ISO 14001 Briefing Note

CQIChartered Quality Institute

Environmental management systems – DIS 14001: What’s new?2

Introduction

Report published in September 2014 by:International Register of Certficated Auditors, part of The Chartered Quality Institute (CQI), 2nd Floor North, Chancery Exchange, 10 Furnival Street, London EC4A 1ABT: +44 (0) 20 7245 6722 I www.thecqi.org I www.irca.org

Incorporated by Royal Charter and registered as a charity number 259678

Environmental management systems – DIS 14001: What’s new? 3

There will be challenges for those concerned with managing or auditing ISO 14001

Ahead of a revision of ISO 14001 due in 2015, this briefing looks at the principal changes proposed in the recently published Draft International Standard (DIS).The changes incorporated into DIS 14001:2014 can be divided into those arising as a result of the adoption of Annex SL as the underlying framework for the Standard and those arising from the need to update its current environmental-specific content. In respect of the latter, the Standard writers have taken into consideration:

a. the work done within Technical Committee 207 Sub Committee 1 Working Group 5 (TC207/SC1/WG5) to identify future environmental challenges that ISO 14001 may have to face

b. the results of an ISO 14001 customer survey carried out in 2012–13.

During the development of the new revision, a third group of requirements was introduced by WG5. These were considered necessary to supplement the existing core text contained within Annex SL. TC176/SC2/WG24, the technical committee developing the new 9001 quality management system standard, also identified the need to expand on the Annex SL core text during their development process. These respective deviations opened up the potential for inconsistencies between the final published versions of 9001 and 14001. In order to address this, WG5 and WG24 are now working together to close out this possibility.

The previously published IRCA briefing note on Annex SL (available free of charge on the IRCA website, www.irca.org) provides a summary of the contents of Annex SL and sets out the implications of its introduction for all those using management system standards, be they standard writers, management system implementers, auditors or training providers.

The requirements of Annex SL will facilitate the integration of the environmental management system into the organisation’s general strategic, tactical and operational management processes. As a consequence, the environmental management system should not in future be seen as ‘a bolt on’ to business as usual.

Additionally life should eventually become easier for:• Management system standard writers: they will not have to draft the high-level structure, or titles

for clauses, subclasses and parts of the text, as these are ‘given’ in Annex SL. Hopefully, this will lead to shorter development times for ISO standards

• Implementers of multi-discipline management systems: this will simplify both the initial implementation and the ongoing maintenance of such systems as different management system standards will share a high proportion of common requirements.

• Management system auditors, who will have to audit a generic set of requirements common to all those disciplines.

However, in the short term, there will be challenges for those concerned with establishing, implementing, managing or auditing against ISO 14001.

In order to equip auditors to audit successfully against the requirements of the new standard, IRCA is mandating transition training for all IRCA EMS registered auditors. Details will be published shortly however it is imperative that auditors attend an IRCA-approved transition training course as opposed to a non IRCA-approved transition training course.

IRCA is committed to reviewing its core EMS Foundation, Internal Auditor, Auditor/ Lead Auditor and Auditor Conversion courses later this year.


The organisation has to determine the interested parties that are relevant to the EMS.

From ISO 14001:2004 to ISO 14001:2015 – main changesAnnex SL

The proposed ISO 14001 adopts the structure, text, terms and definitions contained within in Annex SL, albeit with some very minor editorial variations.

This briefing now views Annex SL through environmental eyes, and summarises the text that has been added by WG5. It is intended to be read in conjunction with the IRCA briefing note on Annex SL previously referred to.

New clause: Understanding the organisation and its context (4.1)

The intent of Clause 4.1 is to ensure that the organisation has a high-level, conceptual understanding of the important issues that can affect, either positively or negatively, its ability to achieve the intended outcomes of its Environmental Management System (EMS).

Typically an organisation’s issues will fall into one or more of the following categories.

a. external cultural, social, political, legal, regulatory, financial, technological, economic, natural and competitive issues, whether international, national, regional or local.

b. internal characteristics or conditions of the organisation, such as its activities, products and services, strategic direction, culture and capabilities (people, knowledge, processes, systems).

In addition to the core Annex SL text, ISO DIS 14001 adds a requirement that the organisation shall additionally consider environmental conditions that may impact the organisation. For example: climate change, storms and floods, air quality, water quality, land use, existing contamination, natural resource availability, biodiversity, etc.

New clause: Understanding the needs and expectations of interested parties (4.2)

The organisation initially has to determine the interested parties that are relevant to the EMS, and then determine the relevant requirements of those interested parties. There is no expectation however that the organisation shall subsequently comply with all of the relevant interests of relevant interested parties. DIS 14001 coins the term “compliance obligations”. These include:• all relevant legal requirements• all requirements imposed by upper levels in the organisation (for example corporate requirements)• all relevant requirements of relevant interested parties that the organisation decides to comply with.The third bullet is very important, as it clarifies that the organisation has the right to choose which relevant requirements of relevant interested parties it will comply with.

Scope of the EMS (4.3)

To the Annex SL text, ISO DIS 14001 adds other issues to be considered by the organisation when defining the scope:a. organisational units, functions and physical boundariesb. its activities, products and servicesc. its ability and authority to exercise control and influence.


EMS (4.4)

To the Annex SL text, ISO DIS 14001 adds a reminder that the main purpose of the EMS is to enhance environmental performance. It also requires the organisation to consider the context (determined in 4.1) when establishing and maintaining the EMS.

New clause: Leadership and commitment (5.1) To the Annex SL text, ISO DIS 14001 adds another, and very important, way that top management has to demonstrate its leadership and commitment, namely by taking accountability (new term in ISO 14001) for the effectiveness of the EMS.

Environmental policy (5.2) To the Annex SL text, ISO DIS 14001 adds a third commitment that needs to be included in the policy: to protect the environment, including prevention of pollution.

Note that the policy now has to be communicated not only to employees, but also to “all persons working under the control of the organisation”.

Roles and responsibilities (5.3) No major additions to the Annex SL text.



New clause: Actions to address threats and opportunities (6.1)

This clause prompted a lengthy discussion before WG5 reached a consensus. It took a lot of time to answers key questions such as: • What is the relationship between clauses 6.1, 4.1 and 4.2?

• The Annex SL definition of risk permits risk to have positive as well as negative outcomes. Is it appropriate to view risk in this way when considering environmental impact? Can we live with the definition of risk as being the effect of uncertainty on results?

• What is the relationship between risk and the identification of significant environmental aspects?

• Is it correct to associate risk with compliance obligations?

It was finally agreed that DIS 14001:2014 would split clause 6.1 into five sub-clauses:

• General requirements, to be contained within 6.1.1

• Requirements relating to the identification of significant aspects to be contained within 6.1.2

• Requirements relating to the identification of compliance obligations to be contained within 6.1.3

(up to here it is similar to the current text of ISO 14001:2004, with almost no Annex SL wording except some general references in 6.1.1)

• Requirements relating to risks associated with threats and opportunities to be contained within 6.1.4

• Requirements related to planning to take action to be contained within 6.1.5.

In 6.1.4, the first part of clause 6.1 of Annex SL comes into play, with the requirement to evaluate risk associated with threats and opportunities related to the context of the organisation (4.1) and the interested parties’ requirements (4.2).

Clause 6.1 introduces requirements that may be seen as describing different risk evaluation processes. The interpretation guidance to this clause (included in the Annex) confirms it is up to the organisation to decide whether it wishes to implement different risk evaluation processes at different organisational levels, or to combine all the risk evaluation requirements in a single process.

Finally, there is a requirement to take action to address:

• significant environmental aspects (6.1.2)

• compliance obligations (6.1.3)

• risks and opportunities (6.1.4).

One of the possible actions is to establish objectives (see 6.2).

Objectives (6.2)

There are a few, but important, additions to the core Annex SL text. These are:

• When establishing objectives, the organisation shall take into account the significant aspects, the compliance obligations and the threats and opportunities

• When defining how results will be evaluated, the organisation shall include indicators to monitor progress towards achievement of objectives

• When defining actions to achieve objectives, the organisation shall integrate those actions into the organisation´s business processes

The Annex SL definition of risk permits risk to have positive as well as negative outcomes.


Support (7)

There are no major additions to resources (7.1), Competence (7.2), Awareness (7.3) and Documented information (7.5) However, it was considered that Communication (7.4) needed further clarification in an EMS. Consequently the sub-clause is considerably expanded and divided into three parts.• General (7.4.1), with a specific requirement on the quality of the communication

• Internal (7.4.2), with a requirement to encourage any person doing work under the organisation´s control to make his/her voice heard in relation to improvement opportunities

• External (7.4.3), with a specific requirement to communicate information on the environmental performance of the organisation

Operational planning and control (8.1)

There is a key addition to the core Annex SL text, namely the introduction of the concept of “life cycle perspective”.

This new requirement requires the organisation to: • determine environmental requirements for the procurement of products and services

• ensure that environmental requirements are considered in the design, delivery, use and end-of- life treatment of products and services

• communicate environmental requirements to suppliers and contractors

• provide information about potential environmental impacts during the delivery, use and end-of- life treatment of products and services

Emergencies (8.2)

This is a sub-clause not included in Annex SL, and which is basically identical to clause 4.4.7 of the current ISO 14001.

The requirement of identification of emergency situations, as part of the first paragraph of the current edition, has been relocated to 6.1.2, identification and evaluation of significant aspects.

Monitoring and measurement (9.1)

There are some important additions to the core text in Annex SL. The DIS stipulates that what needs to be monitored and measured shall be related to operations, compliance obligations, operational controls and progress towards meeting the environmental objectives, using indicators.

In the current version of ISO 14001, the use of indicators is not explicitly required, (though in all probability their use is widespread. Now, this is a clear requirement. The organisation has to define criteria to allow it to evaluate its environmental performance, again through the use of appropriate indicators.

Another key issue is that the organisation has to communicate information internally and externally on its environmental performance, complying, at least, with any applicable compliance obligation. The requirement to evaluate conformity with compliance obligations is still there, and is seen as underpinning the whole standard.

The words “conformity with compliance obligations” also generated lengthy amongst members of WG5; however, consensus was reached that this expression is correct, taking into consideration the definition of “requirement” and “conformity” in the DIS Clause 3. Internal audits (9.2) Management review (9.3) Non conformity and corrective action (10.1) / Continual improvement (10.2) – No major additions to Annex SL text.

Summary The principal clauses, when considered together, form a journey: from 4.1 and 4.2 (as inputs) , 6.1 as the risk analysis process, 8.1 as the operations and 9.1 monitoring and measurement , and, finally 10.2 as the continual improvement. This is a circular process and changes in any of these areas force an organisation to run through another iteration.

• the changes pertaining to leadership will present challenges for many organisations. Top management will in future need to be much more hands on.

There is a key addition to the Annex SL text: introduction of the concept of “life cycle perspective”.


LRQA TrainingLRQA training is committed to supporting clients through the transition to 14001:2015. We have designed a suite of public training and in-company facilitated training courses to help organisations understand and implement the changes, and their potential impact.

The potential organisational impact of DIS 14001:2014 is dependent on the organisation and its individual EMS. Factors that will help organisations determine their degree of change against the new ISO 14001 revision include:

a. the maturity and complexity of the existing ISO 14001 system

b. the existence of other certified MSS (such as ISO 9001 or OHSAS 18001)

c. current processes in relation to the environmental impact of its services and products, as well as the organisation’s overall impact on the environment.

Every organisation is unique, so the impact of the revised changes will be individual to that organisation, its people, and its management system.

Among the areas of the standard that have been revised or now contain more specific information on which organisations may need further support, and which our facilitated training will address, are :

a. Increased emphasis on leadership and top management engagement.

b. Performance evaluation: this means that organisations are encouraged to look at their overall environment by incorporating the management system into the strategic thinking of the organisation.

c. The organisation is now required to commit to protection of the environment within its policy – this is a significant shift from the existing version (ISO 14001:2004) and focuses on the prevention of pollution and compliance with legislation.

d. To support the context the organisation needs to pay particular attention to the views of Interested Parties.

The final area of note is that of communication – while this is a part of the existing ISO 14001, organisations are now specifically required to determine what they will communicate, when they will communicate and to whom they will communicate.

LRQA’s proposed next steps for organisations Get a copy of the DIS and understand the impact it has on your organisation and its environmental management system. Also, make sure that environmental managers and internal auditors understand the differences that Annex SL will bring to your EMS and any other MSS in your organisation.

1. Contact your certification body and ensure that they not only understand the DIS, but more importantly, understand what the DIS means to your EMS and wider organisation.

2. Engage your certification body to find out how a gap analysis and training on specific areas of ISO/DIS 14001:2014 can benefit you personally, as well as your organisation.

3. Formalise a transition plan and process, and ensure that top management is involved from the start.

THE BUSINESS VIEW


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Published in September 2014 by:The International Register of Certificated Auditors (IRCA)Part of: The Chartered Quality Institute

Documents

ISO 14001 Briefing Note