Comparing the latest version of ISO 14001 with ISO 14001:2004

ISO 14001:2015 will be based on Annex SL – the new high level structure (HLS) that brings a common framework to all management systems. This helps to keep consistency, align different management system standards, offer matching sub-clauses against the top-level structure and apply common language across all standards.

With the new standard in place, organizations will find it easier to incorporate their environmental management system into the core business processes and get more involvement from senior management.

Based on Annex SL, Fig. 1 shows how the clauses of the new high level structure could also be applied the Plan-Do-Check-Act cycle. The PDCA cycle can be applied to all processes and to the environmental management system as a whole.

. Performance evaluation

New/updated concept       Comment

Context of the organization             The organization will have a greater understanding of the important issues that can affect, positively or negatively the way it manages it’s environmental responsibilities

Issues                                                 Issues can be internal or external, positive or negative and include environmental conditions that either affect or are affected by the organization

Interested parties                             Much more detail about considering their needs and expectations,  then deciding whether to adopt any of them as compliance obligations

Leadership                                        Requirements specific to top management and people in leadership roles within the EMS

Risk associated with threats             The context of the organization provides the framework for the evaluation of risks associated and opportunities             with threats and opportunities

Compliance obligations                    Replaces the phrase ‘legal requirements  and other requirements  to which the organization subscribes

Environmental objectives and          Greater level of detail on environmental objectives which now have to reflect changed planning to achieve them   planning process (see risk associated with threats and opportunities above) and include

determination of appropriate indicators

Communication                                  There are explicit and more detailed requirements  for both internal and external communications

Documented information                 Replaces documents and records

Operational planning and                 Generally more detailed requirements, including a consideration of procurement, design and control                                        the communication of environmental requirements  ‘consistent with a life cycle perspective’

Performance evaluation                   Covers the measurement of EMS, operations that can have a significant environmental impact, operational controls, compliance obligations and progress towards objectives

Evaluation of compliance                 More detailed requirements  relating to maintaining the knowledge and understanding the status of compliance levels.

Nonconformity and corrective         More detailed evaluation of both the nonconformities themselves and  corrective action                                                actions required

Management Review                       More detailed requirements  relating to inputs and outputs of the review

Clause 4: Context of the organization

This is a new clause that in part addresses the depreciated concept of preventive action and in part establishes the context for the EMS. It meets these objectives by drawing together relevant external and internal issues (i.e. those that affect the organization’s ability to achieve the intended outcome(s) of its EMS) in clause 4.1 with the requirements of interested parties in clause 4.2 to help determine, amongst other elements, the scope of the EMS in clause 4.3.

It should be noted that the term ‘issue’ covers not only problems, which would have been the subject of preventive action in the previous standard, but also important topics for the EMS to address, such as any market assurance and governance goals that the organization might set for the EMS. Importantly, those issues should include not only environmental conditions that the organization affects but also those that it is affected by. Some further general guidance on ‘issues’ is given in clause 5.3 of ISO 31000:2009. 

Clause 5: Leadership

This clause places requirements on ‘top management’ which is the person or group of people who directs and controls the organization at the highest level. Note that if the organization that is the subject of the EMS is part of a larger organization, then the term ‘top management’ refers to the smaller organization. The purpose of these requirements is to demonstrate leadership and commitment by leading from the top and wherever possible integration of environmental management into business processes. A particular responsibility of top management is to establish the environmental policy, and the standard defines the characteristics and properties that the policy is to include. This can include commitments specific to an organization’s context beyond those directly required, such as the ‘protection of the environment’

Finally the clause places requirements on top management to assign and communicate the roles, responsibilities and authority for those who facilitate effective EMS.

Clause 6: Planning

Taken as a whole, Clause 6 probably presents the greatest area of change for users of earlier versions of the standard. It works with Clauses 4.1 and 4.2 to complete the new way of dealing with preventive actions. It focuses the organization on the development and use of a planning process (rather than a procedure) to address both a range of factors and the risk associated with such factors.

Clause 7: Support

This clause begins with a requirement that organizations shall determine and provide the necessary resources to establish, implement, maintain and continually improve the EMS.  Simply expressed, this is a very powerful requirement covering all EMS resource needs.

The clause continues with requirements for competence, and awareness, which are similar to their counterparts in ISO 14001:2004.

Finally, there are the requirements for ‘documented information’. ‘Documented information’ is a new term that replaces the references in the 2004 standard to ‘documents’ and ‘records’.  These requirements relate to the creation and updating of documented information and their control. The requirements are similar to their counterparts in ISO 14001:2004  for the control of documents and for the control of records.

Clause 8: Operation

This clause deals with the execution of the plans and processes that enable the organization to meet their environmental policy and objectives. There are new, more specific requirements that relate to the control or influence exercised over outsourced processes.

A potentially larger change is the new broader requirement to consider certain operational aspects ‘consistent with a life cycle perspective’. This means giving serious consideration to how actual or potential environmental impacts happening upstream and downstream of an organization’s site are influenced or (where possible) controlled.

In the light of these changes (including those that relate to planning outputs), users of the standard will obviously want to review their procedures relating to environmental emergencies. When they do so, they should also refer to the more detailed stipulations in clause 8.2 to ensure they are meeting the full range of requirements.

Clause 9: Performance evaluation

This covers much of what was in clause 4.5 of the previous standard. As a general recommendation, determine what information you need

to evaluate the environmental performance and the effectiveness of your EMS. Work backwards from this ‘information need’ to determine what to measure and monitor, when, who and how.

Organizations should also revisit their audit programme in particular to ensure that it meets the new requirements.

Clause 10: Improvement

Due to the new structure and risk focus of the standard, there are no specific requirements for preventive actions in this clause. However, there are some new more detailed corrective action requirements. The first is to react to nonconformities and take action, as applicable, to control and correct the nonconformity and deal with the consequences. The second is to determine whether similar nonconformities exist, or could potentially occur elsewhere in the organization, leading to appropriate corrective actions across the whole organization if necessary. Although the concept of preventive action has evolved there is still a need to consider potential nonconformities, albeit as a consequence of an actual nonconformity.

The requirement for continual improvement has been extended to ensure that the suitability and adequacy of the EMS as well as its effectiveness are considered in the light of enhanced environmental performance.