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‘
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”.
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.