A different environment?
With the revised version of ISO 14001 published on 15 November as 14001:2004, Anne-Marie Warris explains the new changes to the standard
The Final Draft International Standard (FDIS) features clarification of requirements, alignment with ISO 9001 (particularly in terms of wording and titles) and makes the standard more user-friendly. The changes are likely to require organizations to review and amend their system to ensure conformance with the final version.
One noticeable change has been that documented procedures are no longer required, except for procedures required under the clause relating to operational control. However, organizations still need to 'establish, implement and maintain' procedures to implement and manage their EMS.
Scope - clause 4.1
- the scope of the EMS must now be defined. This scope directly links the management system with the organization's activities, products and services
- it should be documented - eg in the environmental policy
- the organization needs to evaluate and document how its EMS fulfils the requirements of ISO 14001. This could be done as part of the internal audit or as part of management review, as long as it is traceable
Definitions
- auditor: this definition is new and is taken from ISO 9000 and links to the concept of competence of auditors
- continual improvement: slight changes remind users that the process is recurring. The definition is also made more definitive by linking it to environmental performance rather than improvement of the management system
- internal audit: changes to the wording underline the fact that audits must be independent and switches the emphasis of the audit scope from determination of conformance of the EMS to determination of conformance with the EMS audit criteria
- environmental performance: the focus has changed from the management system to an organization's management of its environmental aspects
- prevention of pollution: the wording has been clarified to reflect methods and options for the prevention of pollution. More options are now listed
Policy - clause 4.2
Several changes now require an organization to review its environmental policy. The policy should:
- be developed by top management
- cover the scope of the EMS and not imply a wider scope than that
- cover all activity, products and services within the scope of the EMS
- note change to terminology related to legislative and regulatory requirements
- reflect other environmental requirements the organization may have subscribed to be distributed to everyone working for, or on behalf of, the organization, eg sub-contractors
Environmental aspects identification - clause 4.3.1
- all activities are now covered, ie products and services within the scope of the EMS. Control and influence are separated, and planned and new developments, new and modified activities, products and services are introduced
- significant aspects will now be considered in the planning activities such as new and changed activities, products and services as well as the development, implementation and maintenance of the EMS
- the wording regarding influence has changed from 'over which it can be expected to have an influence' to 'those which it can influence'. Thus, the procedure for identifying environmental aspects must cover all activities, products and services within the defined EMS scope
Legal and other requirements - clause 4.3.2
- 'legislative' has been changed to 'legal'. Thus, rather than referring to a law passed by government, 'legal' is much broader and covers regulatory and court decisions and others
Resources, roles, responsibility and authority - clause 4.4.1
- the replacement of the word 'provide' with 'ensure the availability' could be significant for organizations experiencing high staff turnover, particularly where this involves the loss of provided auditors. Organizations should have contingency plans in place to ensure that alternative auditors are available eg an auditor from an affiliated organization
Competence, training and awareness - clause 4.4.2
- a new term has come into use: 'persons working for, or on behalf of, the organization.' This is broader than just employees - or the old 'members' - and all relevant persons must be covered, eg in terms of competence
- competence now extends in two directions: first, to 'potential significant impacts' and, second, to cover persons working for, or on behalf of, the organization
- competence evaluation should cover all persons working for, or on behalf of, themselves, such as subcontractors, contractors, temporary staff and remote workers, and that significant impact also covers potential impacts. The new first paragraph now allows organizations with established training needs to provide the training themselves or take other action, eg recruiting
Communication - clause 4.4.3
- the changes clarify what organizations need to do if they decide to communicate externally about their environmental aspects. This will affect the management system only if it is decided to communicate in this way - in which case methods for communication need to be established
EMS documentation - clause 4.4.4
- the title has been changed to 'documentation' to reflect the fact that the requirements are now in common with ISO 9001 and the list of required documents and records has been extended
Document control - clause 4.4.5
- the title and the wording have been changed in line with ISO 9001, although the changes are minimal. The key ones relate to external documents and the need to identify changes to documents issued by the organization. This means document control procedures need to be reviewed and the wording updated.
- however, distribution control for documents of external origin - such as legal requirements - to which the organization subscribes must be identified
- changes in versions of documents issued by the organization must be identified by tracking changes, revision index etc
Emergency preparedness and response - clause 4.4.7
- existing emergency and accident procedures should cover 'identification of potential emergency situations and potential accidents that can have (an) impact(s) on the environment, and how it (the organization) will respond to them'
Evaluation of compliance - new clause 4.5.2
- the last paragraph of clause 4.5.1 was brought into a separate clause to highlight the importance of periodic evaluation of legal compliance
- there is an introduction of periodic evaluation of compliance with 'other requirements to which the organization subscribes'
- the rationale for the evaluation of legal compliance has been defined as being required 'to meet the organization's commitment to compliance.' Organizations will need to amend their procedure(s) for evaluation of legal compliance and also include or create another procedure for the compliance evaluation of other requirements to which the organization subscribes
- records of the evaluation should be kept to show its results and the fact that the periodic evaluation has been carried out
Non conformance, corrective and preventive action - now clause 4.5.3
- now a very close match to the corresponding text in ISO 9001 and the concept of potential nonconformity has been brought to the forefront
Conclusion
There have been many comments and debates about the revision to ISO 14001 and despite press reports that predict 'business as usual', organizations must be aware that changes will be required to their management system in order to ensure conformance with the new standard.
This article is based on 'A new environment' by Dr Anne-Marie Warris, Lloyd's Register Quality Assurance (LRQA) global product manager, and EMS and UK expert to ISO 14001 revision - it was first published on LRQA's website
About LRQA
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and training organization. It provides certification of compliance
with international management system standards and helps clients use
management systems to reduce their risks and improve their business.
LRQA is also a notified body for a number of EC directives and offers
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www.lrqa.com
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