It’s been over a year since the new ISO 14001 standard was launched and what’s become clear, is that there is no set way to meet the requirements. The subjectivity means that external auditors must go in to each audit with an open mind, due to the increased variation from one system to another. This is no bad thing, however, it can make it slightly daunting to know where to start, particularly when there are so many different ways of doing things. We at Green Element, over the last year or two have been pulling our resources together, attending webinars, training and discussing the new standard with other environmental professionals. Throughout this time, we have put together a detailed, well thought out action plan that includes not just our own take on the clauses, but all the different perspectives we’ve encountered along the way. Without going into too much detail, we want to provide a more practical guide against the clauses with examples of the kind of changes and additions you can make to safely transition over.
4.0 - Context
This clause is often overlooked but is actually fundamental in the new standard. Firstly, clearly define your boundaries and this doesn’t just mean a few sentences describing the generic scope of the environmental management system (EMS). For instance, if your company is a tenant in a large complex, at what point will you fail to have influence or control? Is the waste area shared? Do you have control over common parts? If you have multiple sites, does the EMS scope cover these sites as well? If the scope only includes the head office, this needs to be clear and must be reflected in the environmental policy. For defining physical boundaries, documents like the site plan and site drainage plan will be very useful. You then need to think about the internal and external issues and the needs and expectations of interested parties. Feel free to make reference to your impact and aspects register but before you go any further, see if your company has completed a PESTLE (Political, Economic, Social, Technological, Legal, Environmental) Analysis, or something similar as part of its business strategy. This will save you some time and also help with integration of the EMS. For external issues, remember to think about how the environment can affect your business, for example, climate change, flooding resource scarcity etc. Don’t worry about what risks these pose at this stage; this will come later. For interested parties think about the requirements and expectations of your staff, customers, suppliers, even your local authority and water company. Again, don’t be afraid to refer to other documents such as your legal register, where appropriate. You should end up with a comprehensive section that provides you with a reference point throughout the rest of the EMS.
5.0 - Leadership
Probably the most important clause of the new standard yet one that often proves to be the most challenging. I think one of the reasons for this from an implementation point of view, is that it is hard to demonstrate. After you’ve updated the Environmental Policy against the new ‘5.2’ clause, there is no require to document. So, what next? Well as an external auditor as well as a consultant, I would not hesitate to raise a non-conformity against clause ‘5.1 Leadership and commitment’ if I felt that this was the root cause of failures in other parts of the standard. Therefore, it is imperative that serious discussions are had with senior management and what is expected of them. The key point here is that they are not expected to do more day to day, but they are expected to know more. This is where integration of the EMS into the strategic plan comes in. For instance, target and objectives could be considered as part of the overall business strategy alongside financial and company policies.
Communication of the importance of the EMS I would also say is critical. There are a multitude of ways for it to be achieved but if resources are stretched, even a simple company email could demonstrate this. Though normally something a little more imaginative will have a greater effect. For larger companies, relevant staff need to be aware of the importance of the EMS. For instance, communication from senior management to ‘middle management’ is vital to allow for time delegation for certain staff members. It would also be expected that projects and proposals to improve environmentally should be seriously considered by management with financial and time resources being allocated. Finally, ensure you set aside time during the external audit for a discussion to take place between senior management and the auditor. Questions may go into targets and objectives and even why management identified a certain ‘risk’ as high or low. The most important thing to remember with this clause is integration. Systems that are too isolated from the business will struggle to comply.
6.0 - Planning
A great clause in my opinion and one that is made easy to comply with, providing you put the work in when establishing the ‘context’. The introduction of ‘risks and opportunities’ makes the EMS a lot more business friendly and will help with the integration mentioned previously. A simple way to determine your risks and opportunities is adapt your impacts and aspects register. For example, you could include reputational and financial risks against an aspect such as spillages. You could also think about positive aspects to help identify opportunities, such as building improvements. Keep in mind that you are simply trying to assign the level of business risk and opportunity to all the issues you identified in ‘4.0’, and to your current aspects. Don’t forget to consider compliance obligations and keep it relevant to the scope of your business. When reviewing your compliance obligations, you now need to view your ‘legal’ register more as a ‘compliance’ register. Therefore, any industry memberships, volunteering, tender requirements etc. that are related in some way to the environment must be included. Think about the interested parties mentioned in ‘4.2’. As for environmental objectives and targets, try to keep these linked to your risks, opportunities as well as significant impacts. For some risks, you may just put in place procedures and controls to minimise them, again as you would for your significant impacts. Just remember to feed the targets and objectives into the business process.
7.0 - Support
This clause relates back to leadership with the focus being on communication. Under ‘7.3 Awareness’ there is more than just the environmental policy that staff need to be aware of. Now employees must be aware of what impact their role has on the environment, their contribution to the effectiveness of the EMS and the implications of not conforming. As mentioned previously, communication channels vary from business to business so find what works best for your company and remember you need to be able to evidence this. I would go as far to say even small communications such as emails reminding someone to switch off the lights should be recorded. Obviously, this wouldn’t be significant for some industries but for your average office, it will make a difference. There is also more focus on external communication and there is no longer a decision to communicate on the significant impacts. Have a think about what you want to communicate, what you already communicate and record this in one way or another.
8.0 - Operation
The main new addition to this clause is the introduction of a life cycle perspective. The level of work required obviously varies from one industry to another but for your average office, you should start but looking at current procurement policies. Look at the contracts in place for stationary, paper, IT equipment, cleaning products, coffee etc. and understand why these suppliers were chosen. Did they have to complete supplier questionnaires and submit tender requirements? You should aim to integrate environmental issues into this process such as distances travelled, materials used, environmental credentials etc. These can then be used for new contracts and reviewing current ones. Also, think about external communication of your companies own values i.e. your environmental policy. As well as looking at where your products and services come from, you also need to assess their end of life treatment and final disposal. This means reviewing all your waste streams and applying the ‘waste hierarchy’ wherever possible.
9.0 - Performance Evaluation
Like ‘4.5 Checking’ in ISO 14001:2004, this clause is where the bulk of the ongoing work sits and it also now includes the management review. There aren’t any radical changes but there is certainly more emphasis on evaluation of compliance. A more detailed review of compliance obligations will be expected and maintaining real time knowledge and understanding of your compliance status. Therefore, I would try to review the compliance register more often and increase the number of audits where necessary. Compliance obligations should definitely feature in your communication strategy and you should also consider trends in compliance audits and ensure these are included in the management review. As for monitoring, it may now be apparent from assessing the life cycle of products and services, that monitoring them would be of benefit. This will obviously be where you have influence and opportunity to improve environmentally e.g. reduce quantity. Since monitoring figures are more likely to be communicated internally and externally, is it paramount the data is robust and reliable. Therefore, more extensive and objective audits should be carried out regularly. The changes to the management review are self-explanatory in the new standard but it’s important the outputs are formally recorded. Any actions and aims could then be fed back into the targets and objectives where necessary. Also, try to make sure management are involved with each topic and they agree with what has been presented. For example, risk and opportunities as mentioned earlier may be discussed in external audits, so they need to be aware of what has been identified. It may also be a good idea to hold the management review close to the audit date, so they are up to speed with the EMS.
10.0 - Improvement
This clause is now where ‘Nonconformity and corrective action’ rightfully sits. Again, no major changes but there may be a need to ensure the corrective action procedure is effective in eliminating the cause of the nonconformity, in order that it does not recur or occur elsewhere, by determining if similar nonconformities exist, or could potentially occur. As for ‘10.3 Continual improvement’, hopefully this is demonstrated throughout the EMS but it also features in the management review as ‘opportunities for continual improvement’. It’s vital to make the most of this section as there will often be a number of actions/projects that can greatly improve the company and EMS, but just need management support. For me, having a clause that is dedicated to the continual improvement of the EMS will shine a light on those that are just coasting, something that is all too common.
I should mention that what we’ve outlined above is just a rough guide and by no means the only way to achieve a successful transition to ISO 14001:2015. It should, however, provide you with ideas and a good starting point to making the leap. It will become clear when transitioning that the clauses are interlinked even more than before. In my opinion, they complement one another brilliantly and if you put in the effort, it’s a fantastically useful tool to not just help improve environmentally, but to improve your business as a whole.
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