International Organisation for Standards: ISO 14001:2015 Review I recently attended the IEMA making the Transition to ISO 14001:2015 course and wish to inform you with a summary of the ISO 14001:2015 changes. The key changes are: Organisational context and the needs of interested parties Risks and opportunities Life cycle perspective control and influence Integration into core business processes Environmental sustainability Leadership Competence Compliance obligations and demonstration of compliance status ISO 14001 was first published in 1996 and updated in 2004. This third edition was published in September 2015. It cancels and replaces all previous editions. Organisations are granted a three-year transition period after the revision has been published to migrate their Environmental Management System (EMS) to the new edition of the standard. Why was ISO 14001 revised? All ISO standards are reviewed every five years to establish if a revision is required in order to keep it current and relevant for the marketplace. However, in reality there can be a decade or so between published versions of a standard. Assuming that ISO maintains its current process, ISO 14001:2015 will be revised in 2020, and a decision taken then as to whether or not it needs to be revised. So on this basis, we can expect that ISO 14001:2015 will be in use until approximately 2025. The revision was conducted by 121 expert members of an ISO Technical Committee called ISO/TC 207/SC1 for environmental development, which is led by British Standards Institution (BSI), ISO member for the United Kingdom (UK), representing multiple stakeholder groups from 88 countries. A new structure Major developments for ISO 14001 are an inclusion of core text and a new structure. The structure reorders some clauses, new clauses are introduced and familiar clauses have new requirements. ISO 14001:2015 Structure Some clauses are reordered. New clauses are introduced. Familiar clauses with new requirements. The 2015 version of the standard should be used in a different way. The previous versions were aimed primarily at organisations establishing an EMS for the first time. It was expected that users of the QD04-103-01 1 22/10/2015
standard would work their way through the clauses in a linear fashion. The new ISO 24001:2015 aims to encourage organisations to improve their EMS by introducing new requirements. Instead of working through clauses one by one there is far more interaction between clauses, which are mutually reinforcing. ISO14001:2004 Clauses are linear 4. Environmental Management System 4.1 General requirements 4.2 Environmental Policy 4.3. Planning 4.3.1 Environmental aspects 4.3.2 Legal and other requirements 4.3.3 Objectives, targets and programmes 4. Context of the organisation ISO14001:2015 Clauses are mutually reinforcing 4.1 Understanding the organisation 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 Organisation roles, responsibilities and authorities 6. Planning 6.1 Actions to addess risks and opportunities 6.1.1 General 6.1.2 Environmental aspects 6.1.3 Compliance obligations 6.1.4 Planning actions 6.2 Environmental objectives and planning to achieve them 6.2.1 Environmental objectives 6.2.2 Planning actions to achieve environmental objectives There is far more interaction between clauses, which are mutually reinforcing, almost like a spider s web. This is a more efficient approach, allowing themes to be followed through the clauses of the standard. Key themes which occur throughout ISO14001:2015 include the following: Leadership, responsibility, competence Environmental sustainability and taking life cycle perspective Integration of environment into business strategy and business processes Strategic and operational risks and opportunities Engaging with stakeholders and establishing and managing compliance obligations New requirements 1. Organisational context and the needs of interested parties Organisations must be able to demonstrate that their EMS have been developed by taking into account context and the views of interested parties. This should provide a high-level, strategic overview of what the organisation needs to address with its EMS. The greatest risks and opportunities to the organisation could relate to business and resource efficiency and profitability; reputational risks; mandatory compliance failings; and ability to improve environmental performance. QD04-103-01 2 22/10/2015
Internal and external parties Internal and external issues Parent company Partners Investors Customers Communities Staff Any other entity with an interest in the organisation s environmental performance Internal characteristics of the organisation Activities Products and services Culture Capabilities (e.g. people, knowledge, processes, systems) Business objectives * Internal and external parties and issues are always organisation specific External circumstances Cultural, social, political, legal, regulatory, financial, technological, economic, natural, competitive Local, regional, national, international Environmental conditions Condition that can either affect the organisation Conditions that can be affected by its environmental aspects In addition to the requirement to consider context when establishing the EMS, senior management must also ensure that the environmental policy and objectives are compatible and aligned with the strategic direction of the business. Preparation needed in your organisation: Some form of evidence is needed to demonstrate that context and interested parties have been considered. The aim is to provide an overview of key considerations. This means that an organisation could use brainstorming to meet their needs and record the outcomes in management review records. The output of the process should identify important issues. It could be ensured that: All production, engineering and design functions address resource efficiency to drive down cost Resources and processes are adequate to deliver legal compliance There are mechanisms to evaluate potential impacts of new developments and to address community concerns There is a robust process for reporting performance to stakeholders 2. Risks and opportunities The new common text of management systems introduces a new concept of addressing risks and opportunities, using risk to denote both potentially negative consequences and also convey the concept of uncertainty of the outcome. Uncertain outcomes can be positive or negative. ISO14001:2015 new definition of risk and opportunities is potential adverse effects (threats) and potential beneficial effects (opportunities). The new text deals with risk and opportunities in the planning clause, describing a process which involves: Determining risks and opportunities Identifying environmental aspects QD04-103-01 3 22/10/2015
Determining significant environmental aspects Identifying compliance obligations The intent of the text is to ensure that organisations take a holistic view of risks and opportunities, rather than simply focussing on the scale of potential impact on the environment at operational level, the new text places more emphasis on risks and opportunities to the organisation from external factors, including environmental conditions and the need of interested parties. It also requires consideration of factors that could prevent the EMS from operating effectively. Preparation needed in your organisation: In reviewing an organisation s process for addressing risks and opportunities it is important to recognise that the concept has been broadened. In determining the scale of risk at operational level, it is necessary to consider the high level, strategic risks related to the organisation s internal and external context and the needs of interested parties. This approach is more effective in determining priorities for the EMS, so that it continues to provide appropriate management of operational risks to the environment, but also: Focusses on risks and opportunities to the organisation from external environmental conditions Addresses genuine needs of interested parties Takes advantage of opportunities, not only for environmental improvement but also in relation to wider business performance. Example: Aspect External environmental factors External sociopolitical factors Internal factors Interested parties Risks and opportunities Transport - Air pollution - Noise - Vehicle - emissions - Public perception - knowledge - Investment in - cleaner engines - Quality control - In-time delivery - Trucks for - specific - product? - Other road - users - Neighbours - General public - End - customers - Traffic police - etc - Vehicle - emissions - Complaints - Increase in - investment - costs - Decrease in - operation - costs 3. Life cycle perspective control and influence The revised standard addresses control and influence across the life cycle in the clause on operational planning and control, for the logical reason that a core element of the life cycle is the activities of the organisation itself. QD04-103-01 4 22/10/2015
The text specifies that organisations should adopt a life cycle perspective in relation to: Determining environmental requirements for procurement of goods and services Addressing environmental requirements in the design and development process of its products and services, considering each stage of the life cycle Communicating relevant environmental requirements to external providers, including contractors Providing information about potential significant environmental impacts during the transportation or delivery of the goods or services and during use and end-of-life treatment and final disposal of the product Clauses also require the organisation to control or influence outsourced processes. The requirements to address procurement should be applied only "as appropriate". This should not be seen as a way of avoiding the requirements but rather as an encouragement to address the environmental impacts at different stages of the life cycle, where this can add value to the organisation, for instance through improving product quality, security of supply or reduced costs. These benefits, together with reduced burdens, can be shared by partners throughout the life cycle. Preparation needed in your organisation: The organisation should consider how, or if they can control or influence activities outside the scope of their own EMS. Detailed planning to address aspects and risks in the life cycle can be accomplished in the planning stage. 4. Integration into core business processes "Senior management can effectively address its risks and opportunities by integrating environmental management into the organsation s business processes, strategic direction and decision making, aligning them with other business priorities, and incorporating environmental governance into its overall management system." This is a very strong guidance that an EMS should not be a stand-alone system. Appropriate environmental practices and behaviours should become part of mainstream business and operational processes and culture, rather than afterthoughts. There are specific requirements with senior management being assigned responsibility to ensure that integration into business happens. Actions for the achievement of objectives should be integrated into business processes and the output of the management review should include any necessary recommendations for improving the integration of EMS with other business processes. Organisations will need to consider how other business processes and functions are able to influence its management of its aspects. This could range from functions with direct control of environmental aspects to those with the capability of influence or managing people in some way connected with aspects. QD04-103-01 5 22/10/2015
Preparation needed in your organisation: Organisations will need to give careful consideration to how they improve the integration of environmental management into business processes. To demonstrate the linkage between significant environmental aspects and those functions and individuals who are best placed to address the associated risks and opportunities, a functional mapping exercise can be a good starting point. Example: Organisations can think about how they have integrated elements of environmental management into core business already. These could be at strategic or operational level What other business functions support environmental management? Are there individuals in specific roles who provide support? Are other management systems used? What further integration would be beneficial? What are the barriers to this? What are the implications for other discipline systems such as Health and Safety (H&S), quality, energy management etc? Environmental management meetings, staff training etc 5. Environmental sustainability Key recommendations of the Future Challenges study were for ISO 14001 to relate environmental management more clearly to the planet, or environmental pillar of the concept of sustainability. It also recommended aligning language with that of the social responsibility standard ISO 26000. It emphasises that environmental management is more than the commitment to the prevention of pollution. There are other additions to the text, including the concept that environmental conditions with the potential to affect the organisation need to be identified and addressed. This aligns with the focus of ISO 26000 on climate change adaption. Also, the concept of risks and opportunities can be related to, for example, resource efficiency and associated operational cost savings. Preparation needed in your organisation: Organisations should identify for themselves the need for, and benefit of broadening their approach to sustainability through consideration of their context, needs of interested parties and related risks and opportunities. QD04-103-01 6 22/10/2015
Once a strategic approach, aligned with broader business goals, has been established, the EMS can be adapted to address any new requirements, which could include: New policy commitments Objectives focussed on specific areas within the environment pillar of sustainability Processes to evaluate risks and opportunities and develop new operational approaches Monitoring related aspects and impacts Example Your company has a strategic objective to reduce costs, which can be used as a driver for resource efficiency: Objectives and targets Modified procedures Awareness and training Involvement of other functions Monitoring 6. Leadership The new common text imposes a range of new responsibilities on senior management, which is now defined as: A person or group of people who direct(s) and control(s) an organisation at the highest level Senior management must now demonstrate leadership and commitment with respect of the environmental management system by : Communicating the importance of effective environmental management and of conforming to EMS requirements Directing and supporting staff to contribute to the effectiveness of the EMS Supporting other relevant management roles Promoting continual improvement Senior management must also take accountability for the effectiveness of the EMS. They also have to ensure that certain things are done (which implies that they can be delegated): Environmental objectives are established Environmental management system requirements are integrated into the organisation s business processes Resources are provided for the EMS The EMS achieves its intended outcomes QD04-103-01 7 22/10/2015
Preparation needed in your organisation: In smaller organisations with an EMS, top management may be heavily involved in the EMS already. For larger organisations it will be necessary to: Ensure that top management is aware of their new responsibilities Modify EMS processes to engage them: o o o Communications top management must be seen to participate and lead in environmental communications Roles, responsibilities and authorities must be established, clearly setting out the new responsibilities for senior management Management reviews these must be effective, with genuine participation by senior management Utilise other management processes effectively: o Management meetings ensure that environment is given proper attention by top management o Staff reviews ensure that managers include relevant environmental responsibilities o Reporting processes ensure that these are used frequently to inform senior management 7. Competence Competence requirements for many roles will be more demanding. The one important and completely new requirement is to evaluate the effectiveness of competence and improvement actions. The competence clause is also more explicit regarding the types of action that needs to be taken to improve competence, referring to: The provision of training Mentoring Re-assignment of currently employed persons Hiring or contracting of competent persons Overall, the revised standard introduces competence requirements that were not explicitly referenced in the 2004 version, including: Strategic thinking in relation to the environment and the direction of the business Appreciating stakeholder concerns The broader principles and practices of Environmental Sustainability Ability to integrate business processes Addressing the life cycle, from the perspective of procurement and design QD04-103-01 8 22/10/2015
Preparation needed in your organisation: It is essential that an organisation understands the competence of its staff. Organisations will need to assess the situation, by reviewing competence needs and competence levels, and where necessary establishing improvement actions. Potentially some of the needs can be met by hiring external expertise. However, the organisation s own staff will need to be capable of dealing with business process integration, ensuring senior management support and developing an environmental sustainability strategy. It should be noted that the broader requirements for internal auditing may encourage some large organisations to utilise their internal corporate risk auditors for elements of EMS auditing. These auditors will need to be competent to audit environmental aspects and their management. 8. Compliance obligations and demonstration of compliance status ISO 14001:2015 has a clause requiring organisations to determine and have access to compliance obligations related to its environmental aspects. The revised standard uses Compliance Obligations, to embrace both mandatory and voluntary requirements that an organisation has to fulfil. This gives equal standing to legal obligations and those other commitments which the organisation adopts. These could include, as defined, in the note to the new definition of compliance obligations, organisational and industry standards, contractual relationships, codes of practice and agreements with community groups or non-governmental organisations. Once the compliance obligations are identifies, the organisation is required to ensure they are taken into account when establishing the EMS and must also establish a process for evaluating conformity with them. Preparation needed in your organisation: Organisations will need to expand their approaches to identifying legal compliance requirements to include other voluntary obligations, and document them in the same way. Organisations should review their operational control and performance evaluation process to ensure they provide adequate information on the status of conformance with compliance obligations, so that: Preferably, potential non-conformance can be identified in advance Actual non-conformance is identified quickly so that actions can be planned to rectify the situation If appropriate, regulatory authorities or other interested parties can be informed of the nonconformance and, if necessary, approve the actions proposed. QD04-103-01 9 22/10/2015
9. Other important changes are to: Define indicators for monitoring progress towards measurable objectives Determine the need of communications and when and how to deliver them Ensure communications are consistent with information generated by the EMS and reliable Ensure its communication processes enable individuals to contribute to continual improvement Address change management Take into account reasonably foreseeable emergency situations when identifying environmental aspects Ensure that the response to an emergency situation is proportionate Determine what needs to be monitored, when and how Communicate internally any changes to the EMS Enhance environmental performance by improving the EMS As part of the course Safe Track Associates Limited received the electronic IEMA STS EMS Gap Analysis Tool to assist with the planning, management and transition to the updated standard. An important element of this is to identify elements of an existing EMS that will not meet the requirements of ISO 14001:2015. It also helps: Identifying any areas of weakness in the EMS Considering how EMS processes can be made more effective and efficient and Assessing the benefits that the EMS delivers Anna Menschikow BSc Health, Safety and Quality Co-ordinator QD04-103-01 10 22/10/2015