ISO 14001 - Key proposed changes

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Revision of ISO 14001 Key Changes Proposed in the March 2013 Draft

CRA Europe Unit 1, Calverton Business Park Hoyle Road Calverton Nottingham, NG14 6QL www.cra.co.uk April 2013 900002


Revision of ISO 14001 Key Changes Proposed in the March 2013 Draft

This report was prepared by: Nigel Leehane and reviewed by: Bryan Hughes

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Revision of ISO 14001 – Key Changes Proposed in the March 2013 Draft

Table of Contents Page 1.0

Introduction .........................................................................................1 1.1 1.2

Background ........................................................................................1 Where can you find out more? ............................................................2

2.0

Greater Expectations for Top Management’s Leadership and Commitment ........................................................................................3

3.0

How to Address Strategic Environmental Issues, the Interests of Stakeholders and the Direction of the Business ..............................5

4.0

What commitments to make to sustainable development and social responsibility? .........................................................................8

5.0

Extending environmental influence into the value chain, with implications for procurement...........................................................10

6.0

Environmental Design as a Tool for Improvement .........................12

7.0

Demonstrating Environmental Compliance Status ........................13

8.0

Using performance indicators to track improvement ....................14

9.0

Timeline and Milestones for the Revision Process ........................15 9.1 9.2

10.0

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Opportunities for Responding to Consultation ...................................15 Timescale for Conforming to a Revised Standard .............................16

How can CRA help with the transition to ISO 14001:2015? ...........17


Revision of ISO 14001 – Key Changes Proposed in the March 2013 Draft

List of Appendices Appendix A

Future Challenges Recommendations

Appendix B

Relationships between the Clauses of ISO 14001:2004 and the March 2013 Revision Draft

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Revision of ISO 14001 – Key Changes Proposed in the March 2013 Draft

1.0 Introduction 1.1

Background

ISO 14001:2004 is being revised. The International Organisation for Standardisation (ISO) working group responsible for revising the text met in early February and has produced a “Committee Draft” which is being circulated for comment to its member bodies. When published, ISO 14001:2015 will have a new structure and “common text”, following ISO rules for all management systems standards. It will also address the recommendations from the ISO “Future Challenges” study (Appendix A), for the adoption of various new approaches and methods in the field of EMS, and to meet the needs of stakeholders in the future. This is a fundamental revision of the standard, with far greater implications for organisations than the previous revision in 2004. This report, which identifies seven major changes proposed in the current draft, aims to help you appreciate the key themes of the revision, and what auditors may expect from you once ISO14001:2015 is released: 1. 2. 3. 4. 5. 6. 7.

Greater expectation for top management to understand the organisation’s environmental issues, support the EMS and champion improved performance; Broader strategic consideration of the organisation’s environmental context, including the interests of stakeholders and the direction of the business; Making specific commitments to sustainable development and social responsibility; Extending environmental influence into the supply chain, with implications for procurement; Embracing opportunities for using environmental design as a tool for improvement; Being able to demonstrate an understanding of the organisation’s environmental compliance status at all times; and Using performance indicators to track improvement.

Some of these new requirements are addressed by changes to the structure of the standard, which will include new clauses on: • • • • •

Understanding the organisation and its context; Understanding the needs and expectations of interested parties; External communication and reporting; Value chain planning and control; and Continual improvement.

Many of the other clauses have been strengthened and the order of many in the standard has changed. For example, “awareness” is no longer part of competence and training, but is a separate sub-clause. Non-conformance now sits between management review and

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Revision of ISO 14001 – Key Changes Proposed in the March 2013 Draft

continual improvement, a new sub-clause which provides greater emphasis on improvement at the end of the standard. Tables showing the relationships between the clause structure of the 2004 edition and the proposed new structure are provided in Appendix B. The anticipated timescales and key milestones in the revision process, including opportunities to respond to consultations, are set out in Section 9.0.

1.2

Where can you find out more?

CRA will be publishing briefings throughout the revision process. If you would like to receive them, then please subscribe to our quarterly newsletter via our website. Existing subscribers will automatically receive the newsletters and any other ISO 14001 briefings. Nigel Leehane is one of the UK’s technical experts appointed to the ISO working group revising 14001. Please contact him on 0115 965 6700 or nleehane@cra.co.uk if you would like to know more about the changes to ISO 14001 and the implications for your organisation.

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Revision of ISO 14001 – Key Changes Proposed in the March 2013 Draft

2.0 Greater Expectations for Top Management’s Leadership and Commitment ISO 14001:2015 will include new clauses on leadership and the commitment of the organisation, which expand significantly on the requirements of the current version of the standard. The current version of the standard requires top management (those who “control or direct organisations at the highest level)” to define the environmental policy, appoint a management representative responsible for the EMS and reporting back to them, and undertake the management review. This has allowed top management to become divorced from meaningful environmental management, instead relying on its delivery by an environmental management function. The revised standard will require much more of top management, including: • • • • • • • •

Understanding the organisation's context (in terms of its environmental risks, opportunities and stakeholder expectations); Ensuring that the environmental policy and objectives are compatible with the strategic direction of the organisation; Considering environmental performance in strategic planning; Ensuring the integration of the EMS into the organisation’s business processes; Ensuring adequate resources are available; Communicating the importance of effective environmental management; Ensuring that the environmental management system achieves its intended outcomes and promotes continual improvement; and Directing and supporting staff to contribute to the effectiveness of the EMS, and supporting those responsible for environmental management.

These are far more onerous responsibilities for top management, aimed at encouraging them to be more involved in environmental management and supporting environmental management efforts. These robust criteria provide effective ammunition to auditors to allow them to test the involvement and support from top management, which is needed to foster organisational behaviour change. Additionally, the new requirements should lead to greater integration of environmental management into business processes, and ensure environmental issues are considered at a strategic level, including in the context of longer term planning. These measures should encourage organisations to derive greater business benefits from improved environmental performance and crucially help to remove barriers to environmental improvement by harmonising business and environmental goals.

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Revision of ISO 14001 – Key Changes Proposed in the March 2013 Draft

How will your organisation’s top management respond to these challenges? Consider what they will need to do to demonstrate to an auditor that they are fulfilling these obligations. What evidence will auditors need to verify that environmental performance is considered in strategic planning or that the EMS is being integrated into the organisation’s business processes?

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Revision of ISO 14001 – Key Changes Proposed in the March 2013 Draft

3.0 How to Address Strategic Environmental Issues, the Interests of Stakeholders and the Direction of the Business ISO 14001:2015 will include new opening clauses concerning the context of the organisation and understanding the needs and expectations of stakeholders. This is an important development, aimed at ensuring the organisation considers high-level, strategic drivers when establishing the scope of its EMS, making its core commitments, and developing its environmental policy. There is a clear shift in emphasis from the 2004 edition, in which the only explicit requirement to identify environmental issues is in the context of identifying and assessing environmental aspects, after the policy has been established. In the Annex, it is suggested that an initial review, including of the environmental aspects, should be undertaken before developing the policy, but there is no suggestion that this should be at a strategic, rather than operational, level. The revised edition does both, with requirements for high level consideration of risk and also operational environmental aspects evaluation. This is an important distinction, separating strategic and operational environmental issues, and ensuring that appropriate attention is now also given at the strategic level. This should be undertaken when planning the system and also periodically, in the same way that operational environmental aspects are considered.

Strategic Level

Consider context and stakeholders

Determine system scope & define policy

Review and improve

Implement system

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Revision of ISO 14001 – Key Changes Proposed in the March 2013 Draft

Operational Level

Assess environmental aspects

Implement operational controls

Review and improve

Monitor performance The new clause for understanding the organisation and its context requires the determination of internal and external issues “relevant to its purpose” and which may influence the effectiveness of the EMS. It also specifically refers to the implications of external environmental conditions, which is a subtle nudge towards addressing climate change adaptation. The use of the term “purpose” of the organisation is important, in that it directly relates environmental management to the raison d’etre of the organisation, implicitly requiring strategic consideration of anything “environmental“ that may have a bearing on broader organisational goals. This fulfils the Future Challenges recommendation that environmental management be integrated with business strategy. The new clause for understanding the needs and expectations of interested parties, or stakeholders, simply requires the identification of relevant parties and their requirements, in relation to the environmental management system. Stakeholder needs and expectations clearly can vary in significance from one organisation to another and, rightly, the standard does not prescribe how or when these needs and expectations should be evaluated. The output of both of these evaluations, of context and stakeholders, should provide an input into the determination of the scope of the EMS. Additionally, the environmental policy should also reflect the “direction of the organisation”, or its broader strategic policy.

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Revision of ISO 14001 – Key Changes Proposed in the March 2013 Draft

These new requirements will pose some interesting challenges for organisations, potentially requiring a greater degree of consideration of environmental matters at strategic level. It will be interesting to see how far external auditors will go to obtain evidence that these requirements are being fulfilled.

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Revision of ISO 14001 – Key Changes Proposed in the March 2013 Draft

4.0 What commitments to make to sustainable development and social responsibility? The Future Challenges study recommended that consideration be given in the revision of ISO 14001 to the content of ISO 26000 – Guidance on Social Responsibility, which considers the environment as the “planet” element of the “People, Planet and Profit” model. Future Challenges suggests that 14001 should address the environmental principles in ISO 26000 and also consider aligning its language. The four environmental themes considered in ISO 26000 are: • • • •

Prevention of pollution (waste and emissions); Sustainable resource use (materials, energy and water consumption); Climate change and mitigations (GHG); and Protection of the environment and restoration of natural habitats (ecosystems, biodiversity, land and natural resources, urban and rural development).

Prevention of pollution is already a key principle of 14001, to which a commitment must be made in the environmental policy. This is retained in the revised text, but with the additional requirement to “support environmental protection specific to the context of the organisation”, and decide if other commitments should be made. The use of the term “context” refers to the new clauses 4.1 and 4.2, which require the consideration of the organisation’s internal and external issues and stakeholder needs and expectations. This is not a detailed operational aspects assessment, but a high level, strategic review, intended to identify broader risks and opportunities. The outcome will depend very much on the nature of the organisation’s activities, products and services, the value chain and geographic factors, among others. The revised text incorporates the three ISO 26000 topics, with some modifications: • • •

Sustainable resource use; Climate change mitigation and adaptation; and Protection of biodiversity and ecosystems.

It also includes the catch-all “or other relevant environmental issues”, which, for organisations involved in agriculture, for example, could be water scarcity. Although there is no mandatory requirement to address these sustainability principles in the policy, organisations should determine if they would benefit from doing so, taking account of the broader business implications. One of the requirements of top management is to ensure that the environmental policy is compatible with the strategic direction of the organisation,

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Revision of ISO 14001 – Key Changes Proposed in the March 2013 Draft

and so they should be sufficiently well informed to decide if commitment is needed to any specific sustainability principles. Should specific commitments be made, then the system needs to provide the tools to fulfil them. The revised text provides substantially greater drivers for this, including: • • • • •

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Setting objectives consistent with the policy; More detailed requirements for external reporting (compatible with the Global Reporting Initiative, etc.); Adopting a life cycle perspective; Requiring the use of key performance indicators for measuring progress towards objectives; and Value chain planning, control and monitoring.

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Revision of ISO 14001 – Key Changes Proposed in the March 2013 Draft

5.0 Extending environmental influence into the value chain, with implications for procurement The current edition of ISO 14001 recognises the need to address the impacts of “activities, products and services”, but the emphasis is very much on controlling the organisation’s own activities. The ISO Future Challenges report suggests that the need to think more broadly outside the organisational control box is implied in the current standard, rather than being explicit, and it recommends that the revised standard should: •

Address life cycle thinking and the value chain perspective more clearly in the identification and evaluation of environmental aspects related to products and services; and Include clear requirements/guidance related to strategic environmental considerations, design and development, purchasing, marketing and sales activities.

The working group has made some progress incorporating these concepts, including a generic requirement for organisations to consider how they can control or influence upstream and downstream processes in the value chain. There are specific requirements to address environmental issues in procurement and outsourcing, for: • • • •

Evaluating the supply of goods, services and outsourced processes, taking a lifecycle perspective; Specifying environmental requirements as appropriate for the procurement of goods and services or outsourced processes; Communicating requirements to suppliers, including contractors; and Monitoring key characteristics of the value chain.

There is no expectation that organisations would need to carry out detailed life-cycle assessments. The revised text makes it clear that the consideration of value-chain issues should be related to significant aspects, and this should be the starting point for organisations to determine if they do have opportunities for control or influence in the value chain. The revised text provides definitions of the value chain, supply chain and lifecycle (see the Value Chain/Lifecycle model below), which are helpful in considering where and how organisations can exert control or influence. Generally, organisations have more opportunity to control, and a greater sphere of influence over the characteristics and resultant environmental aspects of materials, products and services that they procure and ultimately supply, than they do over the activities of other organisations forming the value chain. The opportunity to influence other organisations

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Revision of ISO 14001 – Key Changes Proposed in the March 2013 Draft

should not be ignored, but the tools and approaches may be very different (softer communications and engagement), from those used for specifying materials. How will external auditors test the processes applied to the planning and control of the value chain? The approach used for assessing the significance of value chain aspects will be a starting point, but also the auditors will be interested in how the organisation determines those significant aspects it can or should control or influence. As a minimum, this could include the process by which procurement decisions are taken, and whether they involve the consideration of the environmental characteristics of the purchased materials or services. More advanced approaches would address the opportunities to influence suppliers, not only to improve the environmental characteristics of the materials and services, but also to adopt better environmental management practices throughout the organisation. However, it must be recognised that organisations may have limited opportunities for influencing the behaviours of suppliers. SMEs may feel that they have no influence, but even so they do have the opportunity to decide what they buy and from who.

Value Chain and Life Cycle Organisations in the Value Chain

Upstream – Suppliers, etc, defined as the “Supply Chain”

Our Organisation

Downstream – Customers, etc

Life-cycle of a material/product through the value chain

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Revision of ISO 14001 – Key Changes Proposed in the March 2013 Draft

6.0 Environmental Design as a Tool for Improvement The latest draft includes short but potentially powerful statements relating to the design, development and change of products and services, and the need to communicate information relating to potential impacts associated with the use and end-of-life of products, and the delivery of services. This is in contrast to ISO 14001:2004, where the first reference to design is in the single Annex, so addressing environment in design currently is not a requirement of the standard. The revised text introduces requirements for: • •

Identifying the environmental aspects of its activities, products and services … that it can control and those that it can influence considering a life cycle perspective; and Considering the result of the evaluation of significant environmental aspects as input in the process of the design, development or change of its products and services.

The Annex also explains that the organisation should consider how it will integrate environmental management system requirements into its various business functions, such as design & development. It also makes reference to product, process and facility design and development. So, although there will be no requirement for organisations to undertake detailed life-cycle analysis of all inputs and outputs, there will be an expectation to identify and assess the significance of key aspects in the value chain, and to consider how these can be managed to reduce impacts. It will be up to the organisation to decide and justify its approach, but clearly it should be expected that external auditors will be looking for evidence that: • • • •

Key value chain aspects have been identified and evaluated; Decisions have been made in relation to managing them, where feasible, to reduce value chain impacts; Mechanisms exist within the organisation to ensure that design functions consider these key value chain aspects; Consideration is given to minimising direct environmental impacts through considering process and facility design.

Many organisations already recognise the business benefits of reducing operating costs through process and facility design, but the expectation of the revised text clearly is to extend these drivers into the value chain, potentially to the benefit of the organisation, their partners, suppliers, customers and end-users in the value chain.

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Revision of ISO 14001 – Key Changes Proposed in the March 2013 Draft

7.0 Demonstrating Environmental Compliance Status The Future Challenges study recognised that, while it is difficult for organisations to maintain complete compliance at all times with environmental legislation, they need to know when they are not, so that they can plan to restore compliance as soon as possible. This is not intended as a dilution of the requirement to comply with legislation; it is a pragmatic acknowledgement of what can be achieved, as a part of value added, through the effective application of an EMS. This also harmonises the ISO 14001 stance with that of many jurisdictions where the commitment to compliance is seen as a pledge, rather than a guarantee of perpetual compliance. The revised text retains the requirement to identify applicable legislation and understand the compliance requirements. However, rather than simply imposing a requirement of “periodically evaluating compliance with applicable legal requirements”, the revised text stipulates that the organisation must: • • •

Evaluate compliance at pre-determined frequencies; Take any necessary action (i.e. to address non-compliance, actual or potential); and Maintain knowledge and understanding of its compliance status.

The Annex provides more information, explaining that the evaluation of compliance should not only involve periodic compliance audits, but also comprises: • • •

Site inspections and observations; Review of records; and Comparing the results of monitoring against regulatory requirements.

So, compliance evaluation is also part of everyday inspection and monitoring activities. It is important that the results of these checks are reviewed by competent individuals, capable of identifying actual or potential non-compliances and instigating action to remedy them. This will be nothing new to many organisations that already have comprehensive compliance monitoring and evaluation mechanisms in place; however, the new requirements should encourage external auditors to review that these processes are effective in maintaining knowledge and understanding of compliance status.

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Revision of ISO 14001 – Key Changes Proposed in the March 2013 Draft

8.0 Using performance indicators to track improvement The Future Challenges study report states that the objective of ISO 14001 should be the improvement of environmental performance itself, and argues that the current text, which implies that this improvement is achieved only by improving the EMS, is confusing to the users of the standard. The report recommends: • •

Clarification of the requirements for improving environmental performance, and Strengthening performance evaluation, potentially through the use of indicators.

The first of those recommendations has not yet been addressed, with adherents of the traditional stance successfully arguing for the retention in clause 10.2 Continual improvement of: “The organization shall continually improve the suitability, adequacy and effectiveness of the environmental management system to enhance its environmental performance” It is to be hoped that the aspirations of Future Challenges for the emphasis to be on environmental performance improvement can be incorporated before the final draft is completed. The second recommendation has been addressed, with a specific requirement to establish one or more indicators for each objective set by the organisation. Secondly, there is a generic expectation that indicators will be used for monitoring and measuring performance against specified criteria (for example discharge consent limits or energy intensity targets). The Annex refers to ISO 14031 Environmental management — Environmental performance evaluation, and its approach to sub-dividing environmental performance indicators (EPIs) into: • • •

Management performance indicators (MPIs); Operational performance indicators (OPIs); and potentially Environmental condition indicators (ECIs).

The selection of indicators is at the discretion of the organisation, and can be aligned with any regulatory requirements, expectations of stakeholders and, as specified in the revised text, its objectives.

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Revision of ISO 14001 – Key Changes Proposed in the March 2013 Draft

9.0 Timeline and Milestones for the Revision Process 9.1

Opportunities for Responding to Consultation

The current draft (a “committee draft”, in ISO terminology) is circulated by ISO to its members bodies (BSI in the UK). Members of the BSI environmental management systems committee can circulate it within the organisations they represent. Comments from the UK are collated by BSI and submitted to the ISO secretariat, which in turn collates comments from all its member bodies globally and presents these to the working group to consider. The next meeting of the working group is planned for the end of June 2013, with the likely output being a more refined committee draft, which will be circulated to the same audience, in August/September. This time, in addition to providing comments on the text, members (i.e. BSI) are asked to vote for the draft to progress to the next stage. In November, the working group will reconvene, hopefully to prepare a “Draft International Standard”, which will be circulated for public comment, probably in early 2014, with a threemonth consultation period. Again, members vote on proceeding to the final stage, a “Final Draft International Standard”. Again, assuming all goes to plan, the working group will reconvene in early summer 2014 to address the latest round of comments and prepare the final draft. Once this is completed, it is circulated to member bodies to vote to accept it for publication (members can submit minor editorial comments at this stage). Assuming the vote is positive, the secretariat arranges for the standard to be finalised and translated into various languages, for publication in January 2015. ISO 14001 Revision Timescales Working Group Dates

Feb 2013

Jun 2013

Nov 2013

Jun 2014

Output

Committee Draft 1

Committee Draft 2

Consultees

ISO Members and their committees

ISO Members and their committees

Draft International Standard ISO Members and the public

Final Draft International Standard ISO Members

Probable Consultation Period

Mar-Apr 2013

Aug-Sept 2013

Early 2014

Late Summer 2014

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Revision of ISO 14001 – Key Changes Proposed in the March 2013 Draft

9.2

Timescale for Conforming to a Revised Standard

Typically, ISO allows 18 months for organisations to meet the requirements of a revised management systems standard. A longer period may be granted in this case, owing to the substantial scale of the proposed changes, but that cannot be guaranteed. Assuming that the publication target date of January 2015 is achieved, organisations should be prepared to comply with the new requirements by mid-2016.

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Revision of ISO 14001 – Key Changes Proposed in the March 2013 Draft

10.0 How can CRA help with the transition to ISO 14001:2015? CRA is in a unique position to provide support to organisations with the transition from ISO 14001:2004 to ISO14001:2015. Participating in the ISO working group carrying out the revision means that we have insights into the potential direction of future drafts leading up to 2015. We can also appreciate the intentions and reasoning behind the changes to the standard. CRA can help organisations, such as yours, develop a plan to review and modify their systems to meet the requirements of ISO 14001:2015. Gap Analysis The starting point is to undertake a gap analysis of existing systems being used by the client, not only the EMS, but other related business processes, with which ISO 14001:2015 will expect a greater degree of integration. Owing to the increased emphasis on higher level business management, this should also include processes for strategy development. The gap analysis would focus on all the areas of change set out in the earlier sections of this report. It would also explore how the new structure (based on the ISO high level structure for all management systems) can be accommodated. It is not a requirement to adopt the new clause numbering system, provided the new requirements are incorporated into the organisation’s system. We can provide guidance on how these requirements can be interwoven with an existing management systems structure. The output of the gap analysis would include: • • • •

Recommendations for addressing the new requirements of ISO 14001:2015; Guidance on integrating these and existing EMS arrangements further into other business processes; An appropriate and achievable timeline for system redevelopment; and Recommendations for developing and empowering a system review team.

Additional Services CRA can provide support in all aspects of system redevelopment, but at an early stage clients may wish to consider: • •

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Briefings to senior management on the implications of the revised standard; and Training EMS staff in carrying out detailed review and system modification tasks.

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Revision of ISO 14001 – Key Changes Proposed in the March 2013 Draft

For Further Information Nigel Leehane is one of the UK’s technical experts appointed to the ISO working group revising 14001. Please contact him on 0115 965 6700 or nleehane@cra.co.uk if you would like to know more about the changes to ISO 14001 and the implications for your organisation.

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Revision of ISO 14001 – Key Changes Proposed in the March 2013 Draft

Appendices

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Revision of ISO 14001 – Key Changes Proposed in the March 2013 Draft

Appendix A Future Challenges Recommendations

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Revision of ISO 14001 – Key Changes Proposed in the March 2013 Draft

Future Challenges Recommendations The ISO Future Studies report made the following recommendations for the revision of ISO 14001: EMS as part of sustainability and social responsibility • Consider inclusion of practical tools to address sustainability in ISO 14004 EMS and (improvement of) environmental performance • Clarification of the requirements of (improving) environmental performance in ISO 14001 • Strengthen performance evaluation as part of 4.5.1 in ISO 14001 (e.g. use of indicators) EMS and compliance with legal and other external requirements • Clearly describe and communicate the approach/mechanism of achieving legal compliance in ISO 14001 (e.g. in the Annex) • Address the concept of 'demonstration of the commitment to legal compliance' • Consider to include the concept of demonstrating knowledge and understanding of the organisation’s compliance status EMS and overall (strategic) business management • Pay attention to strategic considerations of environmental management, the benefits and opportunities of it for organisations, not only in introduction, but also in the requirements • Strengthen (on a strategic level) the relationship between environmental management and the core business of organisations, i.e. its products and services and the interaction with stakeholders (including clients and suppliers) • Use the JTCG identical text on ‘context of the organisation’ to strengthen link between environmental management and the organisation's overall strategic considerations • Consider the implications of new (strategic) business management models for application of ISO 14001 EMS and conformity assessment • Draft clear and unambiguous requirements in ISO 14001 • Provide where necessary clearer guidance in Annex A (according to its current aim: to prevent misinterpretation of the requirements) EMS and the uptake in small organizations • Maintain the applicability of ISO 14001 to SME, e.g. by drafting/maintaining simple and understandable requirements

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Revision of ISO 14001 – Key Changes Proposed in the March 2013 Draft

Consider the guidance given in CEN Guide 17 “Guidance for writing standards taking into account micro, small and medium-sized enterprises (SMEs) needs”

EMS and environmental impacts in the value/supply chain • Address life cycle thinking and the value chain perspective more clearly in the identification & evaluation of environmental aspects related to products and services • Include clear requirements/guidance related to strategic environmental considerations, design & development, purchasing, market & sales activities in alignment with organisational priorities EMS and engaging stakeholders • Building upon the (draft) JTCG identical text introduce a more systematic approach for identification of, consultation and communication with stakeholders on environmental issues EMS and parallel or sub systems (GHG, energy) • Communicate the broad applicability of ISO 14001 as well as the advantages of considering environmental aspects/issues not separately but in an integrated way and broader perspective • Consider developing briefing notes on application of ISO 14001 for specific aspects/sectors as alternative to development of new aspect/sector specific standards (e.g. GHG) EMS and external communication (including product information) • The future revision of ISO 14001 should address a requirement to establish an external communication strategy, including communication objectives, identifying relevant interested parties, description of what and when to communicate • Provide guidance in the Annex on information related to environmental aspects of products and services to external interested parties

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Revision of ISO 14001 – Key Changes Proposed in the March 2013 Draft

Appendix B Relationships between the Clauses of ISO 14001:2004 and the March 2013 Revision Draft

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Revision of ISO 14001 – Key Changes Proposed in the March 2013 Draft

Correspondence between ISO 14001:2004 and ISO 14001:201X ISO 14001:201X

ISO 14001:2004

Context of the organization (title only)

4

Understanding the organization and its context

4.1

Understanding the needs and expectations of interested parties

4.2

Determining the scope of the environmental management system

4.3

Environmental management system

4.4

Leadership (title only)

5

Leadership and commitment

4.1

General requirements

4.1

General requirements

5.1

4.4.1

Resources, roles, responsibility and authority

Policy

5.2

4.2

Environmental policy

Organization roles, responsibilities and authorities

5.3

4.4.1

Resources, roles, responsibility and authority

Planning (title only)

6

4.3

Planning (title only)

Actions to address risks and opportunities (title only)

6.1

General

6.1.1

Environmental aspects

6.1.2

4.3.1

Environmental aspects

Legal requirements and voluntary obligations

6.1.3

4.3.2

Legal and other requirements

Environmental objectives and planning to achieve them (title only)

6.2

4.3.3

Objectives, targets and programme(s)

Environmental objectives

6.2.1

4.3.3

Objectives, targets and programme(s)

Environmental improvement programmes

6.2.2

4.3.3

Objectives, targets and programme(s)

Support (title only)

7

4.4

Implementation and operation (title only)

Resources

7.1

4.4.1

Resources, roles, responsibility and authority

Competence

7.2

4.4.2

Competence, training and awareness

Awareness

7.3

4.4.2

Competence, training and awareness

Communication (title only)

7.4

4.4.3

Communication

General

7.4.1

4.4.3

Communication

Internal communication

7.4.2

4.4.3

Communication

External communication and reporting

7.4.3

4.4.3

Communication

Documented information (title only)

7.5

4.4.4

Documentation

General

7.5.1

4.4.4

Documentation

Creating and updating

7.5.2

4.4.5

Control of documentation

4.5.4

Control of records

Control of documented information

7.5.3

4.4.5

Control of documentation

Operation (title only)

8

4.4

Implementation and operation (title only)

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Revision of ISO 14001 – Key Changes Proposed in the March 2013 Draft

ISO 14001:201X

ISO 14001:2004

Operational planning and control

8.1

4.4.6

Operational control

Value chain planning and control

8.2

4.4.6

Operational control

Emergency preparedness and response

8.3

4.4.7

Emergency preparedness and response

Performance evaluation (title only)

9

4.5

Checking (title only)

Monitoring, measurement, analysis and evaluation (title only)

9.1

4.5.1

Monitoring and measurement

General

9.1.1

4.5.1

Monitoring and measurement

Evaluation of compliance

9.1.2

4.5.2

Evaluation of compliance

Internal audit

9.2

4.5.5

Internal audit

Management review

9.3

4.6

Management review

Improvement (title only)

10

Nonconformity and corrective action

10.1

4.5.3

Nonconformity, corrective action and preventive action

Continual improvement

10.2

4.1

General requirements

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Revision of ISO 14001 – Key Changes Proposed in the March 2013 Draft

Correspondence between ISO 14001:2004 and ISO 14001:201X ISO 14001:2004

Environmental management system requirements (title only)

General requirements

Environmental policy

Planning (title only)

ISO 14001:201X 4

Context of the organization (title only)

4.1

Understanding the organization and its context

4.2

Understanding the needs and expectations of interested parties

4

4.1

4.2

4.3

4.3

Determining the scope of the environmental management system

4.4

Environmental management system

10.2

Continual improvement

5.2

Policy

6

Planning (title only)

6.1

Actions to address risks and opportunities (title only)

6.1.1

General

Environmental aspects

4.3.1

6.1.2

Environmental aspects

Legal and other requirements

4.3.2

6.1.3

Legal requirements and voluntary obligations

6.2

Environmental objectives and planning to achieve them (title only)

6.2.1

Environmental objectives

6.2.2

Environmental improvement programmes

7

Support (title only)

8

Operation (title only)

7.1

Resources

5.3

Organization roles, responsibilities and authorities

5.1

Leadership and commitment

7.2

Competence

7.3

Awareness

7.4

Communication (title only)

7.4.1

General

7.4.2

Internal communication

7.4.3

External communication and reporting

7.5

Documented information (title only)

7.5.1

General

7.5.2

Creating and updating

7.5.3

Control of documented information

8.1

Operational planning and control

Objectives, targets and programme(s)

Implementation and operation (title only)

Resources, roles, responsibility and authority

Competence, training and awareness

Communication

4.3.3

4.4

4.4.1

4.4.2

4.4.3

Documentation

4.4.4

Control of documentation

4.4.5

Operational control

4.4.6

900002 April 2013


Revision of ISO 14001 – Key Changes Proposed in the March 2013 Draft

ISO 14001:2004

ISO 14001:201X 8.2

Value chain planning and control

Emergency preparedness and response

4.4.7

8.3

Emergency preparedness and response

Checking (title only)

4.5

9

Performance evaluation (title only)

9.1

Monitoring, measurement, analysis and evaluation (title only)

9.1.1

General

Monitoring and measurement

4.5.1

Evaluation of compliance

4.5.2

9.1.2

Evaluation of compliance

Nonconformity, corrective action and preventive action

4.5.3

10.1

Nonconformity and corrective action

Control of records

4.5.4

7.5.3

Control of documented information

Internal audit

4.5.5

9.2

Internal audit

Management review

4.6

9.3

Management review

900002 April 2013


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