The new ISO 14001:2015 standard incorporates several new themes as well as introduces a new organizational structure for environmental management system (EMS) design and implementation. Perhaps the most significant theme is the need to incorporate a life cycle perspective when evaluating environmental aspects and developing operational controls.
Organizations seeking to align with the new standard must determine precisely what that term "life cycle perspective" means for them. On one hand, the standard makes it clear that a formal life cycle assessment (LCA) is not required; on the other hand, however, language in the standard and associated guidance states the each life cycle stage must be considered when addressing EMS requirements. There is an implication that an organization must conduct a technical analysis that in some ways resembles a formal LCA in seeking to conform to the new standard.
What is a "Life Cycle Perspective"?
What does the standard actually say about life cycle perspective? Taking a close look at the relevant language in several areas of the standard and associated guidance reveals why the new provisions may be challenging. These areas are listed and discussed below.
- Aspects Clause – ISO 14001:2015, Section 6.1.2
- Life Cycle Definition – ISO 14001:2015, Section 3.3.3
- Operational Planning and Control Clause – ISO 14001:2015, Section 8.1
- Annex to the ISO Standard: Environmental Aspects – ISO 14001:2015, Section A.6.1.2
- ISO 14004:2015 Implementation Guidelines
The Aspect Clause contains a concise stipulation regarding life cycle perspective with no elaboration on the term itself. The clause reads: "within the defined scope of the EMS, the organization shall determine the environmental aspects of its activities, products, and services that it can control and those it can influence, and their associated impacts, considering a life cycle perspective" (emphasis added). The reader should take note of the language indicating the need to examine aspects that can be controlled or influenced. Thus, the standard implies that an organization should assess its ability to control or exert influence over environmental aspects that may be outside its immediate operational or facility boundary.
Life Cycle Definition
In the definitions section of the standard, the language points to a potentially broad evaluation that includes both upstream and downstream activity. The language reads: "consecutive and interlinked stages of a product (or service) or generation from raw material acquistion or generation from natural resources to final disposal" (emphasis added). This definition aligns with the establishment of boundaries typically associated with a formal LCA.
Operational Planning and Control Clause
Further elaboration on the meaning of life cycle perspective is provided in the Operational Planning and Control clause. There are several stipulations noted, ranging from establishing controls in product development to determining EMS requirements in procurement practices, communicating EMS requirements to contractors, and sharing information regarding environmental impacts related to downstream activity.
Specifically, the language reads: "consistent with a life cycle perspective, the organization shall:
- 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 life cycle stage;
- Determine its environmental requirement(s) for the procurement of products and services, as appropriate;
- Communicate its relevant environmental requirement(s) to external providers, including contractors; and
- 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."
Annex to the Standard: Environmental Aspects – Section A.6.1.2
The Annex to the Standard clearly states that a detailed LCA is not required in order to conform to ISO 14001:2015. But, the emphasis remains on examining upstream and downstream activity for a product or service, which is described as including stages such as raw material acquisition, design, production, transportation and delivery, use, end-of-life treatment, and final disposal. The Annex clarifies that assessing the ability to control or influence any of the life cycle stages is what is needed primarily. The standard remains flexible on how the stages are assessed and how the impacts associated with these upstream and downstream activities should be incorporated into the EMS.
ISO 14004:2016 Implementation Guidelines
The ISO 14004:2016 Implementation Guidelines provide additional clarification on how a life cycle perspective should blend into an existing environmental aspects evaluation. The Guidelines emphasize that the organization should focus on what it can control or influence over the spectrum of stages in a product or service. The Guidelines mention several important factors to consider:
- Stage in the life cycle of the product or service
- Degree of control or influence over any life cycle stages
- Life of the product
- Influence on the supply chain
- Length of the supply chain
- Technological complexity of the product
Putting Life Cycle Perspective into Action in an EMS
There are two important steps in adopting a life cycle perspective in evaluating environmental aspects and developing operational controls: 1) considering all life cycle stages that can be controlled or influenced, and 2) determining which aspects from any stage need to be addressed.
There are various supply and value chain models that would be suitable for framing an analysis of life cycle perspective. One environmentally focused framework for addressing the required life cycle perspective is to draw from categories specified in the Corporate Value Chain (Scope 3) Accounting and Reporting Protocol developed by the World Resources Institute and World Business Council for Sustainable Development (see figure below). The Corporate Value Chain Protocol comprises eight upstream and seven downstream categories. While the protocol pertains to Scope 3 greenhouse gas emissions, the categories listed actually represent all stages of a product or service life cycle. As such, they can used to evaluate other environmental impacts beyond carbon emissions.
While the Corporate Value Chain Protocol can be a guide to consider all life cycle stages, the key is for an organization to determine which aspects within a category are sufficiently relevant to be addressed in the EMS. Ultimately, the aspects within any relevant category should be subject to the same process used to evaluate an organization's other aspects, using whatever risk ranking methodology the organization already has in place. To determine the relevance of any of the categories, an organization can utilize the following parameters in its analysis:
- Level of environmental impact for aspects within the category
- Ability to control or influence the identified aspects
- Level of stakeholder interest in the environmental impacts
This evaluation can be done qualitatively or via a quantitative scoring methodology. As with many requirements under ISO 14001, the standard provides considerable flexibility in the aspects evaluation process. Irrespective of whether a quantitative or qualitative approach is used, the organization should consider a structured approach.
Example points for consideration for selected life cycle categories are presented in the table above. Note that many organizations have already begun evaluating these categories to some extent as they seek to develop a carbon footprint or water footprint for sustainability disclosure purposes.
In reviewing the relevant language in the standard to extract the true meaning of life cycle perspective, several key points become evident. First, there is a need to evaluate environmental impacts beyond the organizational (in most cases, facility) boundary. Second, the new standard requires that the organization closely examine value chain (e.g., supplier) relationships and how the chain members' aspects affect the organization's own environmental performance. Third, the organization should consider its ability to control or influence aspects that are part of a life cycle view.
For further information, contact Mr. Rich Pandullo, Director of EHS Performance & Risk Management, by email or by phone at (919) 462-9693.