Proposed changes to ISO 14001
The International Organisation for Standardisation (ISO) voted in early November 2011 to revise ISO 14001. The revised standard, which is expected to be published in 2015, will operate into the mid-2020s and must therefore provide organisations with a basis for managing future environmental challenges and opportunities.
IEMA, working in close association with other organisations such BSI (British Standards Institute) and CRA Consultancy, has established a working group (WG5) comprised of nominated experts. The function of the group is to develop a series of working drafts, which are open to scrutiny from the environmental community. The working group considers any contentious issues and amends the drafts as necessary.
In March 2013 the revision process reached the stage where a first Committee Draft (CDI) was prepared and circulated to national mirror committees of the ISO Technical Committee revising the standard.
It is important to note that all clauses and sub-clauses of CDI are still to be finalised and this should not be assumed to represent the final standard in part or in whole. ISO 14004 is also being revised in parallel and will provide guidance on implementation.
Key Changes Proposed in CDI
The scope established in CDI provides greater detail than is included in the current scope of ISO 14001. The scope now highlights that the EMS will capture external impacts on the organization – this may typically involve impacts from a changing climate on an organisation’s activities. The scope also puts emphasis on the need to take advantage of opportunities as well as reducing negative impacts.
4.0 Context of the Organisation
New requirements are introduced relating to understanding the external and internal context of the organisation (4.1). The organisation is also required to determine the needs and expectations of interested parties (4.2). This overall context must be taken into account in setting the scope of the EMS (4.3) and in planning actions to address risk and opportunities (6.1).
5.1 Leadership and Commitment
A definition of top management has been introduced (3.11). There is also a requirement related to aligning the EMS with the organisation’s overall strategy. Top management is also required to integrate EMS requirements into core business processes.
CDI expands on the commitments required to be made in the environmental policy by including the need to “support environmental protection” and provides some examples of potential environmental threats.
6.1 Actions to Address Risks and Opportunities
CDI introduces specific requirements for the management of risk and opportunities. These concepts in CDI are much broader in comparison to those addressed in ISO 14001:2004.
6.1.2 Environmental Aspects
Although the requirement in ISO 14001:2004 to consider the environmental aspects it can “control and those that it can influence” could lead to impacts across the value chain of a product or service being considered, this is often not the case. CDI adds to this requirement by specifying a “life-cycle perspective” to be taken when identifying aspects. It is important to note that this does not require a life-cycle assessment to be conducted, but would mean that the impacts of the organisation’s products/services are to be considered.
6.2.2 Environmental Performance Indicators
CDI requires that each objective (established under clause 6.2.1) to have one or more defined indicators associated with it, through which performance is evaluated.
CDI requires organisations to determine the need for both internal and external communication and specifies what should be considered when making the determination.
8.2 Value Chain Planning and Control
Requirements to control or influence upstream and downstream processes are introduced. This clause is important for capturing the environmental impacts which occur outside of the organisation’s direct control.
9 Performance Evaluation
Proposed changes to this clause include the incorporation of the value chain perspective on the organisation’s environmental impacts and the requirement to determine criteria against which performance is evaluated.
9.1.2 Evaluation of Compliance
Requirements associated with evaluation compliance are strengthened in CDI with the introduction of a requirement to maintain knowledge and understanding of compliance status. This requirement would mean that an organisation should be aware of its compliance status and not rely on external parties to inform it that activities were non-compliant.
Implications for organisations
The revised ISO 14001 has implications for organisations putting more responsibility on companies to integrate their ISO 14001 activities with their business process. This means companies must have a more focused approach and strategic plan for implementing ISO 14001 activities. One of the major implications is in evaluation. Companies must now undertake self audits in order to establish any shortcomings in their compliance. This may have serious implications in cases of non-conformance when certification bodies perform audits.