ISO 14001

ISO 14001:2015 Lessons from the Early Adopters #4



Marek Bidwell interviews Helena Tinker from Mmmu_logo_0anchester Metropolitan University about her experience making the transition to ISO 14001:2015.


Helena Tinker is the Environment and Energy Systems Manager at Manchester Metropolitan University. She is responsible for the University’s Environmental Management System, Policy and Strategy implementation.

Manchester Metropolitan is one of the largest campus-based universities in the UK, with a total student population of approximately 38,000 and approximately 4,000 staff. The University has pursued an environmental sustainability agenda for a number of years and was ranked as one of the top three greenest UK universities by The People and Planet Green League in 2015 and the greenest university in 2013.

Manchester Metropolitan has implemented an environmental management system using the EcoCampus framework. They achieved bronze in 2012, silver in 2014 and gold in 2015. In early 2016, they were assessed against the final stage of EcoCampus (that includes the check and review stages of the standard) achieving EcoCampus Platinum and ISO 14001:2015 simultaneously.

In May this year, Helena presented a summary of the university’s journey towards ISO 14001:2015 at the annual conference of The Environmental Association for Universities and Colleges.

Give me a flavour of how you prepared for the 14001 transition?

When we were working towards gold EcoCampus in 2015, I reviewed early drafts of the ISO 14001:2015 standard to ensure the systems we developed incorporated the new requirements, such as leadership commitment and context analysis, and then tweaked the systems when the final version was published.

 I embedded the EMS across the organisation, building competency in other members of staff.

The system is split into 12 areas that link to our environmental policy and a member of staff is accountable for achieving the objectives and targets, defining roles and responsibility and ensuring legal compliance within their area.

I also integrated the EMS into other business processes across the organisation.


Environmental roles and responsibilities at Manchester Metropolitan University


What were the most helpful sources of information?

 The ISO 14001:2015 consultation workshops run by Martin Baxter from IEMA were useful as they gave an early insight to the changes being proposed.  Alex Hobbins from EcoCampus was also helpful; we worked together to understand the impact of the changes on our system.

What were the strengths of your existing system?

Manchester Metropolitan has been active in environmental sustainability for a number of years, so already had some excellent and challenging environmental programmes in place. The Environment Team were well resourced and staff across the university were already engaged in environmental issues via the NUS Green Impact Programme, which we had been running for a number of years. The University already had an Environmental Strategy and Policy with commitment from senior management. We reviewed and updated both documents to meet the requirements of 14001:2015. Further resources were also made available to deliver new environmental objectives and targets.



Environmental Vision, and Policy for 2020 at Manchester Metropolitan University


In early 2014, the university developed an objective to embed sustainability into the curriculum, and recruited a new member of staff to manage this work programme. This helped the University maintain our position in the People and Planet green/university league because there was greater emphasis on ‘education for sustainable development’ in the assessment criteria.

We were already delivering an excellent waste and recycling service with challenging reuse and recycling targets, but a full review of our waste streams and environmental obligations was required. We also formalised our systems and procedures to maintain compliance and increased our waste auditing activities.

What were the main changes you needed to make?

The clause/requirement we had not addressed was ‘context analysis’. To meet this requirement, I delivered a number of workshops with the eight environmental policy managers and their teams in 2015. We undertook a PESTLE analysis of internal and external issues that could affect the university achieving its environmental objectives. We then identified the associated, risks and opportunities and proposed actions to address the issues arising. It was a useful exercise as it helped us identify future challenges and our management response. I selected key risks and opportunities and our proposed actions and presented them to our Environmental Strategy Board for discussion, input and approval.

Did you find the process of identifying risks and opportunities useful, having already identified your environmental aspects?

We found it more useful than the aspects assessment exercise, especially for the travel and waste policy areas; it helped teams think about how their activities are influenced by internal and external factors. It encouraged them to think more holistically and manage our risks and opportunities.

 Examples of the external issues identified included changes and developments in government policy and our continued membership of the European Union, and ongoing improvement works on the Oxford Road Corridor in Manchester creating i enhanced bus and cycle infrastructure. It was useful to discuss the actions required to address the risks and opportunities associated with them and ensure they were incorporated into our action plans.

How did you tackle the new requirements for life-cycle thinking?

We already included procurement activities in the scope of our environmental management system as we were working towards level 3 in the Government’s flexible procurement framework.

 I worked with the procurement team to identify key products and services we purchased that could potentially have a high environmental or social impact. I then determined the environmental impacts associated with each lifecycle stage: Transport, Processing, Manufacture and Construction, Distribution, Use and Disposal; considered if we had control or influence at each stage; and then identified at what current actions we were working on, and future potential actions.

For example, we developed Environmental Design Principles for our building and refurbishment projects, to ensure environmental issues are considered in the design process.

Tell me more about how you worked with the University to embed sustainability into teaching and research?

Embedding environmental and social sustainability issues into the curriculum is one of our largest positive impacts, alongside offering extra-curricular activities associated with sustainability.

The University appointed an Education for Sustainable Development Coordinator who provides support and CPD opportunities to academic staff to embed sustainability into their curriculum.

For example, the Faculty of Business and Law’s mission statement includes: To develop socially and environmentally responsible ‘early career professionals’ for successful careers in management and the professions. Dr Jack Christian from Accounting, Finance and Economics has delivered ethics and sustainability lectures across the Business School for the last five years.

The University was also a pilot for the new Responsible Futures accreditation mark, an initiative driven by the National Union of Students to engage students in the sustainability agenda. The University’s involvement in the scheme helped contribute to the successful certification to ISO 14001:2015.

Did you need to make changes to your processes associated with communication with interested parties?

No, we documented current communication practices. We listed our interested parties, confirmed their needs and expectations, in terms of environmental communication and identified if it was a compliance issues.

We already published our environmental performance on an annual basis via our annual environmental sustainability report. This piece of work is led by our Sustainability Engagement Manager with input from key stakeholders across the university. Our most recent statement is available on our website.

How did the external assessment go?

Two auditors from NQA undertook the assessment, over three days.

 They undertook a number of site visits and interviewed approximately 40 people. They interviewed our Director of Services, who is the Chair of the University’s Environmental Strategy Board. They spent about an hour asking about the Boards role its structure and how our environmental objectives link to University strategy, and future risks and opportunities for the University.

In large organisations, it is impossible for auditors to talk to everyone involved in the EMS, but they said they would have loved to spend more time looking at particular areas in more detail. We have therefore agreed to spend a greater amount of time on issues such as procurement, waste management and sustainability in the curriculum, in our next surveillance visit.

What were the audit findings?

We had four minor nonconformities and a number of observations. One was associated with the new requirements of ISO 14001:2015.

It was linked to our evaluation of legal compliance. We use an environmental legislation update database called ELUS to help create a register of legislation. It was recommended that we link our legal internal audits of compliance to our register of legislation. This would provide evidence of our regular evaluation of compliance.

Do you perceive that there were any benefits for your organisation or the environment from the changes to ISO 14001?

The top benefits are: senior management commitment helps ensure we have sufficient resources in place to manage and improve our environmental performance, and the new monitoring and measurement requirements ensure robust KPIs are in place to review performance and continually improve Undertaking a PESTEL analysis helped identify future risks and opportunities and ensured we had plans in place to address them.

What advice would you give to others on making the transition to ISO 14001:2015?

Always keep it simple; make sure that you have good leadership and commitment; embed the EMS into your organisation; and ensure that people are clear about their roles and responsibilities because you are not going to be able to do it all on your own

What is the next step for your organisation’s EMS?

 We would like to improve our internal auditing system taking on board the comments from the external auditors, ensuring we document the root cause of any non-conformance raised.  We would also like to expand our programme on climate change adaptation and business continuity, working with the Head of Business Continuity. We will continually review our energy, carbon and travel performance and continue to deliver on our challenging action plans to meet our targets.

Using our experience, the university has established an advisory service to support other organisations to implement ISO 14001:2015


Marek Bidwell is Director of Bidwell Management Systems, a Chartered Environmentalist and visiting lecturer in Environmental Management at Newcastle University. Marek has led the design, development and implementation of environmental management systems at a plethora of businesses across the UK. He is the author of a series of articles in ‘The Environmentalist’ on the challenges of adapting management systems to the new standard, and the author of ‘Making the transition to ISO 14001:2015; he was the facilitator for the practitioner-led ISO 14001:2015 Road Test Group.

This is the fourth in a series of articles entitled ‘ISO 14001:2015 – Lessons from the Early Adopters’. Click here for other interviews in the series.


Will ISO 14001:2015 make a difference? A practitioner survey



The revised ISO 14001:2015 standard for environmental management was released in September 2015. There are many new requirements and areas with increased emphasis, including considering how relevant internal and external issues may affect the organisation and its environmental management system; increased responsibilities for top management; determining environmental risks and opportunities; considering the environmental impacts associated with procurement and the life-cycle of products and services; and ensuring that environmental communications are reliable.

In order to gauge the implications of these changes for organisations and whether or not they may lead to improved environmental performance, an in-depth survey was completed by ten organisations who are making the transition to from the 2004 to 2015 version of the standard. Participants were self-selecting, but they represented a range of industry sectors and sizes.

This research was carried out by Marek Bidwell of Bidwell Management Systems and Kirsten McLaughlin of WSP Parsons Brinckerhoff with guidance from Dr Phil Longhurst of Cranfield University.

Survey Questions

Introductory questions were asked about the nature of each organisation and their environmental management systems. A summary of these results is presented in Figure 1.

Participants were then asked to read a brief summary of each of the thirteen key changes in the 2015 version of the standard, before answering the following four questions about each change:

  1. How relevant is this to your organisation?

  2. How much change to your systems / procedures will be required?

  3. Do you believe this will lead to environmental benefits / improvements?

  4. Please provide a brief explanation of the scores you have given

The replies to questions one to three had to be categorised by the participants into:

  • High relevance / significant change / significant environmental benefit (Scored 4)

  • Moderate relevance / moderate change / moderate environment benefit (Scored 3)

  • Small relevance / small change / small environment benefit (Scored 2)

  • No relevance / no change / no environment benefit (Scored 1)

  • Don’t know (Excluded from results)


Figure 1

The organisations participating represented a range of industry sectors from manufacturing to transportation. Four of the respondents had more than 1,000 employees, three between 250-999 employees and three between 100-249.

The respondents were asked when they had first attained ISO 14001. The oil and gas company obtained ISO 14001 first in 1998, while the silicone liner manufacturer obtained ISO 14001 the most recently in 2014. Four of the organisations held the health and safety standard (OHSAS 18001) whilst nine held the quality management standard ISO 9001. These questions were asked because it was thought that the requirements of sister standards might help organisations to address some of the new requirements of ISO 14001:2015.

All of the organisations held at least one environmental permit (for air, water, or waste) except for the electronics firm.

Four of the organisations publish a publically available report that contains environmental information: Professional services, Oil and gas, Passenger transport executive and the Airport. This question was asked due to the increased requirements for planning communications under the new standard.

Finally respondents were asked “How would you describe the attitude of your organisation towards Environmental Management?”. Three of the respondents reported that their organisation thought environmental management was ‘highly important’, six ‘moderately important’, and one ‘slightly important’.

Figure 2


Figure 3


Figure 4


Topic-Based Discussions

Each of the following sections contains an introduction to the new or changed requirement of ISO 14001, the results of how the survey participants ranked the change against three criteria, and a discussion of these rankings with particular reference to the written responses provided.


1.) Structure of Standard

The clauses have been restructured around Annex SL “framework for a generic management system”. Instead of clause numbers 4.2 (Policy) through to 4.6 (Management Review) the new standard will have seven main sections: 4 (Context), 5 (Leadership), 6 (Planning), 7 (Support), 8 (Operation), 9 (Performance Evaluation), and 10 (Improvement).

Typically, many organisations structure their Environmental Manual around the requirements of a standard, so it was hypothesized that this change will create some work restructuring this document. However, at the same time ISO 14001:2015 no longer contains a requirement for a documented environmental manual, so organisations may use this as an opportunity to reduce the complexity of their documented system.

Survey participants ranked this change, compared to the other twelve, as follows:

  • Relevance to the organisation: 11th out of 13

  • Change required by the organisation: 4th out of 13

  • Amount of environmental benefit: 5th out of 13

The largely administrative benefit of this change was summed up by an organisation who develops and manufactures silicone release liners: “The actual management systems for quality and environment are already interconnected, therefore slight relevance and small change. Benefit will come from more and better integration, auditing and maintenance of the systems. Furthermore a more uniform system will be the result also making it easier to implement other additional management systems following the same structure.”


2.) Understanding the organisation and its context

This is a new requirement to: “determine external and internal issues that are relevant to the organisation’s purpose”. This means identifying internal and external issues that may affect the intended outcomes of its environmental management system, and also external environmental conditions that may affect, or be affected by the organisation. Once identified, these issues will inform the development of the environmental management system, including determining risks and opportunities.

Internal issues that may affect the success of the environmental management system (EMS) will be familiar to Environmental Managers. These may include conflicting organisational goals and policies, rapid change and limitations of human, technical and financial resources.

External issues that may affect the outcomes of the EMS include changing regulations and regulators, new innovation and technology — potentially leading to better pollution controls — and economic factors (such as the last recession) that restricted investment and changed consumer behaviour.

This clause also requires the organisation to consider how environmental conditions may affect the organisation (not just the EMS). This is a more strategic consideration and is linked to business planning and contingency planning. Examples include climate change risks such as flooding, disruption to global supply chains and soil erosion. Environmental changes may also create opportunities for some.

Survey participants ranked this change, compared to the other twelve, as follows:

  • Relevance to the organisation: 9th out of 13

  • Change required by the organisation: 6th out of 13

  • Amount of environmental benefit: 2nd out of 13

These results show that respondents thought this change would lead to greater environmental benefit that most. “Will need to expand the aspects register to include how the environment can impact the organisation. For example, climate adaptation, flooding, resource scarcity, population increase and increased extreme weather events” says the professional services organisation.

“We are already aware of our context and the issues that can affect the EMS, including environmental conditions.  But the additional focus on this in the EMS may have some added benefit in terms of enhancing management’s awareness of how environmental conditions may affect the organisation,” says the aerospace manufacturer who ranged this topic as highly relevant, but only requiring a small change.


3.) Understanding the needs and expectation of interested parties

This new requirement requires an organisation to identify interested parties, determine their relevant needs and expectations and then determine which of these needs and expectations become compliance obligations. Once identified these needs and compliance obligations will inform the development of the environmental management system including the communications plan.

Survey participants ranked this change, compared to the other twelve, as follows:

  • Relevance to the organisation: 13th out of 13

  • Change required by the organisation: 13th out of 13

  • Amount of environmental benefit: 13th out of 13

It is perhaps surprising that stakeholder engagement was ranked the lowest in all three categories given the effect of bad publicity on organisations following environmental incidents in the last few years. However, all six participants who provided a written explanation said that their existing environmental management system already addressed interested parties, thus explaining the low ranking. For example the passenger transport executive said: “We are currently undertaking stakeholder mapping for the organisation. We will need to formalise current relationships,” and the aerospace manufacturer said: “We already do this — there is no conceptual difference from the previous concept of legal and other requirements to which the organisation subscribes.” The professional services organisation said they will “formally identify their interested parties and their reporting requirements, especially any legal requirements for reporting.”


4.) Leadership and commitment

This clause places a greater emphasis on role of top management “Top management must demonstrate leadership and commitment with respect to the environmental management system” Nine specific areas are listed including being accountable for the effectiveness of the environmental management system, ensuring the environmental policy and objectives are compatible with the strategic direction of the organisation and integrating the EMS with other business processes.

Survey participants ranked this change, compared to the other twelve, as follows:

  • Relevance to the organisation: 1th out of 13

  • Change required by the organisation: 5th out of 13

  • Amount of environmental benefit: 1st out of 13

One participant said: “It is important to engage with top management from a range of disciplines, for example: finance, human resources, facilities, procurement, and design, sales and marketing. This will then help when considering the impact of products and services throughout their life cycle. We will need to embed environment into Business Strategy. In the future it may be crucial to Business Continuity.”

There were a number of comments along the lines that there was a need for top management to be more involved with the environmental management system than it is currently. One respondent said: “The EMS has been ordered from top holding management level and is not actively supported by our management; therefore the EMS must get a much higher importance and place in daily business. When this is achieved a significant benefit is to be expected.” Another said: “If the intent of the required activity is understood by the executives and is filtered down to the plant management for actions, then there is hope of moderate change.”

The view of survey participants in this area is reinforced by examining organisations who are often cited as exemplars of environmental and sustainability practice such as Interface (the designer and maker of carpet tiles) and Unilever. The turnaround in environmental performance at Interface was driven by the late founder and chairman, Ray Anderson, who wrote a book based on his experiences ‘Business Lessons from a Radical Industrialist’. Paul Polman, the Dutch CEO of Unilever, has gone on record arguing that being less bad is just not good enough anymore: “If the consumer goods industry does not move to a more sustainable model, most of its profits will be wiped out in 30 to 50 years, and if you are in food even earlier”.

Whether or not the changes to ISO 14001 will lead to greater top management engagement in environmental management remains to be seen, and is discussed by Marek Bidwell in this related article:


5.) Environmental Policy

 Additional commitments are required in the policy to ‘protection of the environment’ specific to the context of organisation. These requirements are not prescribed, but examples include sustainable resource use, climate change mitigation & adaptation and protection of biodiversity & ecosystems.

Survey participants ranked this change, compared to the other twelve, as follows:

  • Relevance to the organisation: 7th out of 13

  • Change required by the organisation: 11th out of 13

  • Amount of environmental benefit: 10th out of 13

Written responses to this change were brief along the following lines: “Will just need to broaden existing policy”; “This will hopefully make the policy more meaningful”; “Climate change will need to be formally considered.”; and “Often the scope is defined in the policy, so will need to reflect the requirements of the new standard, for example, the effect of external factors on the EMS.”

It appears that respondents are focussing on the act of updating the environmental policy document. Readers should note, however, that once a commitment is made in the policy it becomes auditable and evidence must be available that the organisation is meeting the commitment.


6.) Threats and opportunities

When the survey was distributed it was based on the Draft International Standard that required the organisation to “determine the risk associated with threats and opportunities”. This requirement was later changed in the final version, requiring the organisation to “determine risks and opportunities” in relation to its environmental aspects, compliance obligations, and issues associated with the context of the organisation. Nevertheless, the feedback provided by the survey is still considered informative, if this change is born in mind.

Survey participants ranked this change, compared to the other twelve, as follows:

  • Relevance to the organisation: 8th out of 13

  • Change required by the organisation: 3rd out of 13

  • Amount of environmental benefit: 8th out of 13

The metal products manufacturer, who ranked this change as high for relevance and moderate for environmental benefit said: “The methodology determined to be used for the best results in dealing with risk will be important and will be one of the most difficult areas in the new standard. The concern globally for risk and threats is consistently rising and causing review of many factors internal and external to the facility.”

The aerospace organisation, who also ranked this change high for relevance, but low for environmental benefit said: “We already identify environmental threats and opportunities that need to be addressed per our process for determining and managing significant environmental aspects.  This change may lead to business benefits in addressing risk/threats/opportunities for the organisation, but will not lead to any significant environmental improvements.”

Environmental managers are considering whether or not their existing systems cover this requirement. The professional services organisation said: “Need to expand existing aspects register, adopt a more quantitative risk based approach. May need input from other colleagues (sustainability team) to address correctly,” whilst the passenger transport executive said: “We already identify risks”.

Clearly, this is an area that will require chance for many organisations if they do no already consider environmental risks and opportunities, over and above environmental aspects, that was already a requirement of ISO 14001:2004.


7.) Planning to achieve objectives

The plan to achieve objectives (formally objectives & targets) must be more specific than previously, including:

  1. i) what will be done

  2. ii) resources required,

iii) who will be responsible

  1. iv) when it will be completed

  2. v) how results will be evaluated.

  3. vi) how it will be integrated into the organisations business processes.’

Records need to be kept showing plans to achieve the environmental objectives.

Survey participants ranked this change, compared to the other twelve, as follows:

  • Relevance to the organisation: 6th out of 13

  • Change required by the organisation: 8th out of 13

  • Amount of environmental benefit: 3th out of 13

The results show that this change ranked higher for environmental benefit than the other two considerations.

The sentiment of a number of the respondents was summed up by the aerospace organisation who said: “We already do this, so for my organisation, the benefit may be more limited; however, for organisations that have not included this information in the past, there may be moderate benefit in the increased specificity and accountability in the planning process.”

On the other hand, one respondent who had previously expressed concern over a lack of top management involvement in the EMS said: “As said before management is not keen on EMS and therefore this will need a change of attitude. Benefits will be small because objectives will be distilled from commercial objectives rather than the other way around.”


8) Competence

The text is almost the same under this clause as in the 2004 version, but with the addition of a requirement to evaluate effectiveness of actions taken to acquire competence and identify competency requirements of persons working for on behalf of the organisation that could affect its environmental performance.

Survey participants ranked this change, compared to the other twelve, as follows:

  • Relevance to the organisation: 12th out of 13

  • Change required by the organisation: 12th out of 13

  • Amount of environmental benefit: 12th out of 13

It is perhaps not surprising that this change was ranked of less importance by the survey group because it is already a requirement of the quality management standard, ISO 9001, and eight out of the ten participants had ISO 9001. This was summed up by the professional service organisation who explained: “This is already addressed in existing systems. Might need to pull the competency information to together or signpost from EMS, for example determining internal auditor competence.”


9.) Communication

This is a new requirement: to plan and implement a process for internal and external communications including: what, when, with whom, and how; taking into account compliance obligations. Information that is communicated must be reliable.

Survey participants ranked this change, compared to the other twelve, as follows:

  • Relevance to the organisation: 10th out of 13

  • Change required by the organisation: 10 out of 13

  • Amount of environmental benefit: 6th out of 13

The variety of responses to this topic were varied, depending upon the sophistication of participants existing communications systems. For example, the passenger transport executive who ranked the change required as moderate said: “We may need to formalise existing arrangements,” while the a vehicle safety systems organisation, who range the change required as high said, “Our communication procedure really needs an improvement to comply with this new requirement”.

The professional services organisation outlined the approach they would take to develop their communication process: “We will probably need to conduct a mapping exercise to identify who we need to communicate with, what we need to communicate and a method for delivering the information. This includes taking into account compliance obligations for reporting, for example, Green House Gas reporting, ESOS and the Carbon Disclosure Project.”

Three of the ten survey participants were small or medium sized organisations (SME) employing between 100 and 249 staff. These organisations ranked the relevance of this change lower, on average, than the remaining seven organisations who all employed more than 250 staff. The three SME’s all were manufacturing organisations and it is therefore likely that they perceived lower levels of stakeholder interest in their activities, compared to some of the other respondents such as the airport and offshore oil and gas organisation.


10. Value Chain – Procurement

There is a new requirement, to consider a life-cycle perspective when identifying environmental aspects including upstream issues, and a specific requirement to determine environmental requirements for the procurement of products and services, as appropriate. This may mean, for some organisations, considering the environmental impact of the products purchased, in addition to the environmental performance of company that supplies them.

Survey participants ranked this change, compared to the other twelve, as follows:

  • Relevance to the organisation: 5th out of 13

  • Change required by the organisation: 2nd out of 13

  • Amount of environmental benefit: 9th out of 13

Reponses to this topic were heavily related to the industry sector of the organisation and the complexity of their supply chain. The metal fabrication organisation, who ranked this change as moderately relevant said: “This will be a change that if understood correctly should add new perspective in both the program development and documentation as well as regulatory concerns and a higher review with new personnel i.e. purchasing or schedulers.” There is acknowledgement here that certain personnel will have greater involvement with the environmental management system than before as the scope of the system is extended to cover the supply chain.

For other organisations however, this new requirement was less important, either because they offered consultancy services, rather than a product, or they already include environmental issues when purchasing.


11.) Value Chain – Design and Downstream

There is a new requirement for the organisation to establish controls to ensure that environmental requirements are addressed in the design and development process for the product or service, considering each stage of its life cycle. This may include design, development, delivery, use, and end-of-life treatment of products and services.

Survey participants ranked this change, compared to the other twelve, as follows:

  • Relevance to the organisation: 3rd out of 13

  • Change required by the organisation: 1st out of 13

  • Amount of environmental benefit: 4th out of 13

Respondents thought that these new requirement, for environmental design, would require the greatest amount of change for their organisations, with seven out of the ten categorising this a significant change.

The metal fabricator, that also offers technical support services such as die designers and metallurgists gave a similar response to the question on procurement: “This will be a change that if understood correctly should add new perspective in both the program development and documentation as well as regulatory concerns and a higher review with new personnel i.e. purchasing, product managers, schedulers and sales, if not engineers.”

Organisations who have little control over the design process, or who make standard commodity products, may struggle to apply this requirement. For example, one organisation said: “Our main customers are big and then we can hardly influence them. Having a relatively small market share our impact is minimal and the competition high.” The professional services organisation said: “It is difficult to apply this requirement to our business as we provide services / consultancy rather than a product. Will need some thought as how best to address to add value. This may be through environmental / sustainability design guidance, offering client options to clients”


12.) Performance Evaluation

This clause requires the organisation to effectively determine its monitoring and measurement activities:

  • What to monitor and measure

  • The methods to use

  • The environmental performance criteria (KPIs)

  • When it shall take place

  • How and when the results shall be analysed and evaluated

Although monitoring and measurement was a requirement of the 2004 version of the standard, the 2015 version is more prescriptive about defining the methods to use, establishing performance criteria, and analysis of results.

Survey participants ranked this change, compared to the other twelve, as follows:

  • Relevance to the organisation: 4th out of 13

  • Change required by the organisation: 9th out of 13

  • Amount of environmental benefit: 11th out of 13

For some of the respondents, this does not represent a change, so much as a strengthening of the existing evaluation process. The passenger transport executive said: “We will have to do what we already do, but more detail” and the professional services organisation said: “This is already being conducted, but we may need to pull information together into one place, or signpost from EMS. We will have to ensure of methods are consistent, reliable and possibly externally verified.” However, the developer and manufacturer of silicone liners said: “Evaluation is the hard part of any management system and will require the largest change in our daily business. Eventually it will have significant benefits but we are far from that point now.”


13.) Compliance Status

The requirements in this clause are more explicit than before, and they are broken down into three sections:

  1. i) determine the frequency that compliance will be evaluated

  2. ii) evaluate compliance and take action if needed, and

iii) maintain knowledge and understanding of compliance status.

Requirement i) is more specific, and iii) is new.

Survey participants ranked this change, compared to the other twelve, as follows:

  • Relevance to the organisation: 2nd out of 13

  • Change required by the organisation: 7th out of 13

  • Amount of environmental benefit: 7th out of 13

This was ranked at the second most relevant change by the respondents, with seven of the ten categorising it as highly relevant. Nine out of the ten participants also reported that they have one or more environmental permit, and it is likely that their regulated status increased the relevance of this change. As regulated businesses however, some already monitor their compliance status, for example the aerospace organisation said: “We are already doing this”, and the passenger transport executive said: “We’ll have to formalise what we already do.”

Other respondents believed that they had more work to do in this area. The manufacturer of vehicle safety systems said: “The new part of this requirement is not included in our existing procedure” and the manufacturer of silicon release liners said: “This was one of the findings during the initial audit. We do have a great system now but we are finding out that it is very hard to make sure the requirements list is complete.”



Taking an average across the ten survey participants, the following topics were ranked as the most important for the each of the three criteria:

Relevance to the organisation:

  1. Leadership and Commitment

  2. Compliance Status

  3. Value Chain – Design and Downstream

Change required by the organisation:

  1. Value Chain – Design and Downstream

  2. Value chain – procurement

  3. Threats and Opportunities

Environmental benefit:

  1. Leadership and Commitment

  2. Understanding the organisation and its context

  3. Planning to achieve objectives

However, there was some variation of rankings between participants for certain topics. Larger organisations ranked topic nine ‘communication’ higher than smaller organisations; organisations who had more complex supply chains ranked topics ten and eleven for ‘procurement’ and ‘design’ as more important than those in the service sector; and organisations with more mature (and possibly more strategic) systems ranked the ‘change required’ as lower for topic two ‘understanding the context of the organisation’.

It will be interesting to follow up this survey, after the transition period, to see if these opinions have changed.


About the authors

Marek Bidwell is Director of Bidwell Management Systems, a Chartered Environmentalist Assessor and visiting lecturer in environmental management at Newcastle University, Marek has led the design, development and implementation of environmental management systems at a wealth of businesses across the UK. He is the author of a series of articles in The Environmentalist on the challenges of adaptation of management systems to the new standard, author of Making the transition to ISO 14001:2015 and facilitator for the practitioner-led ISO 14001:2015 Road Test Group.

Kirsten McLaughlin has over 15 years’ experience in the environmental management field, her main areas of interest are Environmental Management Systems, ISO 14001, environmental performance improvements and Environmental Auditing. In ever advancing areas of environmental management she has successfully applied her management skills to deliver projects for public and private organisations in a variety of sectors including aviation, manufacturing, pharmaceuticals, transportation and construction. She has experience of working in the UK, Europe and the Middle East. Kirsten is currently employed as Company Environment Manager for WSP| Parsons Brinckerhoff in the UK.

Dr Phil Longhurst is a Reader in Environmental Technology and Head of Centre for Bioenergy and Resource Management.  His research interests include: the recovery and diversion of materials from landfill; energy recover from phytoremediation crops; risk assessment and studies on better regulation.  He leads study modules in the Energy, Environment, leadership and management postgraduate programmes at Cranfield University.


The authors would like thank all those who took part in the survey including the following: Kirsten McLaughlin of WSP/Parson Brinckerhoff, Daan Eerland of Loparex, Holly Reidenbach of BP, Andrea Szekely of Takata, Harriet Smith of Merseytravel and Andy Barton of Exeter International Airport.



Please feel free to make use of this research, but reference appropriately.  

Marek Bidwell 2016 

The wait is over – ISO 14001:2015 published today!


ISO14001:2015 CoverThe eagerly awaited revision of ISO 14001:2015 was published today by the International Organization for Standardization. The standard can be purchased from ISO’s website for 138 Swiss Francs (£92.18).

I have been beavering away updating my guide to the changes “Making the Transition to ISO 14001:2015 – From Compliance to Opportunity” and I am proud to announce that you can also purchase this today from my website for only £15. Packed with useful analysis, diagrams, and examples, the guide will help you to understand the new requirements in ISO 1400:2015, and interpret them for your organisation.

Dozens of organisations have already used it to help prepare, for example:

“The ISO 14001 guide by Marek Bidwell (BMS) has been a useful tool for navigating and interpreting the standard. Not having an in depth background in environmental management, I wouldn’t have known where to start without it.” Peter McAuley, Project Engineer, Hydram Engineering

“Used the previous edition to this to provide further interpretation to the DIS standard and found it really useful. Proud to say our system has been certified to the new standard by our certification body… thanks again for the great service you provide” Kyle MacNeill, Environmental Assurance Manager, Northern Rail

Why design is the key to unlocking the benefits of ISO 14001:2015



Environmental managers I work with have expressed concern about the increased scope of the draft ISO 14001:2015 standard, in so much as it extends to processes and departments such as procurement and design that they have little or no influence over, and especially the need for greater involvement of top management with whom they already struggle to engage on the basics of pollution prevention and compliance.

I sympathise with this view to the extent that if you (as an environmental or sustainability manager) go to your top management with the approach: “ISO now says you have to do x, y, and z in order to maintain certification”, it is unlikely to go down well — you will be banging the same old drum, only louder.

Part of the reason for this anxiety is that environmental management is seen by some business leaders to be mainly about mitigating risk and, therefore, an operational on-cost. In the same organisations strategic decisions are made at a high level to restructure the business, develop new products and services, and move into new markets, without any consideration of the environmental or sustainability implications. Leaders then get frustrated with environmental managers for raising constraints associated with capacity or regulation.

However there is another way of thinking about environmental management — it is ‘what you do’ as an organisation, as well as ‘how you do it’. Not only is this way of thinking likely to do more favours for the environment (the life cycle impacts of your product or service may be ten times greater than your operational impacts), it is much more likely to engage top management in environmental and sustainability thinking — because what you do has implications for business strategy, customers and sales. Your portfolio of products and services is also fertile ground in which to grow environmental opportunities for your organisation.

The ‘ISO 14001:2015 Road Test’ group I facilitated last year concluded that four of the key areas in ISO 14001:2015 that will require the greatest amount of change for organisations are: an increased focus on leadership and strategy; determining and addressing risks and opportunities; environmental purchasing; and environmental design and development of products and services. I believe that it is the last of these – the design of your product or service from an environmental, and potentially sustainability, point of view (that I will refer to as eco-design) – is the key to unlocking the benefits of ISO 14001:2015. In this article, I will explain why, and how to make a start on this journey.

Whether your organisation makes products, buildings or infrastructure, or delivers a service — design is king or queen. It defines who you are and what sets you apart from your competitors. Design drives every other aspect of the business from the raw materials that you purchase, operations and risk on the shop floor, to your marketing and sales strategies.

My thinking about the centrality of eco-design for environmental management is illustrated in the following diagram:


Design is the key to unlocking ISO 14001:2015

Design is the key to unlocking ISO 14001:2015


Reduce operational risks

The design of your product or service has critical implications for operational risks; I shall illustrate this with an example from my early working life in the electricity distribution industry.

As an environmental manager I was involved with a range of issues such as oil leaks from underground cables, toxic chemicals (PCBs) used in transformers, monitoring and reducing the impact of a potent greenhouse gas (SF6) used in switchgear, and dealing with groups who opposed overhead lines due to their visual and wildlife impact. Management of these issues took a lot of time, and also money. Millions were spent on retrofitting transformers with secondary containment, installing large spill kits, and remediating contaminated land.

Some of these issues were always known to have an environmental impact, such as oil leaks; others had only become apparent more recently, such as the impact of SF6. Nevertheless, I learnt that network designers made key decisions at the planning stage such as whether the lines will be overhead or underground, the route, the capacity and type of transformers used, the switchgear technology to be employed (vacuum, air, gas), and the methods used for protection — all of which had major implications for the lifetime environmental and safety implications of the network.

For this reason I was at pains to include the network designers in the environmental management process. I knew that if eco-design principles were employed, such as removing toxic materials and the consideration of lifetime management costs, then problems could be dealt with up front, eliminating or reducing the pollution risk, associated regulatory risks, and clean-up costs.

As well as reducing pollution risk, eco-design principles can substantially decrease the lifetime energy costs of a product or project. This is as true when specifying low-loss, or higher-loss transformers (that may be operating for the next 40 years), as it is when constructing a building, or designing a washing machine. The challenge here is to effectively communicate to the organisation, or customer, that by paying a little extra up front, they will enjoy many years of savings. In my experience organisations also need to join-up thinking between capital and revenue budgets.

To give an example from a different industry sector: in ‘Business Lessons from a Radical Industrialist’ by the late Ray Anderson (founder of the carpet company Interface, and frequently hailed exemplar of sustainability) he describes establishing a Toxic Chemicals Elimination team to eliminate ecologically damaging chemicals from all Interface facilities. The team had a hard time obtaining all the information they needed from their supply chain, but eventually developed and implemented a screening protocol. Not only did they screen out toxics such as lead and mercury, they reportedly saved money in the process, and reduced the number of discharges to air and water from their factories. While some of these improvements were mainly associated with the manufacturing process, they termed the initiative ‘benign by design’ — changing the substances used in their carpet tiles was a designer led process, but part of the benefits were enjoyed by manufacturing.


Build resilient supply chains

Companies are increasingly concerned about the resilience of their supply chains. The supermarket chain ASDA, for example, recently reported that 95% of their fresh produce range is at risk from climate change. As a result, they are implementing a framework to adapt to these risks that will involve looking into the detail of their most vulnerable products.

Informed purchasing departments can do a lot when it comes to green purchasing and building resilient supply chains, but there is another side to sustainable purchasing policy that goes to the heart of what the organisation does.

Last year I attended an informative sustainable procurement conference in Birmingham. There were a range of speakers who worked in sustainable procurement, from the BBC to a large ceramic tile manufacturer. These organisations had complex global supply chains, employing thousands of individuals, across several continents. There were discussions about the best way to engage with supply chains to ensure that social, economic, and environmental criteria were embedded. Techniques employed ranged from traditional questionnaires and supply-chain audits, to more innovative engagement with small groups of suppliers, using storytelling and role-play to effect change.

However, as the event progressed I was struck by the revelation that many of these purchasing managers are in a similar position to operational environmental managers. They are given a shopping list of what to buy and have to get on with it, doing their best to minimise risk. Towards the end of the day I plucked up the courage to ask a question to the panel: “Do you have the opportunity to influence what you are purchasing, or just who from?” The consensus answer was: in the main they can’t influence what they are buying because they have no role in the design of the product or service.

It stands to reason that in order to make a paradigm shift in the environmental and sustainability impact of your supply chain, some organisations may need to think about design of their product or service, with the aim of eliminating problematic product lines and materials, rather than shopping around for the least-worst procurement option.

One organisation I have worked with on environmental management is a metal fabricator – they have ISO 14001 and good environmental controls. One of their largest customers recently insisted that they switch from more environmentally friendly powder to coat their products to solvent-based paint. Although this change would mean greater environmental impact, and regulatory burden, they had little choice other than to lose the contract. A design specification made by that customer embedded greater environmental impacts in their supply chain. The purchasing department of that customer could send out a supplier questionnaire, and do monthly supplier audits – but it would never change the fundamentals of their solvent specification. The lesson is clear – the principle ‘benign by design’ also has implications for your supply chain, as well as direct operations.

A complementary way to reduce the environmental impact of your supply chain, and also increase its resilience, is to move from a ‘take-make-break’ business model, to a cradle to cradle, or circular economy model. There is a misconception that the ‘circular economy’ is primarily about operations – diverting waste from landfill at the back door of the factory. But in order to create products that can be readily disassembled so that their valuable, uncontaminated materials become the feedstock for the next products, they often need to be redesigned from the ground upwards.

Jaguar Land Rover, who also presented at the supply-chain seminar I attended, explained that learning from life cycle assessment studies of their vehicles has informed their decision to switch from heavier steel, to lighter aluminium, for car chassis. They reported that although the initial environmental impact of the aluminium is greater than steel, benefits are gained during the use phase for both the customer and environment, and the company has an ambitious strategy to work with myriad stakeholders to take back and reuse aluminium from their old vehicles to make new ones. Because recycled aluminium only has 5-10% of the environmental impact of virgin aluminium, they can potentially reuse it an unlimited number of times, reducing the environmental impact of their supply chain, whilst simultaneously creating a new source of raw materials for their vehicles – increasing business resilience.


New opportunities for product and services

Sometimes there is a perception that environmental friendly products only appeal to the niche market, and one has to suffer to use them — this is not entirely without basis. I remember buying ten, expensive, first-generation LED lights for our kitchen — they were about as effective as a candle and emitted an eerie blue glow. Needless to say, they are still sitting unloved in a box under the stairs.

However, it doesn’t have to be like this, and increasingly consumers are differentiating on issues that are complementary to the green agenda such as efficiency, and free of toxic materials, but they don’t necessarily think of themselves as green consumers. Who wants to be lumbered with toxic, heavy, inefficient products that are expensive to run, and difficult to dispose of?

Today there are a plethora of decent products on the market that tick green boxes without specifically being marketed as such: washing powders that clean at lower temperatures; lighter, more efficient vehicles with lower emissions; low-solvent paint; houses that cost almost nothing to run; and websites for sharing everything from your spare bedroom, to a drill. One of my favourite possessions that falls into this category is my portable radio — vital for an itinerant Radio 4 addict. My old portable radios often broke, and the batteries were constantly running out. I switched to a ‘Roberts’ radio that allows for the internal recharging of batteries when plugged in. It also has an unusually robust aerial, and detachable colour rims that can be switched to suit your taste or decor. I have no idea whether Roberts specifically designed this radio with sustainability in mind (it is not overtly marketed as such), but for me it ticks three eco-design boxes: it produces less waste during use, has increased durability, and has modular elements. Good design is good design – there should be no surprise when this is also the friend of sustainability.

By incorporating eco-design principles into your product or service, you shouldn’t need to compromise on performance or sustainability. Gareth Kane has convincingly made the case that greener products must compete on price, performance, and the planet. And in his book, Green Jujitsu, he explains that it is not necessary to turn members of staff into eco-warriors in order to get their input into sustainability objectives but rather appeal to each individual’s strengths and creativity. If those objectives are right objectives, they should be good for business, and stand up on their own merits.

In their seminal book ‘Cradle to cradle’, Braungart and McDonough argue that designers should aim for eco-effectiveness above eco-efficiency. The difference between the two is explained using the example of a building: an eco-efficient building is worthy but also uninspiring, it is air-tight, with humming air conditioners, non-opening windows, and tinted glass, designed to house machines, not humans; an eco-effective building, on the other hand, employs biophilic design principles of space, light, nature and ventilation – delighting users and reducing employee sickness. Both can be energy efficient, but the latter enhances the lives of the people who work there. They sum up the umbilical link between design and sustainability: “Our concept of eco-effectiveness means working on the right things – on the right products and services and system – instead of making the wrong things less bad.”

This principle can apply to products, buildings, and even cities. In his recent book ‘Happy City’, Montgomery gives example after example that residents of greener, relatively dense cities, designed for people rather than cars, enjoy happier and healthier lives. Montgomery cites studies that found people who live next to green spaces in cities not only knew more of their neighbours and had stronger feelings of belonging, but also experienced lower levels of property and violent crime. While greenery is good, the American dream of living in a detached home on a leafy cul-de-sac backfires, because of the negative effects of long commutes on health, social cohesion, and one’s bank balance. Low-density sprawl, devoid of shops and natural meeting places, has a particularly pernicious effect on the young and old who cannot drive. Therefore planning and zoning policies, dictated by city planners, can have a substantial positive or negative effect on the health and wellbeing of residents, and perhaps not surprisingly the same policies that are good for people also reduce the environmental impact of the city.

So by employing eco-design principles designers can sometimes make products and services more efficient, effective, and delightful. There is no simple formula to achieving this, but some organisations are travelling in this direction – is your organisation amongst them?


A note about services

Many organisations are one or two stages in a long supply chain and their direct environmental impacts only represent a small share of the total environmental impact of the product. With regards to a service the same logic applies; by considering the design of services you can maximise your positive influence. What is taught in a school will potentially have a far greater impact on the lifetime environmental impact of a child compared with the environmental impact of the building – however working on the two together could have synergistic benefits. The service-related environmental impact of a planning department in a council (what types of buildings and infrastructure go where) is of paramount importance compared to how much paper they use in the office. Again, the lion’s share of the environmental impact of a travel agency is about the service they provide: poor tourism practices have devastated the environment in some areas (such as Cancun in Mexico), while good practices also exist that tread lightly and are restorative.

Sometimes switching your business model from a product-based approach, to a service, can reduce your environmental impact. For example by leasing products, rather than owning them, customers are ensured that the products are maintained in top condition, and they have ready access to the latest technology. You may also be in an industry sector where a physical product is being replaced by an electronic one, such as the switch from DVDs to video streaming. This is known as dematerialisation and may also have lower overall environmental impacts.

Services don’t just happen, they are planned (or designed), and way you design them has implications for the environment.


Engaging top management

At the beginning of this article I set out a potential problem raised by environmental managers, that the draft ISO 14001:2015 standard has new requirements that are not traditionally part of your remit, and it simultaneously requires greater engagement with top management — with whom you are already struggling to engage on the basics.

However, I have argued that you can use the new focus on the design of your products and services as the key to unlocking other new requirements: building more sustainable and resilient supply chains, and identifying opportunities for your product or service, whilst underpinning traditional pollution prevention and compliance requirements — from the point of view of top management, what is there not to like? It is a new message that environmental management can add value to your organisation, as well as reducing risk — ‘from compliance to opportunity’.

I put this to the test on a recent visit to an architect’s practice for whom I provide an internal audit service. Talking to the Directors about reducing office waste and energy consumption was moderately interesting, but the conversation came alive when it turned to the subject of embedding eco-design principles (such as passive house, fabric-first, and biophilia) into their architectural process. This is not surprising because architects are normally passionate about their profession, and if eco-design can be shown to help create better buildings and happier customers then it is a win-win.


How to do it

I have set out reasons why eco-design should be central to any environmental management system  but how to do it?

Some organisations are already leading the field in this area and have tools that allow them to model the life-cycle implications of design changes on-the-fly. They can ask questions like: “What happens to the carbon or water footprint of our product if we reduce the packaging weight by 5%, or change from one type of material to another?”. However a full life cycle assessment may not be the most appropriate approach for all, and the draft version of ISO 14001:2015 specifically states that a full LCA is not required.

A simplified qualitative approach may be appropriate by asking a series of questions about your product or service associated with each stage of its life cycle. The answers to these questions could then be used to develop an action plan to reduce your environmental impacts, whilst simultaneously adding value to your organisation. No doubt it would be best to use a multidisciplinary team approach and you may wish to target them with a single product or service in the first instance. Ultimately consideration of eco-design principles should be embedded into your design process so that it becomes business as usual; the earlier that these principles are first considered the better the outcome for the product or service and environment. Initial considerations can be revisited and refined as the design and development process progresses. Ideally the outcome of changes will be measureable so that you can demonstrate environmental improvement, and justify any green-claims made.


Raw materials:

  • Do our raw material / ingredient / subcontract specification embed environmentally damaging practices into our supply chain? If so can we change the specification?
  • Are we maximising the recycled content in our raw materials?
  • Can we incorporate reused / remanufactured / upcycled elements into our products?
  • Can toxic materials be eliminated or reduced from our products and services?
  • Can embodied carbon and water be reduced from our products and services?
  • Does our product have any unnecessary components that can be eliminated? (Take it apart, have a look, challenge every component.)
  • Can our product be made lighter? (Thus reducing the raw materials input, transport, and disposal costs.)
  • Can the product be designed so that biological and technical materials (nutrients) are not mixed together (either in raw materials, or manufacture) in ways that they cannot subsequently be separated?
  • Is packaging kept to a minimum, and excludes toxic materials?


  • What environmental issues are our customers most concerned about with our project or service?
  • Would it be more beneficial for the customer and environment if we leased our product(s) rather than selling them?
  • Could we facilitate the sharing of our product / service rather than everyone owning one each? (A principle known as Factor Four – doubling wealth by halving resource use.)
  • Can our product or service be redesigned so that it produces less waste when in use?
  • Can our product or service be redesigned so that is uses less energy and water?
  • Can our product or service be redesigned so that it is less noisy, or reduces any other environmental impact during use?
  • Can our product or service be redesigned so that it is restorative – it gives back more to nature than it takes?
  • Can our product or service be designed so that it lasts longer?

(A key definition of LCA is functional unit. A product that lasts four times as long, but has double the environmental impact associated with its materials and manufacture would score more highly, especially if its use phase impacts are lower.)

  • Can our product or service be redesigned so that it mimics nature in a way that is beneficial to its form or function? (Known as biomimicry.)
  • Do our products and services maximise the opportunities for environmental education?
  • Do we provide information to our customers that explains how to get the maximum environmental benefit / reduce the environmental impact from our product or services throughout its lifecycle? (This is a specific requirement of the draft ISO 14001:2015.)

Upgrading / Reuse / End of life

  • Can the product be fully disassembled at the end of its life?
  • Is the product modular in nature? (Can parts easily be swapped and / or upgraded? Can the product have multiple functions?)
  • Do we / can we provide a take back service for the product at the end of life?


  • Have any of the changes made above inadvertently created new environmental impacts that need dealing with (trade-offs)?
  • Are there any eco-design quality indicators that you can employ that are specific to your sector such as BREEAM for construction, or an EU Ecolabel? Be aware, however, that external design standards can become tick-box exercises if not used with care.


If you have read this article and want to embed some of the ideas into your organisation, what is the first step and who needs to be involved? – let me know how you get on as I would like to gather some case studies of organisations who are doing this.


By Marek Bidwell (

Marek Bidwell is director of Bidwell Management Systems, facilitator of a cross-sector group of organisations road-testing the draft 14001: 2015 standard, and author of Making the transition to ISO 14001: 2015: from compliance to opportunity:


Further Reading

  1. Anderson, 2011: ‘Business lessons from a radical industrialist’, St. Martin’s Griffin
  2. Benuys, 1997: ‘Biomimicry’, William Morrow
  3. Bidwell, 2014: ‘Making the transition to ISO 14001:2015 – From Compliance to Opportunity’:
  4. Braungart and W. McDonough, 2009: ‘Cradle to cradle’, Vintage
  5. Kane, 2012: ‘Green jujitsu’, DoShorts
  6. Kane, 2013: ‘Taking Green into the Mainstream’
  7. Montgomery, 2003: ‘Happy city’, Penguin Books
  8. Telenko, C Seepersad, M Webber, 2008: ‘A compilation of design for environment principles and guidelines’, Proceedings of IDET/CIE
  9. Weizsacker, A Lovins, L Lovins, 1998: ‘Factor four – doubling wealth, halving resource use’, Earthscan
  • ISO 14040 series: Life-cycle assessment
  • ISO 14062: Environmental management – integrating environmental aspects into product design and development
  • BS 8903:2010 (Principles and framework for procuring sustainably)
  • Ellen Macarthur Foundation: www.ellenmcarthurfoundation
  • WRAP:
ISO 14001:2015 FAQs

Transition to ISO 14001:2015 – Frequently Asked Questions


Your questions answered about the changes to ISO 14001 by Marek Bidwell, author of ‘Making the Transition to ISO 14001:2015 – From Compliance to Opportunity


ISO 14001:2015 FAQs

ISO 14001:2015 FAQs

1. How long do I have to make the changes to our Environmental Management System?

At the time of writing (August 2014), the Draft International Standard (DIS) has recently been published, and we are entering a consultation period, ending on 28th November 2014; however the date for the public making comments to national standard bodies is sooner – and varies by country. Following this, ISO will review comments, and either the Final Draft (FDIS) will be issued, or the standard may go directly to publication. It is expected that the new version of 14001 will be published by the end of 2015.

Certified organisations will then have a 2-3 year transition period to make the necessary changes.


2. Why is ISO 14001 changing?

There are 3 main reasons: all ISO standards are reviewed periodically (every 5-7 years); to keep ISO 14001 up to date with emerging environmental issues (highlighted by ISO’s Future Challenges Study Group); and to fall into line with the recently published common framework for management system standards, called Annex XL.


3. What are the key changes to ISO 14001?

The key changes include a new structure, increased requirements for top management, a requirement to consider the context of your organisation, determination of risk associated with threats and opportunities, and an increased focus on the environmental impacts of your products and services. I have outlined the 13 key changes here.


4. What will be the impact on my organisation?

This will vary from organisation to organisation. Those focussed on the paperwork may feel that the changes to the structure will take some time to deal with – rewriting the manual. I would argue that, if this is necessary at all, it is one of the less important issues. Ideally your management systems should be integrated with your business processes.

Of fundamental importance to many, will be the increased focus on the environmental impact of your products and services, and supply chains, and the new requirement to consider risks and opportunities.

Organisations involved with the ‘ISO Road Test’, which I facilitate, ranked the key changes by ‘relevance’ to their organisations, and the level of ‘change’ involved. The group scores for ‘change required’ were aggregated, and the top ranking issues were: 1st) value chain downstream; 2nd) structure of the standard; 3rd) value chain upstream; and 4th) risks and opportunities.

The group scores for ‘relevance’ were aggregated, and the top ranking issues were: 1st) risks and opportunities; 2nd) compliance status; and 3rd) context of the organisation.


You can evaluate the most important issues for your organisation by taking part in our survey, the anonymous results of which will be sent to all participating organisations.


5. Will the changes mean more work for me?

Yes, probably! If you are reading this is it likely that you are an environmental, H&S, quality, or sustainability manager, and be responsible for your organisation’s environmental management system.

However, I would balance this by pointing out that one of the new requirements is for the environmental management system to be integrated into the organisation’s business processes, and for top management to provide support to other relevant management roles as it applies to their areas of responsibility.

The intention is that people with expertise in disciplines such as procurement, design, or engineering, consider environmental issues, and associated controls and opportunities, as part of their day-to-day job.

The changes will also present opportunities for those looking after 14001 systems: interacting with new parts of the business, and considering the interfaces between business strategy and environmental management.


6. Are the changes to ISO 14001 the same as the changes to ISO 9001?

Some are the same, and other are unique to 14001. It is helpful to read through ISO 9001 (DIS), in conjunction with ISO 14001 (DIS).

Some of the changes are driven by the common management system framework (Annex XL). These include ‘Context of the organisation’, ‘Needs and expectations of interested parties’, and the enhanced requirements for ‘top management’.

Other requirements are unique to ISO 14001 (DIS) such as identifying and managing the life-cycle environmental impacts associated with products and services.

A few changes in ISO 14001 (DIS) are subtly different to those in ISO 9001 (DIS). One of these is in the section ‘Context of the organisation’. Both 14001 and 9001 (DIS) require consideration of how internal and external issues that may affect the quality / environmental management system. However only 14001 (DIS) requires consideration of “environmental conditions capable of affecting or being affected by the organization.” The additional requirement in 14001 (DIS) is more strategic – for the success of the organisation as a whole.

A second subtle difference is that 9001 (DIS) requires the determination of “risks and opportunities that need to be addressed”, whereas 14001 (DIS) requires “determine the risk associated with threats and opportunities that needs to be addressed”. 9001 (DIS) implies a one-stage process, whereas the 14001 (DIS) implies a two-stage process: firstly identify the threats and opportunities, and then evaluate the risks. This terminology may change in the Final Draft, and 2015 publication.


7. Is a full Life Cycle Assessment required for our products?

No. Although there is increased emphasis on both identifying, and controlling, environmental issues associated with the value chain, a full life cycle assessment is not required. ISO 14001 (DIS) Annex A states: “a simple consideration of the life cycle stages which can be controlled or influenced by the organization is sufficient”. The limiting factor therefore is whether your organisation has control or influence up and down the supply chain.

Considering procurement: it is often argued that the further up the supply chain you go, the less the control or influence you have. However, I argue, that this is not always the case. Organisations necessarily specify precise grades and types of source materials; if they wish, they may specify one or more environmental criteria, extending to primary production. However, they will not be able to control every facet of upstream organisations’ activities.

Considering the environmental impacts of products and services: you have control of design, which may include efficiency, longevity, and recyclability. However, a chainsaw manufacturer could design a low-noise, energy-efficient chainsaw, but it could not stop it being used to chop down an ancient tree.

If these life cycle requirements are taken seriously by organisations, and certification bodies, the opportunity exists to shine a spotlight on less sustainable products ­–  and either redesigning them, or drop them altogether – benefiting consumers, organisations, and the environment.


8. What is the difference between Aspects and Impacts, and Threats / Risks and Opportunities in ISO 14001:2015?

Threats and opportunities are not synonymous with negative and positive environmental aspects and impacts.

Threats are of two types: threats to the organisations (such as climate change), and threats to the environmental management system (these may arise from internal factors such as limited resources, and external factors such as changes to regulation).

Opportunities are any environmentally related circumstances that make it possible to do something that will benefit the business. Examples may include increased crop yields due to higher temperatures, design of more efficient products, and the development of new products and services such as flood-defence barriers, recycling services, or exploiting new shipping lanes across the arctic. Turning these opportunities into reality may become the focus of new environmental objectives. However, some new opportunities may also create environmental risk.


9. How can I get Top Management more involved?

The new standard will have additional requirements for top management. “Top management must demonstrate leadership and commitment with respect to the EMS…”. Nine specific areas are listed: taking accountability for effectiveness of the EMS; ensuring the environmental policy & objectives are compatible with the strategic direction of the organization; integration with other business processes; provision of resources; communication; achieving EMS requirements; directing and supporting relevant persons and managers; and promoting continual improvement.

In my experience, top management are most engaged with environmental issues when they are asked their opinion, rather than told what to do (after all the management system is their tools for delivering the aims of their environmental policy), and the discussion relates to opportunities for business development, as opposed to focussing only on compliance. The good new here is that ISO 14001:2015 will encourage this type of strategic environmental thinking.

Gareth Kane, of Terra Infirma has written extensively on this topic, see his video “How do I get my CEO engaged in sustainability”.


Making the Transition to ISO 14001:2015

Making the Transition to ISO 14001:2015

10. How do I make the transition to ISO 14001:2015?

I recommend starting with a gap analysis. You may find that you are already meeting some, or all, of the new requirements, particularly if your organisation has a strong sustainability and supply chain focus. If there are gaps: develop an action plan detailing what needs to be done, by whom, and what auditable evidence will demonstrate compliance.


You can also download my guide that explains the 13 key changes in more detail, each of the changes are identified and discussed, and compared against the existing requirements of the 2004 version.

Making the Transition to ISO 14001:2015 – Download now!

ISO14001 DIS Cover_Aug2014

Making the Transition to ISO 14001:2015

Packed with useful analysis, diagrams, and references, this guide will help you to understand the new requirements in ISO 14001, and interpret them for your organisation.

Download the Guide for only £15.


Feedback so far:

“Used the previous edition to this to provide further interpretation to the DIS standard and found it really useful. Proud to say our system has been certified to the new standard by our certification body… thanks again for the great service you provide” Kyle MacNeill, Environmental Assurance Manager, Northern Rail

A very good read, takes the worry out of implementing the new standard” Andrew Robsertson, SHE Manager, Hydram Engineering

A must read for the upcoming changes to this very popular ISO standard.” Dave Lloyd, Principle Partner, Signacure Resilience

A great read from Marek Bidwell and definitely worth sharing” Dr Paul Stevens, Loughborough University, AVISO Consultancy


What’s included?

By way of introduction, there is a visual representation of the correspondence between ISO 14001:2004 and ISO 1400:2015. There are thirteen sections – each of the key changes to 14001 are identified and discussed, and compared against the existing requirements of the 2004 version. The text is supplemented with helpful diagrams to illustrate key requirements. This guide will help you to build up a picture of what you are already doing, in relation to what you need to do. At the end of each section there is a list of references, tools, and techniques. The guide is 8000 words.


To download:

Follow the link to purchase site. Click on the product(s) you want. Free products download automatically. Paid-for product will be emailed directly to your address within a few minutes.


Marek Bidwell

Marek Bidwell

About the Author:

Marek Bidwell is Director of Bidwell Management Systems, a Chartered Environmentalist Assessor, a visiting lecturer at Newcastle University in environmental management, and co-founder of Green-Thinkers’ book club.Previously he worked for Northern Powergrid as an environmental advisor.

Since the beginning of 2014 he has facilitated the “ISO 14001:2105 Road Test” – a cross-sector group of organisations making the transition to the new standard.




ISO 14001:2015 Transition Guidance (Structure)


ISO14001_2015 Diagram_DIS

This article contains a diagram designed to help readers understand the differences between the structure of ISO 14001:2004 and ISO 14001 – due to be published in 2015.

Getting to grips with the new structure will help you to visualise which requirements are the same, which are changed, and which are new. This in turn will assist with understanding the implications for your organisation as it makes the transition.

ISO 14001:2004 is structured around the Plan, Do, Check, Act cycle. The draft standard is structured in a similar way but has two additional chapters at the beginning: 4) Context of the organisation, and 5) Leadership. Section 6) Planning, has been subdivided into additional sub-clauses, and the requirements of Implementation and Operations have been divided into two new chapters: 7) Support, and 8) Operations.

Operations will be composed of the existing ‘operational control’, and ’emergency preparedness and response’, with the addition of the key new requirements on ‘value chain control’. The existing section on management review has been inserted into 9) Performance Evaluation, and nonconformance jumps to the end in 10) Improvement, with the addition of a final sub-clause called ‘Continual improvement’ that includes some repetition from section 6) Planning. 

In the following diagram the clauses of ISO 14001:2004 are listed in the left-hand column, and the clauses of ISO 14001(DIS) are listed in the right-hand column. Boxes highlighted in red are those that are new, or substantially altered and relate to the 13 key changes, and new requirements.

Read much more about the transition to ISO 14001:2015


ISO 14001:2015 and 2004 Comparison Diagram

ISO 14001:2015 and 2004 Comparison Diagram

ISO14001_2015 Diagram_DIS v2   ISO14001_2015 Diagram_DIS v2


In business is it more important ‘what you do’ or ‘how you do it’?


“Assessing your environmental strategic planning in preparedness for ISO 14001:2015”


Having written previously about the changes to ISO 14001, due to be published in 2015, which are likely to include increased focus on the supply chain, ecosystems, adaptation, and products and services, in this paper I will consider one aspect in more detail, which is giving consideration to environmental performance in strategic planning: ‘what you do’ – compared with an organisation’s direct environmental impacts: ‘how you do it’. I will use the Green Operations and Strategy Assessment Tool (GOSAT) to illustrate these ideas throughout, which may be used by organisations to develop a high level strategy in this area:



In the past, quality management systems (ISO 9001 and its predecessors) got a bad name, because there was a view that you could specify rubbish and make rubbish; conformance with specified requirements was key. To a greater or lesser extent this changed with the publication of the 2000 edition, which placed much greater emphasis on monitoring processes, products and customer perception, thus driving improvement in all areas of the organisation that contribute to meeting customer requirements. This in turn encourages innovation.

ISO 14001 suffers from a similar image problem today in some quarters, as 9001 did pre-2000, but in this case the customer could be seen as the environment. As long as the organisation complies with legal and other requirements, improves in some areas, and prevents pollution (normally considered to be from its direct activities) it can continue do what it does, or making what it makes, without considering its ‘raison d’être’ and overall life-cycle impacts.

As an example let’s consider a hypothetical manufacturer of patio heaters that has ISO 14001. Their environmental policy includes a commitment to ‘greening the earth’, although perhaps ‘warming the earth’ would be a more realistic objective given the product. Such a manufacturer could have a spotless factory, use solvent-free paint, and operate a fleet of electric delivery vehicles, but it will still be making a product that many see as unnecessary and highly unsustainable. Its position on GOSAT would be in the top left-hand corner.

If the 2015 version of ISO 14001 contains a requirement for the organisation to ‘consider the result of the evaluation of significant environmental aspects as input into the design, development or change of its products and services’ it would be interesting to see if the organisation readily retained ISO 14001 with no changes, dropped that product line, redesigned it, or substituted it for something that provided an equivalent service, such as thermal underwear. Redesigning the product could include partially addressing the core issue of heating outside air, such as we saw with the electric patio heater pitch by Eddie Middleton on Dragon’s Den in 2009. They may consider ‘improving’ the product through de-materialisation or perhaps increasing its life expectancy. One way of doing this might be by switching to solvent-based paints that may be more durable, but have a greater environmental impact at the production stage. Another might be by providing a take-bake service for the product at the end of its life. The company could use GOSAT to help plan their overall environmental strategy.

Our patio heater company is not alone in this journey; there are many well-documented examples of organisations that are beginning to, or have already, re-imagined themselves along more environmentally sustainable lines. The late Ray Anderson described in his book Business Lessons from a Radical Industrialist how his flooring company, Interface, re-engineered its process to harvest used carpet tiles, thus reducing fossil fuel dependency and waste to landfill. Other organisations, such as Green and Black’s, embedded sustainability principles in their businesses from the very beginning. Green and Black’s founder, Craig Sams, always believed that organic farming was not only essential for soil quality and ecosystem integrity, but that it also resulted in tastier food. With rising resource prices, climate instability, and degradation of ecosystems there are many sound business reasons to take a long-term holistic approach to running a business.

However, does this mean that all organisations who have strong environmental credentials from a product and service point of view (what they do), have also eliminated environmental compliance and pollution risks from their business (how they do it)? My counterintuitive theory is that this is not necessarily the case, and in some areas the opposite may be true. Before reading on can you think of any examples?

I will explain by considering a different hypothetical organisation: a recycling company that specialises in diverting food waste from landfill, capturing methane, and producing renewable electricity. Its core business model is aligned with sustainability principles. It does not have ISO 14001, possibly because it is considered to be unnecessary, and such controls would be an added cost and constraint. However, while it has grasped the green opportunity, it is less competent with regards to operations. It does little in the way of process monitoring, and frequently has problems with waste deliveries backing up in its yard. Odour from one of its plants is so bad that local residents often feel trapped in their homes, which is having a direct effect on their quality of life, health, and wellbeing. The regulator has received hundreds of complaints, and despite having contacted the plant, residents are taking legal action because they are convinced the problems will continue. The recycling company’s position on GOSAT would be in the bottom right-hand corner, and they could use the model to consider improvements to their overall business strategy, thus closing the gap to the ideal greener trajectory.

I won’t give specific examples here but the Environment Agency’s Sustainable Business Report for 2011 states that the number of serious pollution incidents per 100 permits issued is actually highest for the biowaste sector at 5.5; ironically this is well above the landfill sector, which only had 0.3 serious pollution incidents per 100 permits issued.

Therefore, while some organisations have made a logical progression from pollution prevention and compliance to an all-encompassing green business model, the two do not necessarily go hand in hand. Increasingly we will have to rely on diverse and novel technologies to solve critical challenges that we face, such as resource scarcity, adverse weather, food shortages, increasing migration of pests, rising CO2 emissions, and degradation of ecosystems. These technologies will not necessarily be risk free, and in some case may have greater safety and environmental operational risks than their predecessors. I have always said that there is no silver bullet when it comes to environmental management.

In summary I believe that ‘what you do’ and ‘how you do it’ must go hand in hand in order to solve global problems, prevent local pollution, and preserve the overall reputation of an organisation or brand.

The increased emphasis on environmental sustainability in the 2015 version of ISO 14001 will encourage many organisations to embed it into their business model, not only raising the profile of environmental management with the organisation but engaging leaders with opportunities presented by the green economy. Organisations exploiting new technologies however, large and small, would be advised to consider pollution prevention and neighbourhood impacts in equal importance to the bigger picture.

Please use the Green Operations and Strategy Assessment Tool (GOSAT) presented in this article to assess your organisation referencing the source. For more detailed analysis and guidance Bidwell Management Systems provides an ISO 14001:2015 Preparedness Service; contact Marek Bidwell ( for more details.

By Marek Bidwell (2013)

Audit Checklists: A help or hindrance?


Audit Checklist imageWhen carrying out management system internal audits for health & safety, environmental, and quality  some organisations use standard audit checklists, but do these checklists add value to the audit process or dumb it down?

Developing a personal audit checklist is a vital part of planning for each audit that I focus on during audit training courses. The process of reviewing the audit criteria such as relevant legislation, company procedures, and standards (eg: ISO 14001, ISO 9001, OHSAS 18001) enables the auditor to make sense of the requirements, structure them into a series of logical questions, avoid repetition during the audit, and arrive well prepared. I stress that these checklists should not just be a list of questions to ask, but also physical evidence to look for, and documents to review, thus incorporating  the full range of audit evidence. In its simplest form an audit checklist could be the relevant company process or procedure annotated or highlighted by the auditor, to use as an aid memoir during the audit. (more…)

Audit Skills: Are you a Back to Front, or Front to Back Auditor?


Verification of audit information is a key skill for carrying out an internal audit but the extent of verification, and techniques used, are often highly variable, and may have a significant impact on the validity of your audit findings.

Imagine that you are auditing a transport procedure for a company with a fleet of vehicles. The procedure requires that each vehicle is logged on a database including details such as service intervals, insurance details, and input of monthly mileage data. How would you sample this information and check that the overall process is working?

Observing hundreds of auditors in training I have noticed that many are comfortable discussing the process with the responsible person, taking a sample of information from a database, and then checking this information in a filing system. In this case they may also take sample mileage details from the database and check these against vehicle mileometers in the car park. I call this “back to front auditing”, or checking input data against reality. The auditee is normally relatively confident at this stage because we are checking what they know exists and have records for. In this example it is unlikely that a known vehicle will have missed its MOT or service, and any gaps in mileage data will show up clearly on the database. (more…)

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