ISO 14001:2015 has now been here for a while – what are auditors asking to see?

Distribution Warehouse - minimising environmental impacts

It’s almost a year since ISO 14001 was updated to the 2015 version, so most systems should now be well on the way to addressing the changed requirements.

Just to make sure that you haven’t missed any of the key points, we have put together 6 of the big ticket items we believe auditors will be focusing on – all from the first half of 14001!

To set a bit of background to some of these changes, ISO has adopted a High Level Structure (HLS) which is now mandatory for all of its management system standards. Some of these changes in ISO 14001:2015 have come directly from this HLS and are essentially exactly the same in the other disciplines, such as Quality management systems (ISO 9001), Information security (ISO 27001), Asset management (ISO 55001) and the upcoming Occupation health and Safety (ISO 45001).

This article is based on a previous post ISO 14001:2015 – What will your auditor be asking? We’ve made some updates 12 months on. Check then out below.

1. Understanding the organization and its context – clause 4.1

This is new for the 2015 revision and requires the organization to understand both the external and the internal issues that actually do or could impact upon it with regard to its environmental management system (EMS).

As explained in the guidance at the back A4.1 “the intent is to provide a high level, conceptual understanding of the important issues that can affect either positively or negatively, the way the organization manages its environmental responsibilities”.

So, how can an organization address this and what evidence do they need to show an auditor?

Firstly, this does not need to be documented – the only part of the whole of section 4 that needs to documented is the scope of the EMS in section 4.3. If your auditor insists on documented external and internal issues they are wrong.

Secondly, if you are a business that has a business plan – these issues should be included in it, so you have already have addressed this – just check your business plan includes environmental issues.

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a SWOT analysis is a great way to show understanding of your organisations context.

What process or tool can help you with this? One of the simplest is a SWOT analysis, simply looking at your internal strengths and weaknesses and your external opportunities and threats. And these SWOT analysis are often best done with some of the key people in the organization and written up on a white board. If you don’t want to formally write it up, or include it in your business plan – just take a photo.

2. Is your environmental performance improving?

Environmental management system – clause 4.4

This is not really a new requirement – and we are only going to focus on one part of it – “enhancing its environmental performance and …. continually improve the environmental management system”.

This is a fundamental part of any management system and for some reason it never seems to be done that well for environmental management systems. Organizations seem to be happy to control their impact on the environment and this is often driven by contract requirements and legislation, but not to improve their environmental performance.

The guidance in the back doesn’t help us here either A4.4 – no mention of improvement, or enhanced performance.

Digger machines digging a trench for a large pip in the middle of forrest

Your organisations impact on the environment should be reducing.

So what should be happening? The organization’s impact should be reducing and the organization should be able to demonstrate this. How does the organization provide evidence of this? They should have objectives (documented) and these should be reviewed as part of management review (documented). The key message here is that these objectives should be changing over time, so organizations should not have same ones year after year.

3. Is the EMS embedded in the organization’s business processes?

Leadership and commitment – clause 5.1 (c)

Many organizations that are certified to ISO 14001, whether it be the 2004 standard or the 2015 version, have an environmental management system that is separate from their normal business.

This is not how it is meant to be and the 2015 version really strengthens this in clause 5.1 (c) where it states “ensuring the integration of the environmental management system, requirements into the organization’s business processes”.

No help again here from the guidance – and perhaps none is needed. Put simply, the environmental objectives, programmes, plans, operations, monitoring, measuring, audits, and corrective actions should all be included as part of business as usual – part of not separate from.

So what should this look like? Well your processes and procedures, the work that your organization does, your position descriptions, and your team meetings should include your environmental requirements just the same as they should include your quality and your OHS requirements.

4. Are  you looking at the positives as well as the negatives?

Actions to address risks and opportunities – clause 6.1

In the earlier versions of ISO 14001 in the definitions it is explained that an environmental impact can be either adverse or beneficial, meaning the activities of your business could produce a positive impact on the environment. However, in practice there were very few organisations that captured this with most focusing only on the negative impacts.

To strengthen this ISO 14001:2015 now includes clause 6.1 Risks and opportunities, with opportunities being where the potential beneficial effects exist for the organisation to improves its environmental performance.

These opportunities will in most cases cover the major changes that a business could undertake to improves its environmental performance. Examples of this could include; installing rainwater tanks, changing to solar power, upgrading the vehicle fleet to be more fuel efficient or even going to hybrid or electric only vehicles.

How does an organisation demonstrate this? Most will already have a risk register or an aspects and impacts register, and it will tend to include all the bad stuff. Just add a column or two and ensure that the “opportunities” that exist to improve environmental performance are included also. And if you manage to implement these opportunities, in most cases they will save you significant amounts of money.

“Implementing opportunities to improve environmental performance may save you significant amounts of money.”

5. Are you considering a life cycle perspective when you determine your environmental impacts?

Environmental aspects – clause 6.1.2

The impact an organisation has on the environment is the change associated with how it interacts or can interact with the environment. Previously, this was in most cases taken literally and only the impact that the actual organisation had was taken into account, which is of course not the entire impact – there is also the before impacts and the after impacts.

To ensure this now occurs ISO 14001:2015 has included in clause 6.1.2 …”considering a life cycle perspective” and the typical stages of a life cycle are: raw material, design, production, transport, use, delivery, and disposal. Therefore, when you are considering which raw material supplier to use or which new piece of equipment to purchase – you should consider: where did the raw material came from, how far it has it traveled, and what will happen to it at the end of its life?

You should be careful here, and the guidance is able to help. A.6.1.2 explains that it does not require a detailed life cycle assessment but it does want an organisation to think carefully about the life cycle stages that it can control or influence.

6. How have you determined your significant environmental aspects?

Environmental aspects – clause 6.1.2

ISO 14001 is all about controlling your significant environmental aspects – it was in the previous versions and it is in this version too. What is different in this ISO 14001:2015 version is the criteria that is used to determine those that are significant is to be documented. You have to write down the method that you use.

Help is at hand in the guidance A.6.1.2 where it states “There is no single method for determining significant environmental aspects, however, the method and criteria used should provide consistent results”.

In most cases organisations use some form of risk matrix with likelihood and impact, but there are many other ways, which may take into account things such as; size, type, frequency, severity, scale, exposure, duration, legal requirements or the concerns of interested parties.

“What is different in ISO 14001:2015 is that the criteria that is used to determine significant environmental aspects need to documented – write down the method you use.”

Interested in learning more about ISO 14001:2015 or Environmental Management Systems?

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