John Marsden (FIEMA) , Marsden International (UK) Limited (This article was printed in the IEMA Environmentalist Magazine)
1. Introduction
The current version or edition of ISO 14001 was published in November 2004 and this short article describes the impact of the standard on the work of the EMS auditor and discusses the more important developments that should be considered whilst auditing an EMS. Although it is soon to be reviewed and revised, it is worth looking at the key changes that were made to the original 1996 standard.
It must be said that changes to ISO 14001 are not in any way as far-reaching as those introduced to ISO 9001 : 2000 and this revision should be viewed primarily as a clarification document rather than one of major change. It also provides an opportunity to enhance the compatibility between the two management system standards by means of definitions and word changes to identical clauses.
From the perspective of the EMS auditor, little has changed. The approach taken and the execution of an EMS audit is still the same but there is a greater emphasis on auditing the key significant environmental aspects that are to be found within the defined scope of the EMS. Most EMS auditors involved in certification are already fully conversant with the focus on significant environmental aspects but internal EMS auditors may miss this vital requirement.
Clause |
Change |
Comment |
3. Definitions |
Several terms have introduced that are already included within ISO 9000:2000 (Fundamentals and vocabulary) |
Terms related to auditing and management systems such as audit, procedure, record and others are defined |
4.1 General Requirements |
The scope of the EMS and the term ‘continually improve’ has been included here |
Emphasis on both these points ensures that the boundary of the EMS is clearly stated. |
4.2 Environmental Policy |
Again, the term ‘defined scope’ is added |
The policy applies to the defined scope of the EMS. Nothing new here but this emphasis is useful |
4.3.1 Environmental Aspects |
Introduces explicit requirements |
Extends the meaning of ‘control’ to include new developments. |
4.3.2 Legal and other requirements |
The procedure shall identify and assess the applicability of the requirements to the significant aspects of the organisation |
More specific requirement to determine how legal requirements apply to the business |
4.3.3 Objectives, targets and programmes |
Combines objectives with programmes and includes modified wording relating to how objectives are selected |
Combining programmes (4.3.4) with 4.3.3 of ISO 14001 :2004 provides better association between these closely related functions of the EMS |
The new standard requires organisations and to address the following points listed below ;-
The EMS auditor should be confident that activities which do, or may, generate significant environmental impacts are correctly identified. All activities, products and services of the organisation within the defined scope should be included within the EMS and the auditor should carefully check that this has been carried out. This requirement now prevents organisations from excluding any environmentally dubious activities from the scope of the EMS..
There is a need for organisations to demonstrate what activities they are performing to meet the requirement for ‘continual improvement’ within the defined scope of the EMS mentioned above
The auditor should be aware that the new standard includes the words ‘recurring process’ within the definition of ‘continual improvement’. It is necessary for organisations to demonstrate measurable improvements in their environmental performance and this should be investigated by the auditor to check that the EMS is not ‘standing still’ with regard to environmental performance improvement.
Organisations should ensure that the environmental aspects of new and planned activities are identified and evaluated. The strengthening of this clause is important to ensure that expected environmental impacts arising from new activities are evaluated early in the development phase of a new operation or process. The EIA (Environmental Impact Assessment) process for planned new construction projects is an example of how effective this approach can be.
The auditor should methodically test the effectiveness of the aspect identification and evaluation process for new or planned developments. For example, where a new production process is planned, there should be documented information that clearly identifies the environmental aspects that it can control together with an evaluation of the significance.
Also the auditor should recognise the importance of basing the audit sample in any given area on the significant environmental aspects that have, or should have, been identified and evaluated. Whilst this is true for both old and new standard, the emphasis is more clearly stated in the 2004 version.
Combining clauses relating to objectives and targets with programmes requires no change in emphasis to auditing an EMS. The value of this change is to accentuate the linkage between these three important components of an EMS.
As always, when auditing this clause of the standard, the auditor should be able to scan through all current objectives to verify linkage with significant aspects, their wording and to identify a representative sample of programmes for more detailed analysis and audit.
Clause |
Change |
Comment |
4.4.1 Resources, roles, responsibility and authority |
Includes the word ‘resources’ in the title of this clause and extends the meaning of structure to encompass ‘authority’ |
The inclusion of the word resources helps to emphasise the importance of this input to the effective functioning of the EMS |
4.4.2 Competence, training and awareness |
Includes the need for personnel working on behalf of the organisation to be aware and competent with respect to the EMS requirements |
Emphasises the need to ensure that others (eg. contractors, temporary staff ) are competent |
4.4.5 Control of Documents |
Includes the words related to the control of records and inclusion of certain external documents |
Records are controlled slightly differently to other documents and some external documents specified by the organisation can become part of the EMS. |
4.5.2 Evaluation of Compliance |
New clause created by the separation of the evaluation of compliance with legal requirements from 4.5.1 monitoring and measurement |
More emphasis to ensure that an appropriately detailed evaluation (internal audit or inspection) is carried out. |
4.5.3 Nonconformance, Corrective action and preventative action |
Actions associated with nonconformities are specified from a) to e) more clearly than before. |
More detail added to this clause to provide greater clarity as to how nonconformities and associated issues are dealt with |
4.5.5 Internal Audit |
Includes reference to selection of auditors and conduct of the audit to ensure objectivity |
Improvement of objectivity and impartiality of audits required. |
4.6 Management Review |
More detailed list of input requirements are included within management review. Harmonised with ISO 9001:2000 |
Specific requirements enable the auditor to assess more accurately the effectiveness of the management review |
The clause relating to competence, training and awareness is now improved because the new standard focuses on competency as the key parameter. Rather than stating that ‘all personnel whose work may create a significant impact on the environment have received appropriate training’, the new standard requires persons to be ‘competent’ on the basis of appropriate education, training or experience.
The improvement in the wording enables the auditor to focus much more on the issue of competency, enabling more effective EMS audits to be conducted. Rather than checklist questions based around ‘have you been trained’ the auditor should focus on ‘what is your level of competency with respect to the environmental aspects of activities that you carry out’.
The explicit requirement for persons who are performing tasks for the organisation or on its behalf that have the potential to cause significant environmental aspects strengthens the requirement that contractors and temporary staff must also be able to demonstrate their competence. These days, many functions are performed by outside staff for whom the competency issue is often diluted by the ‘arms length’ control of the contracted body by the organisation’s management.
EMS auditors have always been able to use ISO 14001:1996 (4.4.2) to assess the degree of competence that personnel have in performing tasks that can cause significant environmental impacts, but now the meaning in the standard is clearer and more useful. The need for organisations to document monitoring procedures has been removed, thereby reducing the number of actual documented procedures required by ISO 14001:2004
The auditor should not (without qualification) ask to see the documented procedures relating to monitoring but should investigate and audit the overall process of how information relating to monitoring environmental performance is gathered, documented and used by the organisation.
The creation of a new clause called Evaluation of Compliance (4.5.2) does not quite create the expected level of excitement (if that is the right word) from the auditor community simply because this requirement was already present within the 1996 standard. However, by providing this activity with it’s own clause, there will be a much greater emphasis on the evaluation of compliance of legal requirements. The design of this clause also requires an organisation to evaluate compliance with ‘other requirements’.
The EMS auditor should expect to see the results of this important activity carried out for all applicable legal requirements and the same for ‘other requirements’ either as a combined or separate record. This will require the EMS auditor to have a comprehensive understanding of the legal and other requirements of the organisation being audited. This activity should be carried out periodically and the auditor should be able to determine whether or not the selected period is appropriate. If a concern arises in this area, the auditor should (as always) identify clear objective evidence to support any finding.
The changes to the wording of clause 4.5.3, ‘Nonconformity, corrective action and preventative action’ simply clarifies the overall meaning of the 1996 standard and should not cause any problems to the experienced auditor. A similar situation exists for the remaining clauses of the standard.
John Marsden, FIEMA Marsden International (UK) Ltd Tel: 01302 752123
