ISO 14001 Revision Nears Completion
by Marilyn R. Block
International Organization for Standardization, known as ISO, Technical Committee 207 has released the draft international standard (DIS) for the revised version of ISO 14001.
It is anticipated comments will be reviewed in March and a final draft international standard (FDIS) circulated soon after. FDIS ballots are projected for return in July, and publication of the revised standard is anticipated by the end of 2004.
The DIS introduction explains the revision is intended to help users implement an environmental management system (EMS) without resulting in additional or diminished requirements in comparison to ISO 14001:1996.
Once the second edition is published, ISO 14001 registered organizations most likely will have one to two years to modify existing EMSs to conform to the revised standard. This task should not be onerous for most organizations because substantive changes are few.
Definitions (Section 3)
Four terms have been added to the list of definitions:
- Auditor--person with the competence to conduct an audit.
- Document--information and its supporting media.
- Procedure--specified way to carry out an activity or a process.
- Record--document stating results achieved or providing evidence of activities performed.
Note that in this section and section 4, the insertion of a new number causes all subsequent numbers to advance. Thus, "auditor" becomes definition 3.1 and "continual improvement," which was definition 3.1 in the original standard, advances to 3.2 in the DIS.
Changes to the definitions contained in the original standard are intended to clarify rather than modify. The definition of "continual improvement" serves as an example (see Figure 1). The word "recurring" was added to emphasize that continual improvement is an ongoing process. The words "in line with" have been replaced by "consistent with." Neither of these revisions changes the definition in a substantive way; rather, they shed light on what was originally intended.
Clause 4.1 on EMS requirements has been expanded. In the original standard, this clause states an organization shall establish and maintain an EMS that conforms to the requirements presented in clause 4. The DIS adds language to explicitly state what was previously implied--an organization shall establish, document, implement, maintain and continually improve an EMS.
This clause also adds language that requires an organization to define the scope of its EMS. Although this has the appearance of a new requirement, organizations have had to define system scope for internal understanding and implementation and as part of the application process associated with a registration audit.
Three changes have been made to clause 4.2 on environmental policy. The opening sentence of this clause links the policy to the defined scope of the EMS.
Paragraph c has replaced "relevant environmental legislation and regulations" with "applicable environmental legal requirements."
Paragraph e has been broken into two paragraphs. New paragraph e contains the language that requires the policy to be documented, implemented and maintained. New paragraph f addresses communication of the policy.
The original standard requires the policy to be communicated to all employees. The DIS requires it be communicated to all persons working for or on behalf of the organization. This change recognizes there may be people who are not employees (for example, subcontractors) whose work is covered by the scope of an EMS.
The planning section of the DIS has been reduced from four clauses to three. Clause 4.3.4 on environmental management programs has been eliminated, although the requirements remain. They now appear in the clauses on environmental aspects and objectives and targets.
Although clause 4.3.1 on environmental aspects has undergone a lot of wordsmithing, it remains substantially the same. In an effort to remove some ambiguity, organizations are now called on to identify environmental aspects they "can influence" in lieu of those aspects over which they can "be expected to have an influence." Presumably it will be easier for organizations to identify what can be influenced than to identify expectations.
This clause goes on to say identification of aspects must take into account planned or new developments or new or modified activities, products and services. This language is taken from clause 4.3.4 in the original standard.
The DIS explicitly requires organizations to document information about environmental aspects. While some might argue this is a new requirement (the original standard does not specify documentation), the reality is virtually all organizations have made it a practice to document their aspects identification efforts.
Finally, the clause requires organizations to consider their environmental aspects in developing, implementing and maintaining an EMS. Although the concept is newly introduced in this clause, it does not impose a new requirement. ISO 14001 refers to significant environmental aspects in conjunction with seven requirements. An EMS cannot conform to ISO 14001 without consideration of environmental aspects in its development, implementation and maintenance.
Clause 4.3.2 on legal and other requirements reflects this same language. Organizations must ensure applicable environmental legal requirements and other environmental requirements to which they subscribe are considered in developing, implementing and maintaining an EMS.
Clause 4.3.3 on objectives and targets has been expanded to include language that appears in clause 4.3.4 of the original standard. The requirement moved into this clause addresses the program for achieving objectives and targets, including designation of responsibility, means and timeframe.
Implementation and Operation
The seven clauses contained in this section are largely untouched. A few revisions are noteworthy.
Clause 4.4.2, originally titled "training, awareness and competence" has been renamed "competence, training and awareness." This is accompanied by a reordering of paragraphs, so the last paragraph in ISO 14001:1996 is now the first in ISO/DIS 14001. This suggests organizations should focus more on ensuring competence.
The second change to this clause is the shift in language from "personnel" and "employees or members" to "persons working for [the organization] or on its behalf." This is intended to include subcontractors in addition to employees when efforts are made to evaluate competence, identify training needs and provide training.
The final paragraph of clause 4.4.3, covering communication, is vastly improved. As revised, it states an organization shall "decide whether to communicate externally" about its significant environmental aspects. This is far less confusing than the original requirement to consider processes for external communication. The paragraph goes on to require that if the decision is to communicate, the organization must establish methods.
Clause 4.4.4, which addresses system documentation, has been expanded. The DIS contains a list of EMS documentation that must be in place:
- Environmental policy, objectives and targets. This is not a new requirement, as the policy and objectives and targets clauses in both the original standard and DIS specify these items must be documented. The information has merely been repeated in this paragraph.
- Description of the main elements of the EMS and their interaction and reference to related documents. This corresponds to the original language requiring a description of the core elements of the EMS.
- Documents and records required by this international standard. This requirement corresponds to the requirements in various clauses that an item be documented (for example, results of the management review).
- Documents and records determined by the organization to be necessary. This requires an organization to identify the documentation it needs to manage its EMS, above and beyond the documentation specifically noted in the standard.
Clause 4.4.5 on document control has been revised to address the last requirement contained in clause 4.4.4. The original standard calls for control of all documents required by ISO 14001. The DIS imposes control of documents required by the EMS in addition to those required by the standard. Thus, documents an organization determines necessary must be controlled, even though they are not explicitly required by the standard.
The other change to document control is the addition of a paragraph concerning documents of external origin. Those that are deemed necessary are to be identified and their distribution controlled.
Checking and Corrective Action
The language contained in clause 4.5.1 on monitoring and measurement remains largely unchanged, but the third paragraph on evaluation of regulatory compliance has been moved into a separate clause.
The DIS has a new clause 4.5.2, on evaluation of legal compliance. The language mirrors the original standard but links this requirement back to the environmental policy by stating the purpose of evaluating regulatory compliance is to meet an organization's commitment to compliance.
Perhaps the most onerous change is found in clause 4.5.3 on nonconformity and preventive and corrective action. As revised, this clause requires organizations to determine and take actions to prevent the causes of potential nonconformities.
It is unclear what is intended by the word "potential." One could argue the entire EMS is structured to prevent nonconformities. The point of ensuring employee competence and providing training where needed, for example, or creating work instructions for tasks associated with significant environmental aspects is to make certain jobs are performed consistently and appropriately. This could be construed as preventing potential nonconformities.
Should this language be retained in the final standard, it remains to be seen how registrars will evaluate this requirement during an audit.
The clause on records (4.5.4) has been revised to require records to demonstrate conformity to requirements imposed by the standard and evidence the EMS is operating as intended.
Finally, the clause on EMS audits (4.5.5) has been retitled "internal environmental management system audit." An added sentence requires objectivity and impartiality in the audit process.
The standard's final clause has been expanded to include inputs to the review (for example, EMS audit results, changing circumstances, follow-up actions from previous reviews) and outputs resulting from the review (decisions and actions consistent with the commitment to continual improvement).
This is an effort to emphasize the strategic nature of the management review, which is intended to assess the continuing suitability, adequacy and effectiveness of an EMS.
Implications for Organizations
It seems the majority of organizations with EMSs that conform to ISO 14001:1996 will not have to make significant modifications when the final revision is published. Required changes will be minor and likely to involve renumbering of clauses in various EMS documents and the expansion of existing activities, such as training, to include subcontractors.
It would appear the framework initially established by ISO/TC 207 will remain intact for at least another five years.
MARILYN R. BLOCK is president of MRB Associates, an environmental management system consulting firm in Potomac, MD. She earned a doctorate in human development from the University of Maryland, College Park. Block co-authored the ASQ Quality Press book Integrating ISO 14000 Into a Quality Management System and authored Implementing ISO 14000 and Identifying Environmental Aspects and Impacts. She is a member of ASQ.