In September of 2015, the International Organization for Standardization published a revised version of the ISO 14001 environmental management system (EMS) standard. The issuance of this revised ISO standard (referred to as ISO 14001:2015) has started the clock ticking for ISO EMS upgrades and re-alignment among current certificate holders. Nominally, there is a 3-year period for organizations transitioning to the revised standard, meaning that the old standard will cease to exist after September of 2018. In reality, however, most registrars are expecting to follow an actual transition period that is nine months to one year shorter than the nominal date (see discussion below).
Already, many companies have begun planning efforts and taken initial steps to align with the new standard - including such activity as awareness training, gap analysis, and preliminary implementation. Based on Trinity’s experience with clients working on these activities, here is a list of key considerations and challenges organizations may face in aligning with the new standard.
- The optimal time for aligning with the new standard is during the organization’s next re-certification audit. In most instances that will occur before the September 2018 date, however registrars may prefer an earlier time frame. In general, registrars have noted that they want to avoid cases where they perform re-certification to the old standard within a year of September 2018, then have to conduct another re-certification audit prior to that sunset date.
- The revised ISO 14001 standard incorporates numerous new themes, many of which are related to sustainability. In the past, not many organizations took advantage of using their EMS to launch and maintain sustainability initiatives. Now it is much easier to do so, and in fact it is an expectation of the new standard . Companies with such initiatives in place (e.g., sustainable resource use, climate change, life cycle impacts, stakeholder engagement) may already have some of the essentials to integrate into their EMS.
- Defining Organizational Context is a new element within the standard and takes some thought to implement properly. Many organizations that have already aligned to the new standard have found the need to develop a process for identifying and prioritizing key environmental challenges at a higher level than tends to be done in traditional aspects evaluations. They have also needed to define or improve stakeholder engagement processes to allow for clear identification of the needs and expectations of interested parties.
- Incorporating a life cycle perspective in identifying aspects and developing operational controls has proven challenging. While the standard clearly states that a formal life cycle analysis (LCA) is not required, the language does suggest a critical evaluation that includes many elements of an LCA. In order to effectively meet this new ISO 14001 requirement, organizations need to understand what an LCA or Scope 3 greenhouse gas evaluation would entail for their operations and address aspects relating to both types of analysis that they can control or influence.
- Determining risks and opportunities is yet another challenge. The standard clearly states that a formal risk assessment is not required for conformance. While that may be the case, most organizations have elected to either conduct an abbreviated risk assessment (connecting to enterprise risk management processes) or amend their significant aspects determination process to incorporate risk/opportunity evaluation in a robust manner.
- Visible leadership and support from top management are critical in the revised ISO 14001:2015 standard. The concepts were not absent in the old standard, but are indeed emphasized to a much higher degree in this revision. Representatives from top management should become familiar with the requirements of this modified area of the standard and the organization must make sure that it can comply with all of the key commitments listed in the standard.
- The provisions dealing with Documented Information (encompassing the EMS Documentation and Control of Documents elements of the old standard) provides more flexibility than before in how an organization can manage EMS information. That is a positive change. Still, most organizations are finding that is takes some effort and time to align EMS procedures with the new organizational structure in ISO 14001:2015.
- While continual improvement is a mainstay of any management system, the new standard addresses the need to evaluate the effectiveness of the environmental management system as well as the organization’s environmental performance. The organization is expected to communicate relevant environmental performance information both internally and externally, as identified in its communication process and as required by its compliance obligations.
If you are looking to begin ISO 14001:2015 EMS transition activity and need assistance, please do not hesitate to reach out to your local Trinity contact or Mr. Rich Pandullo, Director of EHS Performance & Risk Management at email@example.com.
For related training on ISO 14001, register for Trinity's training course: Implementing a Best-in-Class ISO 14001:2015 EMS.