By Jackie Stapleton

I’ve been working recently with a student who’s taking the leap into certification auditing. She’s done the training, passed the assessments, has the experience—but now she’s staring down the barrel of her first environmental management system (EMS) audit and asking the question we’ve all asked at some point:

“Where do I even start with ISO 14001:2015?”

Good question.

Because when you open that standard and start looking at each clause individually, it’s easy to get lost in the detail. The trick isn’t to memorize every clause or come up with a 50-point checklist. It’s to understand the key areas that give you the most insight—and know what to ask to draw it out.

Here’s how I break it down with my students (and when I conduct audits myself).

Auditing an EMS is like checking the plumbing in a house.

You’re not just walking through each room asking, “Is there a tap?” You’re checking:

• Where the water’s coming from
• Where it’s going
• If there are any leaks
• Whether it all actually works when you turn the tap on

The same goes for auditing ISO 14001:2015. You’re not just confirming a clause exists. You’re checking how it flows through the business, where it links, and if there’s evidence of it actually working in practice.

EMS flow check

This model seen in the graphic below focuses on five key areas every auditor or consultant should assess when reviewing an EMS. Each area connects logically (just like a well-functioning plumbing system) and gives you insight into whether the EMS is effective, or just decorative.

1. Context of the Organization (Clause 4.1)

Everything flows from this.

If the business doesn’t understand its internal and external influences, nothing else will line up.

Ask:

• What influences your environmental impact?
• How do you identify these?
• Who’s involved in that process?

🔍 Look for strategic thinking — not just a SWOT on a shelf.

2. Environmental Aspects (Clause 6.1.2)

This is the core of any EMS.

If this isn’t clear, the rest of the system is just noise.

Ask:

• What are your key environmental aspects?
• How are they identified and reviewed?
• Is there any life cycle thinking involved?

🌱 Look for relevance, not just a recycled list from another business.

3. Compliance Obligations (Clause 6.1.3)

This keeps the system clean and legal.

No one wants to find out they’ve missed a legal requirement during an audit.

Ask:

• What legal and other requirements apply?
• How are they tracked and reviewed?
• How do you stay up to date?

📌 It’s not optional. This is about legal and other obligations—not just doing what sounds good.

4. Operational Controls (Clause 8.1)

Here’s where the talk turns into action.

Controls should exist for a reason—and be in use, not just in the manual.

Ask:

• What controls are in place for significant aspects?
• Are people following them?
• How do you verify that?

🚨 If the system says one thing and the floor says another—you’ve got your gap.

5. Performance Evaluation and Management Review (Clauses 9.1 and 9.3)

This is the result tap—it shows whether everything’s flowing properly.

If there’s no data, there’s no improvement. It’s that simple.

Ask:

• What indicators do you track?
• What trends are showing up?
• What’s changed as a result of the last management review?

📉 This is where you find out if the EMS is holding pressure—or if it’s sprung a leak.

What you can do next

• Pick one area and start asking questions. Don’t wait until the next audit. Pick one of the five key areas and start asking the right questions now. Start with the one you suspect is your weakest—or the one that keeps getting glossed over.
• Walk the system like a plumbing inspector. Grab your checklist, talk to the people actually doing the work, and follow the flow. If the system’s leaking somewhere, you’ll see it. If it’s flowing — you’ll feel it.
• Conduct a gap assessment. Get a clear view of how your EMS stacks up. Use it to run a self-check and spot your biggest opportunities for improvement.

This article first appeared on Auditor Training Online‘s Lead The Standard newsletter and is published here with permission.