After several years of anticipation, the revised version of the ISO 14001 environmental management systems (EMS) standard was published on September 15, 2015. The ISO 14001 revision is part of a broader effort by the International Organization for Standardization (ISO) to update and align all of the specification standards impacting the management of Environmental, Energy, Health, Safety, and Quality (EEHSQ) issues. While revisions to ISO 14001 are the first to be published, other updated EEHSQ management systems standards are expected over the next two to three years.
The objectives of this ISO 14001 revision effort included making structural changes in accordance with a model that will impact all new ISO standards, addressing recommendations from an ISO technical committee on future challenges to EMS, and ensuring adherence to the basic principles of ISO 14001 (which include continual improvement).
What Do the Changes Entail?
The revised ISO 14001 standard encompasses two types of changes. The first involves a significant overhaul of the clauses to follow a new organizational structure that will ultimately impact all ISO standards. To clarify, the revised version of the ISO 9001 standard (currently nearing final stages) and new ISO 45001 standard (currently in development and intended to replace OHSAS 18001) are organized in accordance with the new structure. The Plan-Do-Check-Act model is retained in the new structure for all management system standards, but the clauses are organized to facilitate implementation of integrated systems.
The second overall change involves a new set of themes that are embedded throughout the standard in multiple locations. From a high-level perspective, one can observe that there is more emphasis on environmental protection, performance improvement, and incorporation of sustainability themes within the EMS. The emphasis on sustainability is readily apparent from the mission statement of the Technical Committee that oversaw development of the new ISO 14001 standard.
ISO TC 207/SC1 Mission Statement
We are responsible for standardization in the field of environmental management systems to support the achievement of sustainability.
Our focus is to develop and maintain standards in the field of environmental management systems that meet stakeholder needs, are market based and support sustainability.
We are recognized as the world leader in the development of environmental management system standards that support sustainability.
Our standards are recognized nationally and internationally by users and other stakeholders as the EMS standards of choice.
The Structural Changes
The new high level structure has seven main areas, each with sub-elements that are intended to define how practices and procedures under a specific discipline (e.g., environmental, quality, occupational health and safety) are implemented.
As previously discussed, ISO is incorporating the new high-level structure into all of its management system standards and the ISO 14001 standard is no exception. So how are the new sections of the high level structure being incorporated into the ISO 14001:2015 standard and how is the resulting content different from that of the ISO 14001:2004 standard?
- Context of the Organization. This section acts as springboard from which organizations can begin to form and develop their EMS. Gaining an understanding of how the organization’s key environmental conditions, external issues (such as legal, social, political, etc.), and internal conditions (such as products/services, culture, and strategic direction) interact is crucial to determining the functionalities and goals of the EMS. Through this analysis, the organization can identify needs and expectations of interested parties —whether it be sustainability initiatives of a primary customer, concerns of a local community, or environmental compliance obligations —that should be accounted for in the EMS. Ultimately the determination of organizational context will lead to defining the scope of the EMS, which should reflect which elements the organization would like to influence and has the authority to influence with the EMS.
The ISO 14001:2004 standard provides some structure and guidance on how to determine the context of the organization in an appendix to the standard as well as scattered throughout a variety of sections. The structure of the new ISO 14001:2015 standard presents these tasks in a more focused manner as well as placing additional emphasis on evaluating internal and external elements that could affect the outcomes of the EMS.
- Leadership. This section marks not only a change in the structure of the standard but also the introduction of a theme that was absent in the ISO 14001:2004 standard. Several responsibilities have been bestowed upon top management with the inclusion of this section. An emphasis is placed on top management demonstrating visible support for the EMS by being held accountable for the effectiveness and performance of the EMS, ensuring that the resources necessary for sustaining the EMS are available, and promoting continual improvement. Organizational roles, responsibilities, and authorities are also discussed in this section.
Another significant departure presented in this section from the old standard pertains to the commitments that must be included in an organization’s environmental policy. The commitments of the old standard have been reworked to be heavily focused on protection of the environment and continual improvement of environmental performance, another prevalent new theme in the ISO 14001:2015 standard.
- Planning. This section, similar to the old standard, covers several key components of an ISO 14001 EMS including the evaluation of environmental aspects and significant impacts, legal and other requirements, and objectives and targets. The most notable addition to this section in the new standard is a requirement to consider a life cycle perspective when determining an organization’s environmental aspects and significant impacts. While a life cycle perspective does not require a full life cycle assessment, it certainly adds an extra dimension to the aspect and impact exercise.
The new standard reiterates the necessity of top management involvement by urging organizations to consider its technological options and business requirements when setting environmental objectives with hopes that these objectives can be integrated into an organization’s business operations. This notion gets rolled up in the new standard’s ‘Planning action’ clause that requires organizations to formulate action items to address significant environmental impacts, compliance obligations, and possible risks and opportunities.
- Support. The Support section of the new standard includes requirements for communication and documentation, as well as competence and awareness (which were derived from the ISO 14001:2004 standard’s ‘Competence, training, and awareness’ clause). With the Competence subsection, we see another instance of the emphasis on environmental performance in the new standard. The new standard requires sufficient training for any individual that can affect the organization’s environmental performance, while the old standard required training for individuals who could cause a significant environmental impact.
Communication requirements have been augmented and made more specific compared to the old standard. For example, the organization’s internal communication process must allow for fluid communication between all levels of the organization regarding changes to the EMS and each individual’s ability to contribute to continual improvement. The old standard largely did not differentiate between internal and external communication.
- Operation. This section encompasses the ‘Organizational planning and control,’ formerly known as ‘Operational control,’ and ‘Emergency preparedness and response’ elements. Two prevalent new themes make appearances in this section – environmental performance and life cycle perspective. The scope that an organization must consider when implementing controls on processes has been expanded to include compliance obligations, further emphasizing environmental performance. Planned changes must be reviewed to determine the appropriate controls, and unintended changes must be reviewed for controls to minimize any adverse effects. With respect to life cycle thinking, organizations must now consider controls for the procurement of products and services and consider during the design process the life cycle effects of products and services on environmental obligations.
- Performance Evaluation. A common trend throughout the ISO 14001:2015 standard is the inclusion of more concrete and specific requirements, as exemplified in the clause covering monitoring and measurement. The old standard was generally vague in its requirements for monitoring environmental performance and calibrating the necessary equipment. Not only does the new standard specify what should be monitored and measured, it also introduces the concept of implementing ‘indicators’ to track environmental performance.
Although the recommended internal audit process was mostly unchanged in the new standard, management review now includes a more in depth look at the various components of the ISO 14001 EMS. Elements such as risk associated with threats and opportunities, whether continual improvement has been achieved, and nonconformities and corrective actions must be discussed and considered in determining the direction of the organization.
- Improvement. The last section of the high-level structure reflects a key theme of the new ISO 14001:2015 standard. While the old standard relies upon preventive action to minimize nonconformities, the new standard enhances the corrective action process such that a cohesive EMS can affect preventive action. Essentially, during the corrective action process, an organization must determine if a similar nonconformity exists or could potentially occur and proceed with the necessary steps to eliminate these causes. The new standard is wrapped up nicely with a closing clause mandating that the EMS be continually improved in order to enhance environmental performance.
The New Themes
One might conclude that the new themes are not truly new at all but instead represent a restatement of underlying objectives in previous versions of the standard. That view would be especially true for organizations with a robust EMS and sustainability initiatives already in place. Those organizations may not have as much work to accomplish to align with the revised ISO 14001 standard. For organizations with a less robust existing EMS, the realignment will take longer.
In any case, the new themes are intended to foster more emphasis on certain key topics relative to the existing ISO 14001 standard, as noted in the table below. The clauses of the revised ISO 14001:2015 standard where the changes are most impactful include Context, Leadership, Planning and Operation.
How Should a Company Prepare?
Most organizations should expect to expend at least a modest level of effort in reconfiguring their existing EMS to align with the new standard. Important tasks include the following:
- Gap Analysis - Conduct a gap analysis and establish a development plan for aligning current EMS procedures with the new organizational structure and underlying themes. Particular emphasis should be given to assessing how new themes can be incorporated in the following EMS areas: Context, Leadership, Planning and Operation.
- Life Cycle Perspective Evaluation - Enhance the aspects/impacts evaluation process to ensure that a life cycle perspective is reflected, particularly in the Planning and Operation areas.
- Risk Evaluation - Establish a risk evaluation process to prioritize how environmental issues are addressed. Ideally, this should be done in conjunction with the revised aspects/impacts procedure.
- Management of Change Process Development - Establish a management of change process to ensure that the organization maintains an acceptable level of risk even when changes occur to equipment, processes, and products.
- Supply Chain Engagement - Increase engagement with supply chain partners to enhance environmental management actions. Evaluate how such engagement can help with addressing the life cycle perspective theme within the revised standard.
- Leadership Re-evaluation – Examine internal policies and practices to ensure that senior leadership is obligated to demonstrate visible support for the EMS and assumes responsibility for ensuring its success. This examination should also include ensuring that EMS objectives are incorporated into organizational decision-making processes.
The official transition period for converting to the new standard is three years, meaning that the old ISO 14001:2004 standard will cease to exist after September 2018. In actuality, though, many registrars may not want to issue certificates under the old standard beyond the two-year mark (September 2017) because in those cases the certificate would be valid for only one year (instead of the typical three-year time period).
In general, organizations will likely find it most convenient to convert to the new ISO 14001:2015 standard at the time of their next re-certification. With that said, much depends on the timing of re-certification and the estimated level of effort necessary for re-alignment (coming from the Gap Analysis task noted above). Organizations will find it prudent to reach out to your registrar as soon as possible to discuss transition timing.