What are the key changes in ISO 14001:2015?
Organizations currently certified to ISO14001: 2004 will need to address the new (or expanded) requirements of ISO14001: 2015 with the following general groupings:
- Understanding the context of the organization and expectations of interested parties
- The integration of the environmental management system (EMS) requirements into the organization’s business processes
- Actions to address risks and opportunities
- Expanded top management commitment
- Expanded definition of Operational Controls
Context and Interested Parties: Past revisions of ISO14001 required organizations to define the “scope”- the activities, processes and buildings and property within their environmental management system. The organization’s environmental policy included commitments to comply with applicable environmental regulations, reduce pollution and continually improve its environmental performance. While many ISO14001 certified organizations included initiatives such as replacement of toxic materials, recycle activities and reduction of fossil fuel use, the majority of the environmental programs fostered by certified organizations were “reactive” in nature. The new clauses of ISO14001: 2015, Understanding the organization and its context and Understanding the needs and expectations of interested parties challenges organizations to analyze its operations and environmental impact from a more holistic, proactive vantage point.
With regard to the Context the organization, depending on the organization business model and environmental impact, there may be opportunities to have programs with a positive, proactive impact: air emissions related to climate change; improvement in soil quality of adjacent land or neighboring waterways; supporting biodiversity (local flora-fauna) initiatives. The organization should be able to explain, within the context of their operations what opportunities exist. A company producing machined parts or electronic components may have limited options; a large chemical plant, oil refinery or paper mill may have many opportunities.
In a similar fashion, in response to expectations of interested parties, the organization should analyze how their activities and products may have environmental impact on their customers, community and neighbors. Examples could be end-of-life product disposal; voluntary labelling on products; reduction of unregulated materials; sustainable resources; commitments to maintain adjacent community land or water ways. A key focus of ISO14001: 2015 is “Life-cycle thinking”, considering each stage of a product or service, from development to end-of-life product life. Organizations producing consumer products may have many opportunities (but also challenges) to have an impact on product disposal, while manufacturers of components for sale to industry, may be limited in this regard. Organizations providing components for sale to industry can demonstrate their commitment to life –cycle thinking by reducing/ eliminating the use of environmentally challenged materials and maximizing recycle initiatives. Consumer products manufacturers can support life –cycle thinking by moving to “zero- landfill” disposal via waste to energy disposal options. The ISO 14001:2015 Implementation Handbook discusses these requirements in more detail.
The integration of the EMS requirements into the organization’s business processes: Many companies currently ISO14001 certified have integrated the EMS into their business planning and strategy. I have audited companies of all sizes where the environmental performance metrics are woven into the business plan; the KPIs (key performance indicators) assigned to quality and business parameters also include the environmental metrics of hazardous waste reduction, material recycle and utility use. Quality driven waste reduction projects include improved environmental performance. “Best-in- class” organizations have established a Business Management System (BMS) incorporating their financial, quality, safety and environmental systems into a cohesive operational model. I have also experienced ISO14001 certified companies who operate with their EMS at arm’s length from their business- just doing the minimum in environmental management to maintain certification. The ISO14001: 2015 standard requirements should nudge these companies into broadening their perspective on environmental performance. The ISO 14001:2015 Implementation Handbook discusses ways to illustrate the integration of the EMS with the organization’s business.
Actions to address risks and opportunities: From my perspective, the requirement to provide risk analysis in the environmental management system activities is the key difference in ISO14001: 2015 compared to previous revisions. An identified method to analyze risk associated with threats and opportunities related to the organization’s significant environmental aspects, compliance obligations or other issues is now required. Results of the analysis should be used in establishing objectives and planning to mitigate the risks. Utilization of FMEA (failure mode effect analysis) as a quality tool could be applied. While organizations with an effective Environmental Management System certainly understand risks related to non-compliance, the new requirements of ISO14001: 2015 may have a positive effect on many organizations by requiring a more formalized process and subjecting the risk evaluation process to a 3rd party audit. The ISO 14001:2015 Implementation Handbook discusses this requirement in more detail with examples of application to environmental controls and legal obligations. It should be noted that ISO14001: 2015 does not have a requirement for “preventive action”. The thought is the entire environmental management system is preventive in nature and the risk analysis approach is also preventive.
Top Management commitment: While the previous revisions to ISO14001 included commitment from management to support the EMS, ISO14001: 2015 amplifies this commitment. The ISO14001: 2015 standard does not use the title “Management Representative” as previous ISO14001 standards did. The organization can continue to use Management Representative as the title having certain responsibilities. The intent of ISO14001: 2015 is to emphasize Top Management’s responsibilities as more than delegating. My past experience with a small group of organizations was that in fact, management had delegated the environmental management coordination too far down the organizational chart. This was evident by way of the environmental management representative not attending the Management Review meetings to present the status of the EMS. Not a good sign. Management would justify this process due to the need to discuss financial or sensitive issues at the meeting, and the environmental coordinator should not be privy to such information. ISO14001: 2015 requirements strive to prevent the over-delegation of the EMS support and coordination.
Expanded Definition of Operational Controls: The intent of ISO14001: 2015 clause 8 closely matches the previous revisions of ISO14001 related to operational controls; however, ISO14001:2015 provides more specific requirements related to outsourced activities (contractors and suppliers), change control, design and product life cycle considerations.
When processes are provided by contractors and/ or suppliers (outsourced), the environmental impacts need to be defined with appropriate controls established and implemented. Examples would include: cleaning services; removal of waste; landscaping; contracted maintenance or construction.
The Product design process should consider the impact of materials used to avoid environmentally challenged materials during use, delivery and disposal at end of life. The Design and Life Cycle requirements of ISO14001: 2015 would be mostly applicable to organizations manufacturing consumer products. Other organizations, such as discreet manufacturers, original equipment suppliers and contract electronics manufacturers are restricted by compliance obligations such as (RoHS -Restriction of Hazardous Substances Directive) and REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals).
The organization needs to ensure controls are in place when changes occur in processes, resources and equipment. This requirement was implied in ISO14001: 2004, clause 4.4.6 Operational Control (and clause 4.3.1, Environmental aspects); however ISO14001: 2015 now explicitly requires the organization to evaluate and adjust operational controls when new processes or equipment is added to the operation.
Two other changes (but not new requirements) are the modification of the clause outlines and documentation formatting. These changes were made in ISO14001: 2015 to provide alignment with the Quality Management System ISO9001: 2015 formatting.
How can organizations respond to ISO 14001:2015 requirements for risk analysis?
ISO 14001:2015 clause 6.1.1; “Actions to address risks and opportunities” requires the organization to establish a process to determine the risks and opportunities, related to its environmental aspects, compliance obligations and give assurance that the environmental management system can achieve its intended outcomes.
The process used to determine which environmental aspects are the most significant for the organization should include an assessment of aspects that present a threat to the organization’s environmental performance. A common technique used to determine an organization’s significant environmental aspects (SEAs) is to rank the aspects based on the frequency an aspect could occur and the severity of the potential impact. A manufacturing plant may have a ranking system as described below.
| Frequency | Pts. | Severity | Pts. | ||
| Continuous | Daily or multiple times during a week | 5 | Catastrophic | Does Aspect have the ability to affect the community or public perception of the company? | 5 |
| Repeated | Occurs at least once per month | 4 | Regulated | Is this Aspect covered in a permit or regulated by law? | 4 |
| Regular | Occurs at least once per quarter | 3 | Serious | Some negative but reversible impact on the environment | 3 |
| Intermittent | Occurs about once per year | 2 | Moderate | Minimal impact on environment; spill or release contained on site | 2 |
| Seldom | Occurs accidentally or rarely | 1 | Harmless | Impact not significant, spill or release contained in immediate vicinity | 1 |
Multiplying the frequency times the severity would allow the organization to rate the risks presented by each aspect. Once the aspects are ranked, the organization can review and analyze the priority for applying operating controls to mitigate the risks. Note: some organizations include the existing controls in the calculation for significance; so if an aspect has best technology controls in place, the aspect ranking score would be lowered. I don’t think the efficacy of the current controls should be used in the calculation since some of the greatest environmental disasters occur when controls fail. Once the list of aspects with the greatest threats is generated, the organization can provide a risk analysis presented by existing controls for these aspects. As an example, a company with a solvent based painting booth could conduct the following analysis.
| Aspects Risk Assessment | ||||
| Aspect | Potential Failure | Env. Impact | Present Controls | New Controls? |
| Operating Solvent Paint Booth | Use unapproved Paint | Exceed VOC limits | Purchase order approval | QA certifies paint released to department. |
| Operating Solvent Paint Booth | Air Filter Not working | Discharge paint solids: Neighbor complaint | Air pressures gage; measures filter quality | Add second gage and alarm. |
| Operating Solvent Paint Booth | Fire and explosion in ducts | Major discharge of solvent fumes | P.M. of static connections | Install in-duct gas monitor |
| Operating Solvent Paint Booth | Spill of paint drum contents | Discharge to exterior of plant | Trained employees | Purchase drum spill containment pallets |
A similar analysis could be conducted by this organization based on risks presented by potential failures in compliance with its legal obligations related to the paint booth.
| Regulated Aspect | Potential Failure | Actions to reduce risk |
| Air Discharges from paint/ mix booths | Report not issued to EPA | Create Compliance Calendar w/ email notifications |
When establishing aspects ranking process, a suggestion is to include in the procedure the ability for management to override the ranking results based on management judgment. An example would be an organization with a large waste water treatment plant used to remove toxic materials from its waste stream. The severity, as a highly regulated process, would result in maximum score for environmental severity; however, if the waste treatment process is used a few times a year the frequency score might yield a low total score. Management would most likely want the waste treatment process to be considered very significant due to the potential risk of a catastrophic discharge of toxic chemicals.
An extreme example of where risk analysis and mitigation was not practiced effectively was the BP oil rig explosion that occurred in the Gulf of Mexico in April 2010. There was much discussion concerning the role of the blowout preventer in mitigating the extent of the spill. Had the “risk” related to operation of the blowout preventer been reviewed as thoroughly as needed- were the maintenance records up to date? Unfortunately, there are two phases to risk analysis: the assessment of the risk and planning to control or mitigate the threat. Sadly, when environmental disasters occur, while the risk assessment may have been done, the follow-up control actions were often not properly implemented.
Bio:
Milt Dentch is a ISO management systems consultant. He has published two books through ASQ. I have been an Exemplar Global (RABQSA) EMS qualified lead auditor for over 15 years, and have conducted over one hundred ISO 14001 3rd party audits for international Registrars Bureau Veritas and TÜV SÜD America. During my 40 years working at the Polaroid Corporation and the Furon Custom Coating plant, I had responsibility for several environmental controls, including waste water treatment; hazardous waste management; toxic chemical reduction and volatile organic chemical thermal incinerators. I have prepared the training modules and provided training for EMS Internal Auditors.
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