The ISO 14001 Environmental Management Systems standard has been adopted by more than 250,000 organizations globally since it was originally issued in 1996 and then revised in 2004. General perception amongst adopters has been that it is a well written standard with enough flexibility to apply to any organization. In fact, ISO reviewed the standard in 2010 and determined that no change was required.

That was before ISO issued Guide 83 “High level structure and identical text for management system standards and common core management system terms and definitions.” Guide 83 is intended to provide a single high-level structure and common text that will apply to all ISO management system standards (MSS). ISO developed Guide 83 in response to complaints from organizations that have implemented multiple standards only to find that each has a different structure and slightly different requirements. And, when integrating management systems, it is a challenge to understand how the different standards fit together with minimum redundancy.

Guide 83 is certainly an interesting concept — a common format, structure and core requirements for ISO 14001, ISO 9001, ISO 27001 and ISO 50001 — this should make it less confusing for an organization to implement a fully integrated management system. ISO has requested that standards be revised to conform to Guide 83; the ISO Technical Committee (TC) 207 has started the process to revise ISO 14001, with a target of issuing a Final Version in 2015.

The Revision Process

ISO standards are referred to as “consensus standards” because they are developed with the consensus of all participating countries. For example, the 2004 revision was issued with active input from more than 70 countries and approval vote from more than 130 countries. Each participating country forms a Technical Advisory Group (TAG) that reviews the standard, proposes wording and revisions, and provides a single vote of approval or disapproval regarding the standard. The United States is represented by the US TAG to TC 207 regarding ISO 14001. Working Group (WG) 5 is responsible for revising the standard.

Imagine the challenge to develop a single document that more than 130 countries agree is suitable to the situations organizations in their country face. When developing consensus standards there is extensive discussion amongst countries to agree on the specific final wording used in the standard. For those of us used to a bit of action, it can be a bit like watching paint dry.

WG 5 is currently developing initial drafts of the ISO 14001 standard to reflect the Higher Level Structure defined in Guide 83. The revised version of ISO 14001 is presently at the Working Draft stage; expect that there will be numerous changes between now and the Draft International Standard version that should be issued later this year. But, even though we can expect changes, it is not premature to start discussing the current Working Draft (WD) version of this document.

The Changes

The primary changes to the ISO 14001 standard are structural in nature. All ISO standards will now adopt a common format, with requirements included in seven sections; the ISO 14001 Plan-Do-Check-Act structure, with 17 elements in section four, will no longer apply. The fundamental question becomes: “Is the revision just a reorganization of the current requirements? Or are there new requirements contained in the proposed changes?” The answer is complicated because the text is subject to significant review and potential change (we are currently at Working Draft 3), but the current text does contain new requirements.

So, let’s talk about some of the new requirements in Working Draft 3 (we will refer to this version as 201X for the rest of this article).

Section 4

Section 4 “Context of the Organization” is similar to the 4.1 General Requirements where the organization needed to define the boundaries of the EMS. The proposed 201X version expands this requirement to require the organization to evaluate and understand the external and internal context of the organization related to the environmental interactions, and to evaluate and identify the needs and expectations of interested parties. The wording is such that an organization may need to expend some effort to conduct these evaluations.

Section 5

Section 5 “Leadership” places greater emphasis on top management’s responsibility than in ISO 14001:2004, and is similar in structure and content to Section 5 in ISO 9001:2008. This version adopts a philosophy that many of us endorse when implementing an EMS: incorporate the EMS requirements into business processes. Top management must ensure that

• objectives and targets are consistent with the strategic direction,
• EMS requirements are incorporated into business processes, and
• the importance of conformance to EMS requirements is internally communicated.

Section 5 also includes the requirements associated with the environmental policy, and there are changes associated with the environmental policy requirements. While the requirements are very similar to the current version of ISO 14001, the commitment associated with preventing pollution is expanded such that the organization shall “…mitigate its risks and manage opportunities associated with prevention of pollution, sustainable resource use, climate change mitigation and adaptation, and protection of the environment, biodiversity and restoration of natural habitat.” Is this a big change? It certainly is a more explicit listing of the items that need to be addressed in the EMS, and many registrar auditors may view this as a list of opportunities an organization needs to address.

Section 6

In Version 201X, Section 6 “Planning” is similar in scope to the Planning section of ISO 14001:2004. It includes requirements associated with identifying environmental aspects, legal requirements and objectives and targets. There are some new requirements associated with these elements:

Environmental Aspects – environmental aspects need to consider a life cycle perspective, and consider environmental conditions originating outside the organization.

Environmental Objectives – identify key performance indicators for each environmental objective against which performance can be evaluated.

Section 7

In Version 201X, Section 7 “Support” includes sections entitled Resources, Competence, Awareness, Communication and Documented Information. While the requirements are generally the same as found in ISO 14001:2004, there are some proposed additional requirements in Communication. First, the organization is required to develop a communication strategy. Second, there is a new section External Communication and Reporting that requires a procedure associated with external reporting. Some wording in the Working Draft 3 version is a bit concerning, as “data and information communicated externally shall be truthful and not misleading” and external communication regarding environmental performance shall be “complete, accurate, transparent and reliable…” The concern is not with the intent of the selected wording, but with the evidence that auditors may request to demonstrate conformance to the standard.

Section 8

In Version 201X, Section 8 “Operations” includes two sections similar to those in ISO 14001:2004: operational planning and control, and emergency preparedness and response. Section 8 adds two new sections to the requirements: design and procurement. These new sections expand the requirements associated with integrating EMS into the design and procurement processes.

Section 9

In Version 201X, Section 9 “Monitoring, Measurement, Analysis and Evaluation” includes requirements similar to ISO 14001:2004 contained in the following elements: monitoring and measurement, evaluation of compliance, internal audit and management review. There do not appear to be any significant new requirements included in these sections.

Section 10

In Version 201X, Section 10 “Continual Improvement” includes nonconformity and corrective action and a new section entitled “continual improvement.” This new section brings added support to demonstrating continual improvement in environmental performance.

There is considerable fear among US TAG members regarding the specific words used in the standard and the objective evidence required by a registrar auditor when performing a registration audit. The wording used in the Working Draft 3 version of the standard supports this fear. While the intent of the revisions can be supported by most environmental professionals, the specific wording may be interpreted differently by auditors seeking objective evidence to demonstrate conformance to the standard.

Next Steps

The standard is still some distance from being in final form, and there are numerous changes that can be expected. A public draft version is planned for later this year (2013), and the planned date to issue the final standard is early 2015. Once the final version is published, ISO will announce a transition schedule for those organizations registered to ISO 14001:2004. Past major revisions have allowed for up to 24 months for the transition to the new standard; plan some time and effort to transition your environmental management system to the revised standard.

One other action that any organization can take is to volunteer your time to support the US TAG to revise the ISO 14001 standard. The US TAG is always seeking the perspective of industry, consulting and public organizations, and your involvement can help shape the future ISO standard.

About the Author

Terry A. Mors, QEP, is a Senior Consultant in the Holland, Michigan office of Environmental Resources Management (ERM). He has more than 32 years of experience providing EHS support for clients in the automotive, chemical, electronics, metals, mining, and service industries. Mr. Mors is Qualified Environmental Professional, RABQSA Lead ISO14001 Auditor, RABQSA Lead Responsible Care Auditor, RABQSA Lead ISO9001 Auditor, and a member of the US Technical Advisory Group to TC 207. He conducts management system audits, works with senior management to improve company performance, and provides training, including implementation training, internal auditor training, problem solving training, and other organization-specific training. Mr. Mors’ management systems experience includes EHS and quality standards (e.g., ISO 14001, RCMS and RC14001, ISO 9001, ISO/TS 16949, and OHSAS 18001).

Photograph: Fern by Piotr Menducki, Ostrowiec Świętokrzyski, Świętokrzyski, Poland.

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