by Karen Stewart and Lisa F. Wilk:
ISO 9001 isn’t the only management system standard being revised. ISO 14001, the environmental management system (EMS) standard, has also reached the Final Draft International Standard (FDIS) phase. Because both standards are based on ISO’s new Annex SL—a common management system structure—the two standards will be more closely aligned.
Below are some of the most frequently asked questions about ISO 14001:2015. Questions focus on changes in language, key areas of revision, and the transition period after publication.
How do organizations get a copy of the new draft standard?
A copy of the draft can be purchased now from several sources including ISO/ANSI/ASQ.
Will the new standard still be aligned to the basic plan-do-check-act structure?
Yes. Clause 0.4 (Plan, do, check, act approach) of the new standard specifically discusses alignment with this approach and includes a figure that graphically shows this alignment with the EMS standard.
Is there a clause-by-clause 2004 to 2015 draft gap analysis?
There is a clause correspondence chart (Annex B) included in the guidance section of the new draft that details where the clauses/subclauses are found in each of the standards and in relation to one another.
What’s new/different regarding “risk” in ISO 14001:2015?
In the current ISO 14001:2004 version, the word “risk” only appears twice, and then only in the context of clarifying what is not covered by the standard (financial risk management requirements) and clarifying the use of documentation to avoid “risk” of ambiguity and deviation. In the new DIS version, the word “risk” appears in several areas, including clauses 6.1 and A.6.1 (Planning/actions), clause 6.2.1 (Environmental objectives), clauses 8 and A.8 (Operation), clause 9.2 (Internal audit), clause 9.3 (Management review), and clause A.10.1 (Improvement/nonconformity and corrective action). The concept of organizational risk includes both adverse and beneficial aspects. For some organizations, the additional emphasis on risk in the new standard may include broader consideration of larger business implications in their processes and systems.
Has “preventive action” been replaced by the concept of “risk”?
The notion of preventive action is as important as ever although the explicit mention of it does disappear. The EMS as a whole should be viewed as being a tool for continual preventive action. Clause A.10.1 (Improvement/nonconformity and corrective action) in the new standard explains that this concept is now inherent in the standard instead of being part of a single clause by maintaining that “one of the key purposes of an EMS is to serve as a preventive tool.” The concept of preventive action is also covered in the new clauses 4.1 and 6.1.
What does life cycle mean?
Within the new standard, “life cycle” is defined as “consecutive and interlinked stages of a product system, from raw material acquisition or generation from natural resources to end-of-life treatment.” Life cycle includes activities, products and services that include procured goods and services, and end-of-life treatment of products and delivery of services. Examples of life cycle activities include design, manufacture, transport, packaging, and end-use or disposal. A key point to remember is that the scope of the EMS only includes areas over which the organization can be reasonably expected to have control. Nonetheless, the new standard places much greater emphasis on the organization assessing its control over environmental aspects over the full life cycle of its activities, products, services, and prioritizing to address the significant aspects/impacts.
How does life cycle relate to ISO 14001?
The ISO 14001:2004 version specifically states, “The identification of environmental aspects does not require a detailed life cycle assessment” (clause A.3.1). However, the new revision does mention the concept of “life cycle” in several areas such as clause 1 and A.4.3 and clause 6.2.1 and A.6.1.2. Guidance on the “Typical Stages” of a life cycle assessment are provided that may include “extraction of raw materials, design, production, transportation, use and end-of-life treatment depending on the particular activity, product, or service.”
Does the new standard provide a definition for “competence”?
The principle of requiring the organization to define competency is maintained in the new standard; however, more detailed information on the extent of roles and responsibilities for which competence should be identified is provided. The emphasis on the need to evaluate the effectiveness of actions taken to acquire competency and then ensure that personnel meet those competency requirements applicable to their EMS roles and responsibilities continues. One notable change to the existing standard with regards to competency is in its being required to be documented. Clause 7.2 states, “The organization shall retain appropriate documented information as evidence of competence,” whereas earlier versions used “should.”
Does the new standard define how to assess “effectiveness”?
Unlike ISO 14001:2004, the new standard does include a definition of “effectiveness” in clause 3.20 as “The extent to which planned activities are realized and planned results achieved.” However, it continues the principle of having the organization define how to assess effectiveness. The new standard does help identify areas to be considered, documented, communicated, and assessed relative to effectiveness, by appearing in several areas of the new standard including clause 3 (Definitions), clause 5 (Leadership), clause 6 (Planning), clause 7 (Support), clause 9 (Management review), and clause 10 (Improvement).
How is “top management” defined in the new draft?
ISO 14001:2015 defines “top management” as “the person or group of people who directs and controls an organization at the highest level.” It also includes two notes: Top management has the power to delegate authority and provide resources within the organization, and, if the scope of the management system covers only part of an organization, then top management refers to those who direct and control that part of the organization.
What are other key areas of revision within the draft?
Overall, the new standard includes a significant reorganization and re-titling of the sections of the standard. Annex B includes a table showing the correspondence between ISO 14001:2015 and ISO 14001:2004. Some sections have been significantly expanded (mostly for clarification of intent). The most significant changes include the addition of life cycle assessments, increased focus on leadership, addition of risk assessment of threats and opportunities, increased emphasis on compliance obligations, and additional emphasis on effectiveness. Some of changes clarify the intent of previous editions of the standard, and may already be addressed by organizations with existing systems, whereas some organizations may need to expand their systems to ensure that they fully address the requirements. A gap analysis is an effective way to identify the specific effect on an organization’s EMS.
When will the ability to register a new system under the old standard end?
Organizations can only be certified to the published version of ISO 14001 standard. Currently, this is ISO 14001:2004. Certification bodies (registrars) can begin issuing certificates for ISO 14001:2015 only after the final revision is officially published—expected by the end of 2015. At that time certification bodies will no longer be able to issue new certifications to the old 2004 revision. Organizations will have three years to transition their ISO 14001:2004 certificates to ISO 14001:2015 certificates.
My organization isn’t yet ISO 14001-certified. Should I purchase the draft 2015 standard and tailor my EMS to it? Or should I wait until after the new revision is published before becoming certified?
Organizations choose to establish and implement an ISO 14001 EMS for a variety of reasons including meeting customer and other stakeholder obligations, improving environmental health and safety culture, and facilitating effective management of environmental health and safety obligations and objectives. The existing ISO 14001:2004 standard will address these objectives and can readily be upgraded when the new revised standard is issued. Given the time to develop a brand-new system, it is best to get started sooner rather than later if you intend to develop an ISO 14001 system to address these objectives.
Do auditors need to be certified to new standard?
Yes, there will be competency and gap training requirements for auditors. Nothing has been issued officially in regards to this yet but ANAB (ANSI/ASQ National Accreditation Board) will determine the guidelines to be implemented by the certification bodies. During the certificate transition phase (about three years), auditors will need to be able to demonstrate competency to audit to both the 2004 and 2015 versions of ISO 14001.
About the authors
Karen Stewart is NQA USA’s environmental health and safety business unit manager. Visit NQA USA online at www.nqa-usa.com.
Lisa F. Wilk has more than 25 years of industry experience in all facets of environmental and systems compliance. She helps clients with planning and implementation of EH&S management systems and successfully integrating EH&S with overall business strategies. She is well-versed in EICC, ISO 14001, OHSAS 18001, and sustainability management, including integration with Quality Management Systems. Wilk played a key role in helping the first U.S.-based semiconductor manufacturer to achieve registration to the ISO 14001 standard. She has actively participated in all aspects of EMS/HSMS systems for clients including developing EH&S management systems, facilitating teams, training, conducting internal audits, and participating in registration and surveillance audits. Visit www.capaccio.com for more information.