) the significant environmental aspects and related actual or potential environmental impacts associated with their work;
c) their contribution to the effectiveness of the environmental management system, including the benefits of enhanced environmental performance;
d) the implications of not conforming with the environmental management system requirements, including not fulfilling the organization’s compliance obligations.
This area has been reinforced all employees and agency staff/sub contractors have to show they know and understand what the issues are :significant aspects
And how they might affect them positively and negatively
Auditor should sample interview personnel during the walk round
To establish that awareness has been addressed.
7.4 Communication
7.4.1 GeneralThe organization shall establish, implement and maintain the processes needed for internal and external communications relevant to the environmental management system, including:
on what it will communicate;
a) when to communicate;
b) with whom to communicate;
c) how to communicate.
When establishing its communication process(es), the organization shall:
a) take into account its compliance obligations;
b) ensure that environmental information communicated is consistent with information generated within the environmental management system, and is reliable.
The organization shall respond to relevant communications on its environmental management system.
The organization shall retain documented information as evidence of its communications, as appropriate.
This is recognizing the development of various means of communication more prescriptive self-explanatory.
Requires process approach
This requires the process to defined on how for example the company collects and communicates data on waste packaging,
Meeting schedule requirements to the Environment Agency
And indeed that the information is accurate/reliable.
But equally it may be the collection and transmission of information on carbon footprint /CO2 emissions
The importance here is now has to be documented
Communications should be audited by looking for evidence of legal compliance,
Supply of data/information to clients on request
7.4.2 Internal CommunicationThe organization shall:
a) internally communicate information relevant to the environmental management system among the various levels and functions of the organization, including changes to the environmental management system, as appropriate;
b) ensure its communication process(es) enable(s) persons doing work under the organization’s control to contribute to continual improvement.
No requirement to document!This can be audited in the process of auditing the company’s environmental processes.
7.4.3External CommunicationThe organization shall externally communicate information relevant to the environmental management system, as established by the organization’s communication process(es) and as required by its compliance obligations.See 7.4.1 on communication of data.
May also be complaints follow up
Auditors should check in particular for evidence of communications with regulators where fulfilment of legal obligations are required.
7.5 Documented Information
7.5.1 GeneralThe organization’s environmental management system shall include:
a) documented information required by this International Standard;
b) documented information determined by the organization as being necessary for the effectiveness of the environmental management system.
NOTE The extent of documented information for an environmental management system can differ from one organization to another due to:
a) the size of organization and its type of activities, processes, products and services;
b) the need to demonstrate fulfilment of its compliance obligations;
c) the complexity of processes and their interactions;
d) the competence of persons doing work under the organization’s control./td>
The company can have additional information that they think is important included in the ems
This is like the new ISO 14001:2015 in that the documentation required is based upon the skill base the company have and how complex the processes are
If people are competent then process mapping may be quite simplistic
Where documented information is a requirement of the standard the auditor shall check for evidence and note it on the audit record
7.5.2Creating and updatingWhen creating and updating documented information, the organization shall ensure appropriate:
a) identification and description (e.g. a title, date, author, or reference number);
b) format (e.g. language, software version, graphics) and media (e.g. paper, electronic);
c) review and approval for suitability and adequacy.
This is not new but is now clearly defined rather than impliedEssentially requires the auditor to see all documented information is suitably controlled
7.5.3 Control of documented informationDocumented information required by the environmental management system and by this International Standard shall be controlled to ensure:
a) it is available and suitable for use, where and when it is needed;
b) it is adequately protected (e.g. from loss of confidentiality, improper use, or loss of integrity).
c) For the control of documented information, the organization shall address the following activities as applicable:
d) distribution, access, retrieval and use;
e) storage and preservation, including preservation of legibility;
f) control of changes (e.g. version control);
g) retention and disposition.
Documented information of external origin determined by the organization to be necessary for the planning and operation of the environmental management system shall be identified, as appropriate, and controlled.
NOTE Access can imply a decision regarding the permission to view the documented information only, or the permission and authority to view and change the documented information.
Now refers to documented information rather than documents
Covers information security.
Recognises some media deteriorate over time
But controls remain largely unchanged
Statutes pollution prevention control guidelines etc need to be controlled and kept up to date
Access doesn’t mean the document is company’s intellectual property
8 Operations
8.1 Operational planning and controlThe organization shall establish, implement, control and maintain the processes needed to meet environmental management system requirements, and to implement the actions identified in 6.1 and 6.2, by:
a) establishing operating criteria for the process(es);
b) implementing control of the process(es), in accordance with the operating criteria.
NOTE Controls can include engineering controls and procedures. Controls can be implemented following a hierarchy (e.g. elimination, substitution, administrative) and can be used individually or in combination.
The organization shall control planned changes and review the consequences of unintended changes, taking action to mitigate any adverse effects, as necessary.
The organization shall ensure that (an) outsourced process(es) is (are) controlled or influenced. The type and extent of control or influence to be applied to the process(es) shall be defined within the environmental management system.
Consistent with a life cycle perspective, the organization shall:
a) establish controls, as appropriate, to ensure that its environmental requirement(s) is (are) addressed in the design and development process for the product or service, considering each stage of its life cycle;
b) determine its environmental requirement(s) for the procurement of products and services, as appropriate;
c) communicate its relevant environmental requirement(s) to external providers, including contractors;
d) consider the need to provide information about potential significant environmental impacts associated with the transportation or delivery, use, end-of-life treatment and final disposal of its products and services.
The organization shall maintain documented information to the extent necessary to have confidence that the process(es) has (have) been carried out as planned.
The ems was never previously as prescriptive about process control
‘Downstream’ activities need to be controlled
E.g. surface treatments like galvanising, painting often done by sub contractors and which potentially have significant environmental impacts need to be controlled
Similarly because this now considers life cycle it should cover activities like shipping, logistics etc.
Legislative controls now come into play much more e.g. End of life vehicle controls etc.
Aspects tables therefore cover much more than the factory environment.
Auditor needs to check that documented information is adequate to maintain control obviously if there is evidence of pollution, breaches in legislation then an auditor can raise a concern but care should be exercised as it may also be down to competence of personnel
8.2 Emergency preparedness and responseThe organization shall establish, implement and maintain the processes needed to prepare for and respond to potential emergency situations identified in 6.1.1.
The organization shall:
a) prepare to respond by planning actions to prevent or mitigate adverse environmental impacts from emergency situations;
b) respond to actual emergency situations;
c) take action to prevent or mitigate the consequences of emergency situations, appropriate to the magnitude of the emergency and the potential environmental impact;
d) periodically test the planned response actions, where practicable;
e) periodically review and revise the process(es) and planned response actions, in particular after the occurrence of emergency situations or tests;
f) provide relevant information and training related to emergency preparedness and response, as appropriate, to relevant interested parties, including persons working under its control.
The organization shall maintain documented information to the extent necessary to have confidence that the process(es) is (are) carried out as planned.
Most companies have addressed these for fire and spillages but traffic accidents, rail crashes etc. have generally not been covered remember the previous section has alluded to external issue of transport logistics etc.
The section is more expressive about ‘lessons learned’
Documented evidence is required that the system or process is working.
Auditor must check to see there is documented evidence of emergency planning
9 Performance evaluation
9.1 Monitoring, measurement, analysis and evaluation
9.1.1 GeneralThe organization shall monitor, measure, analyse and evaluate its environmental performance. The organization shall determine:
a) what needs to be monitored and measured;
b) the methods for monitoring, measurement, analysis and evaluation, as applicable, to ensure valid results;
c) the criteria against which the organization will evaluate its environmental performance, and appropriate indicators;
d) when the monitoring and measuring shall be performed;
e) when the results from monitoring and measurement shall be analysed and evaluated.
The organization shall ensure that calibrated or verified monitoring and measurement equipment is used and maintained, as appropriate.
The organization shall evaluate its environmental performance and the effectiveness of the environmental management system.
The organization shall communicate relevant environmental performance information both internally and externally, as identified in its communication process(es) and as required by its compliance obligations.
The organization shall retain appropriate documented information as evidence of the monitoring, measurement, analysis and evaluation results
Many small companies have not addressed this area well in the past but now they must measure how they are performing so waste generation amount of recycling occurring needs to be actually recorded.
Solvent reduction amount by how much etc.
Analysis of course could be management review (doesn’t say how you analyse)
This harks back to EMAS about publicly declaring data (many companies now have statements in their year-end accounts)
Similarly as per MPCB, the company is legally obligated to provide this information-companies were doing this
Auditor needs to check for documentary evidence of monitoring and measurement
9.1.2Evaluation of complianceThe organization shall establish, implement and maintain the processes needed to evaluate fulfilment of its compliance obligations.
The organization shall:
a) determine the frequency that compliance will be evaluated;
b) evaluate compliance and take action if needed;
c) maintain knowledge and understanding of its compliance status.
The organization shall retain documented information as evidence of the compliance evaluation result(s).
Most small companies have evaluated compliance in as much as checking their legal register was up to date but there was no requirement to actually have a process with corrective action follow up
c) is clearly saying you not only need to know what statutes apply but what the company’s specific obligations are.
The compliance check needs to be documented
Auditor shall check for legal compliance results and evidence of actions taken if breaches are evident
9.2 Internal Audit
9.2.1 GeneralThe organization shall conduct internal audits at planned intervals to provide information on whether the environmental management system:
a) conforms to:
1) the organization’s own requirements for its environmental management system;
2) the requirements of this International Standard;
b) is effectively implemented and maintained.
Audit schedule
Audit to company’s processes as well as the standard
Check no issues
9.2.2Internal audit programmeThe organization shall establish, implement and maintain an internal audit programme(s), including the frequency, methods, responsibilities, planning requirements and reporting of its internal audits.
When establishing the internal audit programme, the organization shall take into consideration the environmental importance of the processes concerned, changes affecting the organization and the results of previous audits.
The organization shall:
a) define the audit criteria and scope for each audit;
b) select auditors and conduct audits to ensure objectivity and the impartiality of the audit process;
c) ensure that the results of the audits are reported to relevant management.
The organization shall retain documented information as evidence of the implementation of the audit programme and the audit results.
Internal audit programme has to say how often and how the audit will be conducted and how its reported
Most companies already comply with these requirements
But transparent requirements self-explanatory
Auditor shall check for evidence of audits being planned and evidence of their results
9.3 Management reviewTop management shall review the organization’s environmental management system, at planned intervals, to ensure its continuing suitability, adequacy and effectiveness.
The management review shall include consideration of:
a) the status of actions from previous management reviews;
b) changes in:
1) external and internal issues that are relevant to the environmental management system;
2) the needs and expectations of interested parties, including compliance obligations;
3) its significant environmental aspects;
4) risks and opportunities;
c) the extent to which environmental objectives have been achieved;
d) information on the organization’s environmental performance, including trends in:
1) nonconformities and corrective actions;
2) monitoring and measurement results;
3) fulfilment of its compliance obligations;
4) audit results;
e) adequacy of resources;
f) relevant communication(s) from interested parties, including complaints;
g) opportunities for continual improvement.
The outputs of the management review shall include:
a) conclusions on the continuing suitability, adequacy and effectiveness of the environmental management system;
b) decisions related to continual improvement opportunities;
c) decisions related to any need for changes to the environmental management system, including resources;
d) actions, if needed, when environmental objectives have not been achieved;
e) opportunities to improve integration of the environmental management system with other business processes, if needed;
f) any implications for the strategic direction of the organization.
The organization shall retain documented information as evidence of the results of management reviews.
Change management
Most companies did trend analysis but didn’t report in detail
So the objectives and targets need to be better reported for example
New requirement about resourcing
Much more evidence of decision making and action follow up
Auditor shall check for evidence of actions and outputs from management reviews doesn’t actually say they have to be minuted as such so take care! But there must be documented information maintained!
10 Improvement
10.1 GeneralThe organization shall determine opportunities for improvement (see 9.1, 9.2 and 9.3) and implement necessary actions to achieve the intended outcomes of its environmental management system.Not new
10.2 Nonconformity and corrective actionWhen a nonconformity occurs, the organization shall:
a) react to the nonconformity and, as applicable:
b) take action to control and correct it;
c) deal with the consequences, including mitigating adverse environmental impacts;
d) evaluate the need for action to eliminate the causes of the nonconformity, in order that it does not recur or occur elsewhere, by:
e) reviewing the nonconformity;
f) determining the causes of the nonconformity;
g) determining if similar nonconformities exist, or could potentially occur;
h) implement any action needed;
i) review the effectiveness of any corrective action taken;
j) make changes to the environmental management system, if necessary.
Corrective actions shall be appropriate to the significance of the effects of the nonconformities encountered, including the environmental impact(s).
The organization shall retain documented information as evidence of:
a) the nature of the nonconformities and any subsequent actions taken;
b) the results of any corrective action.
Much more analytical and in line with automotive/aerospace thinking e.g. FMEA root cause 5 whys etc.
Documented info required
Auditor shall ensure that there is documented evidence of the raising of non-conformances and the outcomes (results of corrective action)
10.3 Continual ImprovementThe organization shall continually improve the suitability, adequacy and effectiveness of the environmental management system to enhance environmental performance.System improvements required as well as reduction in impactsAuditors should look for evidence of the ems improving in such a way that environmental performance has been enhanced.
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