Kim Christiansen, Danish Standards 1

Transcription

1 Kim Christiansen, Danish Standards 1

2 ISO revision from CD.2 to DIS Out of Padova (February 1014) the document was too long - remove redundancies from text and annex, and to delete implementation guidance from Annex the document contained prescriptive/complex requirements - compatibility with other MSS, need for flexibility and simplify requirements to facilitate user understanding the document contained bureaucratic requirements re-evaluate the minimum documentation necessary the document contained confusing concepts and terminology Kim Christiansen, Danish Standards 2

3 ISO revision from CD.2 to DIS 7. Recommendation 07/2014 Based on the approved ballot of ISO/CD and after dispositioning the comments received ISO/TC 207/SC 1/WG 5 agreed to raise the document to DIS stage and asks SC 1 to forward ISO/DIS to ISO/CS. 8. Recommendation 08/2014 ISO/TC 207/SC 1/WG 5 agreed to install an editing group to finalize ISO/DIS 14001:2014 until at the latest. The members of the editing group are: Lisa Greenwood, Amarjit Kaur, Maiko Okuno, Johan Nel, Daniel Trillos, Daniele Pernigotti. 10. Recommendation 10/2014 ISO/TC 207/SC 1/WG 5 experts are encouraged to consider the following in their comments on ISO/DIS 14001:2014: seek comments from constituents in their NMB identifying where redrafting may be needed to ensure WG 5 operating principles are reflected in ISO/FDIS when commenting on ISO/DIS 14001:2014 to pay attention to new terms used and old terms removed, see if additional explanation is needed in Annex A.3 e.g. Targets, key characteristics, Risk and Opportunities, programme, procedure vs. process, training needs, record Kim Christiansen, Danish Standards 3

4 13. Recommendation 13/2014 Intended Outcome ISO/TC 207/SC 1/WG 5 agreed that there was inconsistency throughout the document on the intended outcome(s) of an EMS, and that there was a need to reach consensus on our intent when using this term. in concept that Intended outcome means high level/overarching (i.e. strategic) as it relates to the environmental management system. Still need to reach consensus on what the specific intended outcomes of the EMS are. Risks/opportunities are NOT issues; risks/opportunities arise from issues Issues can arise from non-environmental subjects, e.g. financial, technology, governance Do NOT want to limit to environmental issues only, e.g. air, water, land, natural resources. Need to use this word consistently throughout referring to 4.1 only. to perform an exercise to brainstorm and select statements describing our intent was started in Padova, but not completed. to describe intended outcomes in the Introduction/Scope (as per ISO directives) include a note (either in definition of EMS, or in 4.1 TBD), and verify consistent use and intent throughout document. If needed, explanatory text can be provided in the annex. Action: complete exercise before Panama meeting. Leadership decision to use Survey Monkey to complete exercise Kim Christiansen, Danish Standards 4

5 Agreed in Panama, that intended outcomes of an EMS include (thus implying these are the minimal, core outcomes, and that organizations can set additional intended outcomes for their EMS): a) enhancement of environmental performance b) satisfying compliance obligations c) fulfilment of environmental objectives Agreed to place text in the Scope (thus incorporating it into the requirements of the standard), and that no further notes or explanations are needed at this time. 14. Recommendation 14/ Strategy ISO/TC 207/SC 1/WG 5 agreed that the phrase strategic direction will be used consistently when implying high level/overarching in the context of the business. Need to use this phrase consistently throughout, eliminate where not significant or where used in another context Kim Christiansen, Danish Standards 5

6 15. Recommendation 15/ Issues ISO/TC 207/SC 1/WG 5 agreed that issues are important topics for the organization, problems for debate and discussion or changing circumstances that can affect, either positively or negatively, the intended outcomes of the management system. Environmental conditions are NOT the only relevant issues opposed to generic management related clauses Procedures may not be needed where Annex SL text has already provided detail. ISO/TC 207/SC 1/WG 5 agreed to use clause 4.4 to clarify that it s up to the organization to determine the extent processes/procedures and documented information is needed to have confidence they are controlled, that that they achieve the desired results, and are carried out as planned Kim Christiansen, Danish Standards 6

7 16. Recommendation 16/ Environmental protection ISO/TC 207/SC 1/WG 5 agreed that intent was to have a policy commitment to environmental protection (the higher order concept) which includes the concept of prevention of pollution and could also include other concepts (i.e., sustainable resource use, climate change mitigation, etc.). that we don't want to lose the term prevention of pollution ; want to retain its emphasis in text. that it is Intended to cover something broader than prevention of pollution that implies positive, proactive efforts. ACTION: informal drafting group to consider proposal for a new phrase that can be used in conjunction with prevention of pollution [Martin Baxter, Johan Nel and others] NOTE: Action not complete in Padua. Text edited to reflect interim decision to use environmental protection, including prevention of pollution Kim Christiansen, Danish Standards 7

8 17. Recommendation 17/ Environmental performance improvement The underlying intent of this phrase is to reduce the organization s adverse environmental impacts (i.e., emissions, effluents, wastes, etc.). This concept is referred to as operational performance in ISO ISO/TC 207/SC 1/WG 5 wants to retain alignment with Annex SL and ISO concepts with respect to improvement of the environmental management system, consistent with our mandate, but in selected clauses want to emphasize the focus on improving operational performance. It was agreed to use the phrase to enhance environmental performance in those clauses where WG 5 agreed to add emphasis, and thereby avoid violation of the substitution principle and be consistent with the intent of Annex SL Kim Christiansen, Danish Standards 8

9 18. Recommendation 18/ Processes vs procedures ISO/TC 207/SC 1/WG 5 does not want to incorporate the process approach in ISO ISO/TC 207/SC 1/WG 5 agreed to re-evaluate the need for procedures and review if it s really necessary. In addition to the criteria for evaluating need for requirements in section 6.0 above, consider: Procedures may be needed in environmental management related clauses as opposed to generic management related clauses Procedures may not be needed where Annex SL text has already provided detail. ISO/TC 207/SC 1/WG 5 agreed to use clause 4.4 to clarify that it s up to the organization to determine the extent processes/procedures and documented information is needed to have confidence they are controlled, that that they achieve the desired results, and are carried out as planned Kim Christiansen, Danish Standards 9

10 19. Recommendation 19/ Risks/opportunities ISO/TC 207/SC 1/WG 5 agreed that risks and opportunities are more than environmental risks (i.e., related to air, water, land, natural resources etc.), and include other non environmental issues that pose risk. o risks and opportunities are NOT always relevant to the EMS; only if they can affect the organization s purpose & the intended outcomes of the EMS that our intent is to determine and address the risk associated with organizational context (i.e. issues ) [4.1, 4.2] that (i) pose adverse effects (threats) or (ii) present beneficial opportunities to the intended outcomes of the environmental management system, and to use this knowledge as one of the inputs to the prioritization of risks (threats) and opportunities. that we do not want a prescriptive risk management process in the requirements (consider illustrating the range of options as an example in 14004/Annex) Cont Kim Christiansen, Danish Standards 10

11 that the environmental criteria (toxicity, duration and likelihood of exposure, etc.) is the primary and minimum criteria for assessing environmental aspects. Other criteria may also be used (example: an aspect may not be significant when considering only environmental criterion but when other organizational issues are considered (such as threat of a noncompliance or interested party concerns) the aspect may reach or exceed the threshold for determining significance. However, these other criteria are not to be used to downgrade an aspect that is significant based on environmental impact. to ask TG to look at reordering 6.1 sub clauses to address problems associated with (i) a distorted meaning of Annex SL requirements due to splitting up the text into multiple sub clauses; (ii) disassociation of significant environmental aspects from significant environmental impacts, (iii) flow/clarity of the intent, particularly as it related to the relationship of significant environmental aspects and risks and opportunities. to defer resolution of comments on definition of risk until 6.1 text is written Kim Christiansen, Danish Standards 11

12 20. Recommendation 20/2014 Interested Party ISO/TC 207/SC 1/WG 5 confirmed previous plenary decision to use term interested party, not stakeholder, and agreed that an exhaustive list of examples of interested parties was not needed. 21. Recommendation 21/ Compliance obligations ISO/TC 207/SC 1/WG 5 agreed that they are not limited to legal requirements to retain use of the term compliance obligations that an exhaustive list of examples of compliance obligations was not needed. to ask TG to re-evaluate and confirm the intent to use (interested party) requirement vs (organization s) compliance obligations in the respective clauses Kim Christiansen, Danish Standards 12

13 22. Recommendation 22/2014 Communication ISO/TC 207/SC 1/WG 5 agreed that it is important that communications section retains linkage to the some kind of QA/evaluation done in 9.1 to retain principles but rephrase to make them auditable, and applicable to both internal and external communications to follow Annex SL model and put requirements for communicating a particular topic in the core clause, not in 7.4, if possible. (Same for 7.5 Documented information) Kim Christiansen, Danish Standards 13

14 Recommendations on Clause Recommendation 24/2014 (former TG-Recommendation A.1) on 4.1 and 4.2 The previous plenary decision was confirmed that knowledge was output of 4.1 and 4.2 and input to 4.4. To reduce duplication, statement moved from 4.1 and 4.2 to 4.4. Evidence of this knowledge would be documented in various clauses of EMS therefore no need for a redundant requirement in 4.1 and Recommendation 23/ Life cycle perspective Detailed analysis of risks threats and opportunities, significant environmental aspects and compliance obligations, including application of a life cycle perspective, is done in Clause 6.1. Clause 4.1 provides context which the organization uses in Clause 6.1 to analyze the significant environmental aspects, compliance obligations and risk associated with threats and opportunities for the life cycle stages of its products and services. Clauses 8.1 & 8.2 use that analysis as input and is focused on the implementation of the action/operational controls that result from Duplication of the requirement to apply a life cycle perspective was eliminated from Clauses 8.1 & Kim Christiansen, Danish Standards 14

15 25. Recommendation 25/2014 (former TG-Recommendation A.3) on 4.2 It was agreed that organization determines its compliance obligations at a conceptual level in 4.2 based on knowledge of the relevant requirements of relevant interested parties (a detailed analysis of these requirements was conducted in 6.1.3). Agreed this improved flow, reflected organizational practices, and did not undermine Annex SL intent (JTCG viewed that this step was done in 4.3, as per their concept document). 26. Recommendation 26/2014 (former TG-Recommendation A.4) on 4.3 The previous plenary decision was confirmed that an organization retained the authority to decide the scope. 27. Recommendation 27/2014 (former TG-Recommendation A.5) on 4.3 It was agreed that our intent in 4.3 is to consider compliance obligations, not relevant requirements Kim Christiansen, Danish Standards 15

16 28. Recommendation 28/2014 (former TG-Recommendation A.6) on 4.3 After much discussion on the need for the discipline-specific bullets in 4.3, it was agreed to retain them as it is common practice to consider these parameters when establishing scope statements. It was agreed that some of these parameters were both input to determining the scope, and an output which was included in the scope statement (i.e., Bullets 3 & 4). 29. Recommendation 29/2014 (former TG-Recommendation A.7) on 4.3 The long standing consensus position to allow organization to phase-in EMS implementation was confirmed. To address the concern that some might cherry pick activities, products goods and services to purposefully exclude those with significant environmental aspects, the requirement to make the scope available to interested parties and the modified text in paragraph 3 of clause 4.3 was confirmed as necessary and sufficient. 30. Recommendation 30/2014 (based on former TGrecommendation A.9) on A.4.1 and A.4.2 It was agreed to streamline list of examples of topics that could be considered issues in the A.4.1. It was noted that Annex SL purposefully moved internal and external interested party issues to 4.2, so those examples were deleted in A4.1, and considered for inclusion in A Kim Christiansen, Danish Standards 16

17 31. Recommendation 31/2014 It was decided to defer the decision on deleting management system definition (3.9) to the DIS editing group. Consistent with ISO Directives, if the term is not used in the requirements text, then it cannot be a defined term in clause 3. If it is not used then the wording in definition 3.9 will be incorporated into Environmental Management System definition 3.10 to retain consistency with Annex SL, as appropriate. 32. Recommendation 32/2014 Environmental performance is not managed directly in the Environmental Management System, it is the end result of managing environmental aspects, compliance obligations and risk associated with threats and opportunities. 33. Recommendation 33/2014 On 4.3 Agreed that an organization maintains autonomy to prioritize which issues identified in 4.1 and 4.2 it will address in its EMS, and that it was inappropriate to imply that the organization must work on all issues. Therefore retained the term consider, not take into account, to be consistent with the intent of Annex SL and consistent with the Future Challenges recommendation (#1). 34. Recommendation 34/2014 On 4.2 It was agreed to provide consistency and linkage between the heading and the text without causing a deviation by modifying the third bullet to read needs and expectations (i.e. requirements) Kim Christiansen, Danish Standards 17

18 Recommendations on Clause Recommendation 35/2014 on 5.1 It was agreed that this clause duplicates requirements in other sections, and was acknowledged that this causes double jeopardy when being audited. For example, if the organization does not conform to the 7.1 requirement (to provide resources needed for EMS), there will be a second nonconformity under clause 5.1 because Top Management did not ensure the resources needed for the EMS were available. Recommendations on Recommendation 36/2014 (former TG-Recommendation C.1) on 3.6 Consistent with the plenary decision that environmental criteria is the primary and minimum criteria for assessing environmental aspects, the note a significant environmental aspect is one that has or can have a significant environmental impact was reinserted into the definition of environmental aspect 37. Recommendation 37/2014 (former TG-Recommendation C.2) It was agreed to replace the phrase risks and opportunities with risk associated with threats and opportunities to reflect a compromise reached to build a bridge between business jargon and technical/scientific jargon while being true to the meaning in both and to the Annex SL definition of risk in Kim Christiansen, Danish Standards 18

19 38. Recommendation 38/2014 (former TG-Recommendation C.3) The scale of analysis expected in the various clauses can be conceptual or detailed; for example, the analyses in clauses 4.1 and 4.2 are conceptual, not detailed. Regarding clause 6.1, the intent is to require a detailed analysis for significant environmental aspect determination and require a conceptual analysis when evaluating risks threats and opportunities associated with other nonenvironmental issues. 39. Recommendation 39/2014 (former TG-Recommendation C.4) on 6.1 It was agreed not to imply that significant environmental aspects (the output of 6.1.2) or compliance obligations (the output of 6.1.3) need to undergo a second filtering based on the risk associated with threats and opportunities in when determining which need to be addressed in Recommendation 40/2014 (former TG-Recommendation C.5) on 6.1 It was agreed that the organization decides if they want to do separate analyses for subclauses or combine some (or all) of the analyses Kim Christiansen, Danish Standards 19

20 41. Recommendation 41/2014 (former TG-Recommendation C.6) on 6.1 Since the organization can conduct the assessment of risk associated with threats and opportunities related to issues, significant environmental aspects, and compliance obligations either separately or in combination, it is required that the organization plans a process and maintains documented information on the process (including any criteria) to the extent necessary to have confidence that the process has been carried out as planned. We do, however, require the output of the process (or processes) to be documented. 42. Recommendation 42/2014 (based on former TG- Recommendation C.7) on 6.1 Consistent with the plenary decision to look at the option to reorder 6.1 sub clauses, and to streamline the text, it was agreed to reorder the clauses. 43. Recommendation 43/2014 It was decided, with wide agreement, to accept a compromise text without modification for clause 6.1 to reflect a delicate equilibrium between competing views on discipline-specific requirement(s) that fulfil the intent of Annex SL clause 6.1. This compromise resolved satisfactorily the open issues on this clause identified in Padua (refer to convenor slides at Panama meeting). This compromise text focuses on what an organization has to do, not how to do it, enabling organizations to decide its own method and order for satisfying the requirements of and avoids implying one particular method Kim Christiansen, Danish Standards 20

21 44. Recommendation 44/2014 (former TG-Recommendation C.9) on It was agreed to delete the list of actions to be considered when addressing the risks and opportunities because it is duplicated in the Annex. 45. Recommendation 45/2014 (former TG-Recommendation C.10) on A.6.1 It was agreed that streamlining of Annex was done to eliminate duplication of requirements and provide explanation if necessary to prevent misinterpretation or help the user interpret the requirements. Recommendations on Recommendation 46/2014 On 3.14 It was agreed to define the term environmental objective and to remove the definition of objective since the text of the standard does not use this term without the modifier environmental. 47. Recommendation 47/2014 On It was agreed to change the title of to Planning actions to achieve the objectives Kim Christiansen, Danish Standards 21

22 48. Recommendation 48/2014 On It was agreed that all objectives are not measurable and, therefore, only the measurable objectives need indicators to monitor their achievement. 49. Recommendation 49/2014 On It was agreed that an organization has to consider integrating the actions to achieve environmental objectives into its business processes, and therefore added a requirement in Recommendations on Clause Recommendation 50/2014 (former TG-Recommendation B.2) It was agreed that training is only one possibility to achieve competence. Therefore, training should not be overemphasized in 7.2 when compared to all of the other possible options to assure competence. 51. Recommendation 51/2014 (former TG-Recommendation B.3) on 7.2: It was agreed, that the current wording in the first paragraph " - determine the necessary competence of person(s) doing work under its control that affects its environmental performance" covers both the potential to affect, and potential risk to cause significant environmental impacts". Clarification will be provided in A Kim Christiansen, Danish Standards 22

23 52. Recommendation 52/2014 (former TG-Recommendation B.4) on 7.3 It was agreed not to use the term "environmental policy commitment" and only use "environmental policy" (i.e. delete "commitments") as commitments are covered by the definition of "environmental policy" already. 53. Recommendation 53/2014 (former TG-Recommendation B.5) on It was agreed, that a process is needed for communication. 54. Recommendation 54/2014 (former TG-Recommendation B.6) on It was agreed, that a communication process includes e.g. communication methods and tools. Therefore methods and tools were deleted Kim Christiansen, Danish Standards 23

24 55. Recommendation 55/2014 (based on former TG- Recommendation B.7) On To make the requirement related to the quality of the communication more auditable it was decided to specify the key characteristics of consistency and reliability, but not impose an additional step in to check the information communicated because the checking is done in 9.1. The following text was agreed to be inserted as a bullet point to 7.4.1: ensure that environmental information communicated is consistent with information generated within the environmental management system, and is reliable 56. Recommendation 56/2014 (former TG-Recommendation B.8) on It was decided that responding to relevant communication on the environmental management system is important for both internal and external communication Kim Christiansen, Danish Standards 24

25 57. Recommendation 57/2014 (form TG Recommendation B.9) on It was agreed, that initiatives by which any person working for the organization can contribute to the improvement of the environmental management system are reasonable, but mentioning only their "consideration" is too weak for a requirement. Therefore, a drafting group developed the following bullet as its replacement: ensure its communication process enables any person doing work under the organization s control to contribute to the continual improvement of the EMS. 59. Recommendation 59/2014 On 8.1 Acknowledging the value chain encompasses internal processes described in Clause 8.1 as well as upstream and down stream processes described in Clause 8.2, and that the terminology value chain, supply chain and life cycle perspective were causing confusion because they are overlapping concepts that were being used in some parts of the text incorrectly, it was agreed to merge 8.1 and Kim Christiansen, Danish Standards 25

26 Recommendations on Recommendation 60/2014 (former TG-Recommendation D.6) on 8.3 It was decided to require a procedure for emergency preparedness and response based on experiences that without a procedure this topic was not addressed sufficiently/ effectively. Documented information is not required anymore. Recommendations on 8.1 and Recommendation 58/2014 On 8.2 Acknowledging that ISO standards can only impose requirements on the organization adopting the standard, it was agreed to clarify Clause 8.2 so that it was focused on the organization s internal processes that can be used to influence external providers, not on controlling the external providers processes. The term external providers was used to encompass both procurement of products goods and services and outsourced processes, and to align with Kim Christiansen, Danish Standards 26

27 61. Recommendation 61/2014 (former TG-Recommendation D.7) on 8.3 It was decided to delete the first sentence of 8.3 (1st para) on identifying potential emergency situations because this is meant to be covered in Planning (6.1.2), and therefore duplicative here. WG 5 agreed that there is a need for an explicit requirement to identify emergency situations in the requirements (6.1.2 or 8.3) and deferred this to the editing group. Recommendations on Clause Recommendation 62/2014 (former TG-Recommendation D.1) On 3.26 ISO/TC 207/SC 1/WG 5 would like to forward the following changes made to the notes to entry in the definition of "audit" to ISO/TC 176/SC 2/WG 24 for consideration, interpretation and feedback: The Notes to Entry to definition of "audits" were clarified and brought into a user friendly order: Note 1 to entry: An internal audit is conducted by the organization (3.1) itself or by an external party on its behalf. Note 2 to entry: An audit can be an internal audit (first party) or an external audit (second party or third party), and it can be a combined audit (combining two or more disciplines) Kim Christiansen, Danish Standards 27

28 Note 3 to entry: Independence can be demonstrated by the freedom from responsibility for the activity being audited or freedom from bias and conflict of interest. Note 4 to entry: Audit evidence consists of verifiable records, statement of fact and other information relevant to the audit criteria and verifiable and audit criteria are the set of policies, procedures (3.19) or requirements (3.3) used as a reference against which audit evidence is compared, as defined in ISO The note needed to be clarified to not create confusion to the users. Note 2 to entry stated that an internal audit could be conducted by internal or external party, whereas Note 1 to entry states that external audits are only second or third party. Therefore this text in Note 2 was deleted. The notes were brought to a logical and user friendly order. 63. Recommendation 63/2014 (former TG-Recommendation D.3) on 3.20 "performance" and 3.21 "env. performance" 3.20: It was agreed to keep the generic Annex SL term/definition 3.20, performance, as the term is used generically in the text without the use of the adjective environment because the intention is that it is referring to other types of measurable results (i.e., non-environmental). The Editing Group will do a final check of text. 3.21: It was agreed, after long discussion and effort to align the definition, to keep the current definition 3.21 as it is the best aligned option (see substitution principle) Kim Christiansen, Danish Standards 28

29 64. Recommendation 64/2014 (based on former TG- Recommendation D.8) on It was agreed, that most of the listed bullet points in the first para cannot be measured and monitored, e.g. operational control, so the word "including" cannot be used for listing them. " including" was replaced by "related to" which leads to the following: "The term key characteristic", could be deleted. This term was only used in Recommendation 65/2014 (based on former TG- Recommendation D.9) on It was decided that a process was needed for the evaluation of compliance. 66. Recommendation 66/2014 (former TG-Recommendation D.10) on It was decided to keep the current title on 9.1.2, but use the wording "conformity with compliance obligations" to get rid of the repetition "comply with compliance obligations" and to be consistent with the definition of the term "conformity" in the Annex SL i.e., "fulfilment of a requirement". For the first para in it was decided to use "evaluate conformity " as it is suitable here and creates the link to the title. Editing group is asked to check for consistent use of the phrase throughout the document Kim Christiansen, Danish Standards 29

30 67. Recommendation 67/2014 (former TG-Recommendation D.12) on 9.3 It was agreed that compliance obligations and, the needs and expectations of interested parties are not external and internal issues as dealt with in Clause 4.1 and therefore cannot be listed under bullet point b), and business strategy is only one of the many external and internal issues (there is no need to specifically mention business strategy). 68. Recommendation 68/2014 (former TG-Recommendation D.13) on 9.3 It was agreed that complaints are part of communication(s) from interested parties and do not need to be mentioned specially in 9.3, but the Annex needs to provide interpretation guidance on that topic. Recommendations on Clause Recommendation 69/2014 (former TG-Recommendation D.4) On 3.27 "conformity" It was agreed that the note is not needed for clarity, but was needed on 3.28 nonconformity Kim Christiansen, Danish Standards 30

31 70. Recommendation 70/2014 (former TG-Recommendation D.5) on 3.30 "correction" It was agreed that a definition of correction is not needed, as the term is not used in the document at all. We only use the term "correct" as a verb which is known as "to make something right" and therefore doesn't need to be defined. Also defining these general words in one of TC 207 standard documents would mean that all other documents would have to use the term with the defined meaning. 71. Recommendation 71/2014 (based on former TG- Recommendation D.14) On 10.1 last paragraph, bullet point saying "The organization shall retain documented information as evidence of the nature of the nonconformities and any subsequent actions taken " JTCG is kindly requested to provide guidance on the meaning of "subsequent" in this case. Regarding the importance of alignment of ISO 9001 and ISO ISO/TC 176/SC 2/WG 24 would also be kindly requested to consider that term used, and if it is in their interest to narrow the content to just take into account following/resulting actions Kim Christiansen, Danish Standards 31

32 72. Recommendation 72/2014 (former TG-Recommendation D.17) on 10.1 It was agreed not to reinstate the Preventive Action Process for correcting potential non conformities, as it was seen as a step back with regards to the Annex SL. It was the understanding of the majority that preventive action is covered by the corrective action concept, we should not imply more emphasis on one over the other. 73. Recommendation 73/2014 (former TG-Recommendation D.18) on 10.1 It was decided to delete the first paragraph saying "The organization shall implement and maintain a procedure for dealing with nonconformities and taking corrective action. "The given Annex SL requirement of keeping documented information (see last para including last two bullet points on 10.1) was seen as sufficient. And since Annex SL clause 10.1 provides detailed requirements on NC/CA, it was agreed that imposing an additional requirement was not needed Kim Christiansen, Danish Standards 32

33 74. Recommendation 74/2014 (former TG-Recommendation D.19) on 10.2 It was agreed that implementation of an EMS enhances the Environmental Performance. Because the enhancement of environmental performance is an important outcome of an EMS, and because this topic is a Future Challenges recommendation, it was agreed to keep the additional blue text in 10.2, to enhance environmental performance, but shifting it to the end of the sentence Kim Christiansen, Danish Standards 33

34 Kim Christiansen, Danish Standards 34