ISO 14001:2015 Comparison and Guidance Matrix - · PDF fileThis ISO 14001:2015 Comparison and Guidance Matrix has been written ... A.1.1 An on-site¥ stage 1 “Gap Analysis” shall

© URS 2015 Page 1 of 28

ISO 14001:2015

Comparison and Guidance Matrix

© URS 2015 Page 2 of 28

Contents

1.Introduction Page 3

2.Terminology Pages 2-5

3.URS Expectations Page 5

4.URS Strategy For Certification Transition Page 6-9

5.Comparison and Guidance Matrix Pages 10-28

© URS 2015 Page 3 of 28

1. Introduction

This ISO 14001:2015 Comparison and Guidance Matrix has been written with the aim to assist clients and auditors to understand the URS approach and interpretation of the revised standard. Of course there will be minor differences in interpretation between Certification Bodies but URS needs to have a common approach so that clients can have confidence in our auditors and how they should interpret the standard. This document is not a prescriptive one because client systems have to be developed to suit their own needs but if the requirements are fulfilled in whatever way the client chooses, then certification will be recommended. In this document we simply interpret the standard so that those who do not fully understand the language used by the standard, have some guidance in how to implement the requirements.

2. Terminology

Much of the terminology in the 14001 is the same as ISO 9001 but one that is new is life cycle which is defined as ‘consecutive and interlinked stages of a product (or service) system from raw material acquisition or generation from natural resources to final disposal.’

Throughout the standard, there are some words and phrases that can cause confusion or are difficult to understand. The following interpretations are URS’ interpretations but are hopefully useful in understanding what the standard requires.

A. Documented Information A.1 There are many references to Documented Information throughout the standard. Where the standard states that Documented Information shall be established and maintained then:

A.1.1 Means that a description of an activity (process) needs to be documented. It also needs to be maintained (document control) to ensure it is up to date. A.1.2 The format of the description of a process is entirely up to the client but should contain sufficient information to provide enough guidance to (i) satisfy the requirements of the standard and (ii) ensure the effective implementation of the activity.

A.2 There are also reference to documented information being retained. This means that records are to be kept to provide evidence that activities were performed (correctly or incorrectly).

© URS 2015 Page 4 of 28

B. Determine B.1 There are many references to Determine Information throughout the standard. Where the standard states Determine information, then:

B.1.1 This means that the client has to understand something and provide ‘documented information’ of their understanding. For example, the standard requires that the client ‘determines’ the processes needed for the environmental management system and their application …. This means that the client has to identify all the processes within the EMS and provide some form of documented ‘overview’ of this. This could be in the form of a process map. The need for, and the content of the documented description of each process needs to be decided by the client and to help make that decision, rather than the client just documenting everything, there is a process that the client goes through to make the decision ‘Do we need to produce a ‘documented’ process? If yes, how much detail should there be?

C. Issues

C.1 There are many references to Issues throughout the standard. Where the standard states issues, then:

C.1.1 This means ‘an actual or potential threat’ to the effective implementation and control of one or more activities or an actual or potential threat to the client’s ability to manage an EMS that meets the requirements of the standard and any regulatory and statutory requirements.

D. Understanding the organisation and its context D.1 There are references to Understanding the Organisation and its Context in the standard. Where the standard states Understanding the Organisation and its Context, then:

D.1.1. The client demonstrates compliance to this clause (4.1), in a number of ways.

Firstly, if the client produces an organisation chart or similar which show the functions and lines of reporting – step 1.

A process map (see Determine above) would demonstrate an understanding of the processes (core business and management support) and their interactions – step 2

© URS 2015 Page 5 of 28

In addition, if the client conducts a risk assessment, it will clearly show a true understanding of their processes and threats/opportunities – step 3. (Aspects table could be structured to show interested parties with scores for effect on employees (health and safety related, company concerns e.g. pollution incidents that affect image environmental reporting) community concerns (nuisance related usually e.g. litter noise bright lights at night)

E. Environmental Objectives and Planning to Achieve Them

E1Now clearly states about compliance obligations so for example if targets have been set for the packaging regulations or climate change agreements these should appear in the objectives and planned to achieve them. E1.1 So objectives should show allocation of resource, who will be responsible, completion dates and should cover protection of the environment as well as prevention of pollution

3. URS Expectations

1. There is a need for clients to revisit their aspects table to show not only risks to pollute but to also now to protect the environment and also there may be positive impacts on the environment.

2. Legal compliance checks now need to be much more thorough and show evidence of what’s been checked the legal register needs to be company specific rather than a simple list of current statutes.

3. Objectives and targets are required to be managed more transparently showing allocation of resources and proper project management eg

4. Waste reductions through recycling programmes need to show measurables either waste volumes or weights. 5. Operational procedures should clearly show process controls for water treatment, waste management etc. 6. These are some of the key areas but check through our guidance document as the above is by no means exhaustive.

© URS 2015 Page 6 of 28

4. URS Strategy for Certification Transition

A) Transition Process Steps

A.1 Transition for Existing Registered Clients – Option A:

A.1.1 An on-site¥ stage 1 “Gap Analysis” shall be performed by the Lead Auditor for 0.5 days at the next scheduled surveillance. The purpose of the GAP Analysis is to determine whether the client’s existing system addresses the new requirements of the standard. Formal notes of the GAP Analysis shall be recorded in the client report. A.1.2 Should the GAP Analysis be successful, arrangements shall be made to conduct the formal audit to the 2015 version of the standard at the subsequent surveillance+, normally 12 months later. A.1.3 Upon receipt of the audit referenced in A.1.2+ and subject to closure of any concerns raised, a new certificate shall be issued to the 2015 version of the standard.

Important Notes: In order to allow a transition process which minimizes the administration and maintains effective control via URS’ internal workflow system (CMS), please note:

1. When the auditor contacts the client for the next scheduled surveillance to ISO 14001: 2008, he/she shall ask the client do

they wish the GAP Analysis visit to be conducted for the upcoming surveillance.

2. If the client does request the above option, the auditor shall contact the URS Local Office and an extra half day shall be

added to the Job Instruction (by means of a special visit) and at this point the half-day GAP Analysis invoice shall be issued

to the client (for example in the UK this fee will be £325 + VAT).

3. The half –day visit will be conducted either the day before, or day after the planned surveillance visit – the effectiveness of

the GAP Analysis visit shall be commented on in the normal Client Report – which is left with the client – under the section

Auditor Summary.

Any findings resulting from the GAP Analysis will be recorded under the Comments Section of the report as Potential Non-Compliances (PNC) or Opportunities for Improvement (OFI).

4. Should the auditor and client agree that the GAP Analysis and findings are minor to allow the transition visit to proceed, then,

unless otherwise agreed, this will be performed at the following routine surveillance (usually 12 months later) for the existing

certification, with no further cost – i.e.: it shall be part of the next annual certification and surveillance fee.

5. Under option (4) above, the auditor shall again comment in the Client Report, under the section Auditor Summary, whether

the client can be upgraded to the new version of standard (noting any findings to the new version of the standard, at this

visit, may be recorded as Concerns – Non- Compliances (NC) and/or Discrepancies (D).

© URS 2015 Page 7 of 28

6. Once the report has been reviewed by the Local office and any Corrective Actions etc., are accepted, then a new Certificate

of Registration shall be issued to the 2015 version of the standard.

6.1 In order to ensure the Certification cycle and certificate life are maintained – any new revised Certificate of Registration issued to the new standard shall reflect the current certificate expiry date. 6.2 The above means that should the Client transfer within the life of their current ISO 14001:2008 certificate, the new Certificate of Registration (to ISO 14001:2015) shall have the same expiry date as that of the “old” ISO 14001:2008 certificate.

Option A Process Summary:

1. Client agrees to an additional 0.5 day to the scheduled Surveillance Audit.

2. A pro-forma invoice will be issued - £325* + VAT.

3. The auditor completes the 0.5 day GAP Analysis Review either the day before or after the scheduled Surveillance Audit.

4. The auditor leaves a report with the client.

5. The client shall submit Corrective Actions to URS for review (if recommended by the auditor).

6. The next planned Surveillance Audit will then be completed without additional time required. ISO 14001: 2015 will be

audited during this Audit.

7. If successful, or when Corrective Actions and Evidence for any concerns raised during the Surveillance Audit have been

successfully “closed-out” a certificate will be issued to ISO 14001: 2015.

8. Normal certification cycle resumes.

A.2 Transition for Existing Registered Clients – Option B:

A.2.1 If a client determines a GAP Analysis visit is required before their next surveillance is due, then the client should request this in writing to their Local URS Office. A.2.2 On receipt of the written request from the client, the Local URS office shall raise a Special Job Instruction for the client’s nominated auditor. A.2.3 The steps as stated in A.1.2 and 3 above, will then follow as indicated.

Option B Process Summary:

1. Written request has been received from the client.

2. A pro-forma invoice will be raised for £325* + VAT.

© URS 2015 Page 8 of 28

3. The auditor will schedule a GAP Analysis Review with the client.

4. The auditor leaves a report with the client

5. The client shall submit Corrective Actions to URS for review (if recommended by the auditor).

6. The following planned Surveillance Audit will then be completed without additional time required. ISO 14001: 2015 will

be audited during this Audit.

7. If successful, or when Corrective Actions and Evidence for any concerns raised during the Surveillance Audit have been

successfully “closed-out” a certificate will be issued to ISO 14001: 2015.


A.3 Transition for Existing Registered Clients – Option C:

A.3.1 If a client determines a GAP Analysis is required before their next surveillance is due and the client would like to have their transition visit also before their next surveillance is due, then: A.3.1.1 Then the steps stated in A.2.1 and A.2.2 shall apply. A.3.2 However, after the GAP Analysis visit and report, the auditor and client shall agree a mutually suitable date for a one-day transition audit to be conducted. A.3.3 A special visit shall be raised and associated invoice, the fee being based again on the normal fees stated in the accepted quotation for the existing certification. A.3.4 On a satisfactory transition visit and closure of any Corrective Actions etc., a new Certificate of Registration shall be issued to the new 2015 version of the standard.

Important Notes: The same rules shall apply as those stated in Important Notes above – items 6.1 and 6.2. Option C Process Summary:

1. Written request has been received from the client.

2. A pro-forma invoice will be raised for £825¥* + VAT.

3. The auditor will schedule a GAP Analysis Review this will be for 0.5 day.

4. Corrective Actions shall be submitted to URS for review (if recommended by the auditor).

5. The auditor schedules the Special Audit*. The Audit Plan will be to the ISO 14001: 2015 version of the standard.

6. The Transition audit will be conducted at a mutually convenient date to the auditor and client.

7. If the transition audit is successful, or when any Corrective Actions and Evidence for concerns raised, during the Transition

Surveillance Audit have been successfully reviewed, a certificate will be issued to ISO 14001: 2015

© URS 2015 Page 9 of 28


A.4 Summary Notes regarding Transition for Existing Clients: It cannot be stressed enough, that the changes in approach to the 2015 version of the standard are significant and that the most important elements of the revisions are:

A.4.1 Have a meaningful Process flow/Map. A.4.2 Conducting Risk Assessments for the stated Processes. A.4.3 Measuring the effectiveness of the Processes. Whilst the stated Transition Option process for existing clients will not vary, please be aware, that the indicated GAP Analysis visit and/or transition visit man-day durations stated above, assume that existing clients will maintain their existing systems, as currently registered and update their systems to address A.5.1, A.5.2 and A.5.3 above.

1. Should a client determine a full re-write of their system is required then the transition visit may include more time than

currently scheduled or indicated above.

2. All the options above must be completed before the end of the transition period – i.e.: 3 years after publication of the

2015 version of ISO 14001. If not, any current ISO 14001:2008 certificate will be invalid.

3. ¥ Under extenuating circumstances the GAP Analysis Review Visit can be performed off-site, however, the stated fee

will still apply.

A.5 Transition for NEW Registered Clients:

A.5.1 Any Client that is not currently ISO 14001, but wishes to be registered, may apply directly to the 2015 version of the standard, once it is formally published. Under such circumstances, the existing stage 1 and stage 2 process shall apply as currently stated. A.5.2 Any Client that is not currently ISO 14001, but wishes to be registered to the 2008 version of ISO 14001, may do so, but applications for this version of the standard shall not be accepted after 2 years from the published date of the 2015 version of the standard. After the 2 year period has elapsed, applications from clients must be to the 2015 version of ISO 14001.

© URS 2015 Page 10 of 28

4. Comparison and Guidance Matrix (ISO 14001:2015 versus ISO 14001:2004)

ISO 14001:2015

Clause

ISO 14001:2015 Requirement

ISO 14001:2004

Clause

What the standard requires What should clients do? What does URS have to do?

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. 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. salmon river

See evidence that an evaluation has been carried out on their current issues

4.1

Understanding

the organization

and its context

The organization shall determine:

a) the interested parties that are relevant to the environmental management system;

b) the relevant needs and expectations (i.e. requirements) of these interested parties;

c) 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 IPPC

4.2

Understanding

the needs and

expectations of

interested parties

The 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: IPPC 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

system

The organization shall determine the boundaries and applicability of the environmental management system to establish its scope. When determining this scope, the organization

Scope now should be determined usually in a top tier policy document or in preparatory environmental review (PER)

Auditor will need to review the documented information and see that it has been circulated or made available to their interested parties

© URS 2015 Page 11 of 28

ISO 14001:2015

Clause


ISO 14001:2004

Clause


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.

See 4.1 Needs to be documented hence suggestion to put in a top tier manual or similar

4.4

Environmental

management

system

To 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

More involvement from people at the top Reviews (these don’t have to be one meeting any more mentioned in guidance)

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

© URS 2015 Page 12 of 28

ISO 14001:2015

Clause


ISO 14001:2004

Clause


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.

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

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

Policy

Top 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

Main change here is protection of the

Policy should documented and auditor therefore should review this against 5.2 And note in his audit trail its current status (issue date etc)

© URS 2015 Page 13 of 28

ISO 14001:2015

Clause


ISO 14001:2004

Clause


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

environment not just prevention of pollution Requirement to commit to any other business requirements related to the environment

5.3

Organisational

roles,

responsibilities

and authorities

Top 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 responsibilities

Auditor 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

© URS 2015 Page 14 of 28

ISO 14001:2015

Clause


ISO 14001:2004

Clause


6.1.1

General

The 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

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

© URS 2015 Page 15 of 28

ISO 14001:2015

Clause


ISO 14001:2004

Clause


knowledge and competence of people and the degree of control currently

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. 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.

6.1.3 Compliance

The organization shall:

The usual way in the past was to have a Auditor must check there is evidence

© URS 2015 Page 16 of 28

ISO 14001:2015

Clause


ISO 14001:2004

Clause


Obligations 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.

legal register this recognises 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

or IPPC where permit conditions require improvements

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)

6.1.4

Planning action

The organization shall plan:

a) to take actions to address its:

1) significant environmental aspects; 2) compliance obligations;

b) risks and opportunities identified in 6.1.1; how to:

1) integrate and implement the actions into its environmental management system processes (see 6.2, Clause 7, Clause 8 and 9.1), or other business processes;

2) evaluate the effectiveness of these actions (see 9.1).

When planning these actions, the organization shall consider its technological options and its financial, operational and business requirements.

Actions may not be improvements in an objectives and targets sense but may be to monitor the process to see if the process remains in its parameters then the aspect significance could diminish

Dosing/water treatment is a good example of 2) to meet a consent to discharge again a process control

So the above would become controls within the ems

BATNEEC is considered here i.e. if the actions are too costly and not in the best interests business wise then the company can opt out

Auditor should ask for evidence of planning activities for the management of significant aspects and meeting legal obligations

6.2

Environmental

objectives and

planning to

achieve them

6.2.1 Environmental

objectives The organization shall establish environmental objectives at relevant functions and levels, taking

This whole area is now much more prescriptive and requires SMART targets

Auditors should check for evidence of documented objectives

© URS 2015 Page 17 of 28

ISO 14001:2015

Clause


ISO 14001:2004

Clause


into account the organization’s significant environmental aspects and associated compliance obligations, and considering its risks and opportunities. The environmental objectives shall be: a) consistent with the environmental policy; b) measurable (if practicable); c) monitored; d) communicated; e) updated as appropriate.

The organization shall maintain documented information on the environmental objectives.

The requirements are self explanatory

Targets need to be tracked and if something changes then it should be communicated

Transparency again of actions and progress

Needs to be documented

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

Resources

The 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 determined

Auditor should check for adequate resourcing (can be by interview)

7.2

Competence

The organization shall: a) determine the necessary competence of

person(s) doing work under its control that

This is saying you need to go through the process of formally looking at key tasks and

Auditor needs to check for Competence evaluations

© URS 2015 Page 18 of 28

ISO 14001:2015

Clause


ISO 14001:2004

Clause


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.

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

7.3

Awareness

The 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

General

The organization shall establish, implement and maintain the processes needed for internal and external communications relevant to the environmental management system, including:

This is recognising the development of various means of communication more prescriptive self explanatory. Requires process approach

Communications should be audited by looking for evidence of legal compliance, Supply of data/information to clients on request

© URS 2015 Page 19 of 28

ISO 14001:2015

Clause


ISO 14001:2004

Clause


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 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

7.4.2

Internal

Communication

The 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.

7.4.3

External

Communication

The 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

© URS 2015 Page 20 of 28

ISO 14001:2015

Clause


ISO 14001:2004

Clause


7.5.1

General

The 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.

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

7.5.2

Creating and updating

When 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 implied

Essentially requires the auditor to see all documented information is suitably controlled

7.5.3

Control of documented information

Documented 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,

Now refers to documented information rather than documents Covers information security. Recognises some media deteriorate over time But controls remain largely unchanged

© URS 2015 Page 21 of 28

ISO 14001:2015

Clause


ISO 14001:2004

Clause


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.

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 Operation

8.1

Operational

planning and

control

The 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

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. WEEE and similar legislative controls now come into play much more e.g. End of life vehicle controls etc.

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.

© URS 2015 Page 22 of 28

ISO 14001:2015

Clause


ISO 14001:2004

Clause


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.

Aspects tables therefore cover much more than the factory environment.

8.2

Emergency

preparedness

and response

The 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;

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

© URS 2015 Page 23 of 28

ISO 14001:2015

Clause


ISO 14001:2004

Clause


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.

9 Performance

evaluation

9.1

Monitoring,

measurement,

analysis and

evaluation

9.1.1

General

The 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.

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)

Auditor needs to check for documentary evidence of monitoring and measurement

© URS 2015 Page 24 of 28

ISO 14001:2015

Clause


ISO 14001:2004

Clause


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.

This harks back to EMAS about publicly declaring data (many companies now have statements in their year-end accounts)

Similarly if the company is IPCC they are legally obligated to provide this information-companies were doing this.

9.1.2

Evaluation of

compliance

The 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

General

The 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

© URS 2015 Page 25 of 28

ISO 14001:2015

Clause


ISO 14001:2004

Clause


9.2.2

Internal audit

programme

The 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

review

Top 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;

Change management

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!!

© URS 2015 Page 26 of 28

ISO 14001:2015

Clause


ISO 14001:2004

Clause


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.

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

10 Improvement

10.1 General

The organization shall determine opportunities for improvement (see 9.1, 9.2 and 9.3) and

Not new

© URS 2015 Page 27 of 28

ISO 14001:2015

Clause


ISO 14001:2004

Clause


implement necessary actions to achieve the intended outcomes of its environmental management system.

10.2

Nonconformity

and corrective

action

When 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

Improvement

The 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 impacts

Auditors should look for evidence of the ems improving in such a way that environmental performance has been enhanced.

© URS 2015 Page 28 of 28

Documents

ISO 14001:2015 Comparison and Guidance Matrix - · PDF fileThis ISO 14001:2015 Comparison and Guidance Matrix has been written ... A.1.1 An on-site¥ stage 1 “Gap Analysis” shall