With ISO 14001 having changed to 2015 version, what will auditors be looking for? What questions will they be asking?
Generally, when something changes, that will be what the auditor is going to focus on; the vindictive auditor will try to catch you out, to show they know more than you, and make themselves look good. The professional environmental auditor will focus on the continual improvement approach and appreciate that management systems change and improve over time. Either way, to avoid non-conformities, you still need to be prepared. We’ve put together five key questions we think auditors will be asking, and we’ve also suggested how your environmental management system could address it. …and for you technical “system types” we’ve added some useful tips to make sure you are fully up to speed.
- Environmental management system – clause 4.4
How have you enhanced your organizations environmental performance…and continually improved your EMS?
Your organizations environmental performance should be getting better over time. This does not mean that you should have more procedures and a bigger more complex system. What it means is that the impact you are having on the environment should be getting less. This could be by reducing your negative footprint – using less water, reduced power consumption, or it could be by doing positive initiatives – removing noxious weeds, assisting with community projects. In big organizations it most probably means both. This is more than just complying with your legal obligations, which you have to do whether you have ISO 14001 or not, this is about improved performance and can you prove it. Useful tip: ISO 14001:2015 requires the organizations environmental objectives to be documented (clause 6.2.1) and it also requires as part of management review (clause 9.3) actions to be documented when objectives have not been achieved.
- Leadership and commitment – clause 5.1 (c)
Have you integrated the environmental management system into the organization’s business processes?
It is not acceptable (it actually never was) to have a separate EMS – An EMS that is not part of your normal business. It is clearer now that the environmental requirements have to be part of your core business processes. Whilst you may have specific environmental people or even an environmental team, their role should be as technical experts, supporters and communicators of the EMS and not as the do-ers of all things environmental. So embedded within your business’s operational processes should also be what has to happen environmentally; any specifications, acceptance criteria, sampling, waste disposal, flora or fauna protection, etc. These should not be separate from but part of. Useful tip: Many organizations currently have their environmental controls, their environmental processes, procedures, specification etc. in an Environmental Management Plan EMP, and whilst this will continue to be acceptable to most auditors – it is debatable that this actually conforms to ISO 14001:2015.
- Actions to address risks and opportunities – clause 6.1
How have you considered the Environmental opportunities to the organization?
Environmental aspects and the associated impacts tend to be seen as only being negative, the damage or potential damage that your organization is doing or could do to the environment. With the adoption of a risk-based approach to the environment, ISO 14001:2015 has now included the term opportunities… And an opportunity is where an organisation can improve the environment. It is not about reducing its negative impact, such as using less water, or using less power – they are just reducing the negative impacts. It is more positive than this and could include such things as removing noxious weeds that already existed, managing feral animals, funding local schools. Opportunities will also cover major changes to how the business operates environmentally, for example if it changes its entire fleet of vehicles from petrol over to electric. Even though this is arguably only reducing an impact that the business itself creates the change is so large it is best viewed as an opportunity. Useful tip: In the previous version this was covered in the definitions where it stated that environmental impacts could be adverse or beneficial, it is now more clearly stated, and included in the body of ISO 14001:2015.
- Environmental aspects – clause 6.1.2
When determining your aspects and their associated impacts how have you considered a life cycle perspective?
Once an organization has identified its environmental aspects, it needs to then identify their associated impacts…and this was in the previous version of ISO 14001. There is also now a requirement that organizations consider a life cycle perspective. Typical stages of a life cycle assessment are raw material, design, production, transport, use, delivery, and disposal. So have you taken these stages and the impacts of each of them into account when making decisions about which product/service/activity to use? For example, when you are considering which new piece of equipment to purchase – have you considered where the raw material came from, how far it had to be transported, and what you will do with it when it comes to its end of life? Useful tip: In the guidance at the back of ISO 14001:2015 it states that this does not require a detailed life cycle assessment. It further explains that it is sufficient for an organization to think carefully about the life cycle stages that it can control or influence.
- Environmental aspects – clause 6.1.2
What criteria have you used to determine your significant environmental aspects?
Once an organization has identified its environmental aspects, it needs to then identify the impacts associated with those aspects, and this was in the previous version of ISO 14001. Also, in the previous version was the need to then choose the significant aspects. In ISO 14001:2015 the criteria that it used to determine which aspects are significant now has to be documented…and the method and the criteria used should provide consistent results. Useful tip: Many organizations will be addressing this by using a risk matrix, taking into account the likelihood of the impact and the consequence of the impact. Whilst this may be acceptable in some instances, in may not be appropriate in all circumstances and other methods may be more appropriate which better take into account such things as type, size, frequency, scale, severity, duration, exposure, legal requirements or the concerns of interested parties.