ISO 14000 Revisions Likely To Be Minor
Recommendations make additional documentation, regulatory compliance and external communication unlikely
by Marilyn R. Block
The ISO 14001 environmental management standard reaches its fifth anniversary this September. The International Organization for Standardization, known as ISO, requires a review of its standards every five years to determine whether they should be retained, revised or rescinded.
At the June 2000 annual meeting of ISO Technical Committee (TC) 207, delegates determined ISO 14001, Environmental management systems--Specification with guidance for use, should be revised. This effort was guided by three precepts:
- Revisions should clarify the intent of existing language.
- Language should be modified to improve compatibility with ISO 9001:2000.
- Revisions should not be substantive.
One year later, a drafting group has prepared its recommendations, which are scheduled for discussion as this column goes to press. Representatives from around the world will thrash out concerns until consensus is reached on the changes to be incorporated into a draft document for consideration by national standards bodies.
It is anticipated the draft document will be reviewed by the U.S. Technical Advisory Group to ISO TC 207 at its meeting this September.
Of the 29 changes proposed, 16 are classified solely as clarification and five as improving compatibility. Eight are classified as both. This article will discuss only the most significant changes.
Annex A unchanged
Interestingly, no changes have been offered for Annex A, the guidance for implementing an environmental management system (EMS). This is the case even though the original (current) version notes, "Text may be included in a future revision" in the sections on operational control, emergency preparedness, and monitoring and measurement.
So while many users of ISO 14001 were under the impression that these sections would be addressed in a revision effort, there have been no recommendations yet. But ISO 14004, the guideline on principles and techniques to support implementation of an EMS, is undergoing a comprehensive revision.
Six definitions in ISO 14001 have been recommended for modification to enhance user understanding. For example, definition 3.8, environmental performance, would be changed to "results of an organization's management of its environmental aspects."
Similarly, definition 3.9, environmental policy, would be modified as "overall intention and direction of an organization related to the environment as formally expressed by top management."
Finally, definition 3.13, prevention of pollution, would be rewritten as "use of processes, practices, materials, products or energy to avoid, minimize or control (separately or in combination) the creation or emission of pollutants and waste, in order to reduce overall adverse environmental impacts."
Discussion of general requirements (ISO 14001, clause 4.1) would be expanded. Unlike the current version, which states an EMS must be "established and maintained," the proposed revision requires an EMS must be "established, documented, implemented, maintained and continually improved." This section's proposed revision goes on to require that organizations define the scope of their EMSs.
In an effort to clarify clause 4.3.1, environmental aspects, the first paragraph would be broken into sections. The proposed first paragraph now requires procedures to:
- "Identify the environmental aspects of its activities, products or services (including potential or new developments, and new or modified activities) that it can control and over which it can be expected to have an influence."
- "Determine those aspects that have or can have significant impacts on the environment."
The addition of "potential" developments appears to constitute a substantive change because it adds a new requirement. This is likely to generate discussion and, therefore, may be rewritten for future drafts.
The drafting group also recommended the final sentence in the first paragraph of clause 4.3.1 be moved to create a new second paragraph. The language moves away from a narrow focus on the role of significant aspects in establishing environmental objectives to a broader focus on the relationship of significant aspects and implementation of the EMS.
Although no recommendation has been made at this time to change the title of clause 4.3.4 (environmental management program), it was expected to be discussed this summer. As written, the requirements in this section are directed at achievement of articulated objectives and targets. This is not conveyed by the title and causes confusion among those attempting to understand and implement ISO 14001 requirements.
Three changes have been suggested for clause 4.4.2 on training, awareness and competence:
- First, the last paragraph would be repositioned to become the first paragraph. This would change the emphasis from providing training to ensuring employees are competent, and it would acknowledge competence may be achieved through means other than training, such as education and experience.
- Second, the term "personnel" would be replaced by "any person." This would broaden the group of individuals who must be competent from employees to anyone who can create a significant environmental impact, such as contractors or temporary workers.
- Finally, a note would be added at the end of the clause to explain the term "member," which appears in the paragraph concerning awareness training. "Member" would include volunteer, partner, board member or any other type of nonemployee.
The final paragraph in clause 4.4.3, communication, has been addressed. New language would require an organization to "decide whether to communicate externally on its significant environmental aspects." This is an effort to eliminate confusion that has surrounded the requirement to consider processes for external communication.
Clause 4.4.5, document control, would be revised. The changes of greatest interest appear in the first sentence, which would shift focus from documents required by ISO 14001 to documents required by the EMS, and in the two notes at the end of this clause, which differentiate between "procedures" and "documented procedures."
Proposed note one states documented procedures must be documented (that is, written in paper, electronic or other medium), and note two says procedures must require a specified way to carry out an activity but do not have to be documented.
The current language in clause 4.5.1, monitoring and measurement, contains three distinct requirements: monitoring and measuring operations associated with significant environmental impacts, calibrating the equipment used in monitoring and measuring efforts, and evaluating compliance with regulatory requirements.
Proposed changes to clause 4.5.1 would retain only the first two requirements. Evaluation of regulatory compliance would be placed in a new clause 4.5.2 entitled "Evaluation of legal compliance." Remaining clauses would be renumbered, so corrective/preventive action would become clause 4.5.3, records would become 4.5.4, and EMS audit would become 4.5.5.
The second paragraph of clause 4.6, management review, would be rewritten to specify inputs to the management review and required outputs. Inputs include results of EMS audits, changing circumstances and follow-up actions from previous management reviews. Outputs include possible changes to policy, objectives and other elements of the system to fulfill the commitment to continual improvement.
Recommendations for compatibility
The title of the standard would be changed to Environmental management systems--requirements with guidance for use. This reflects the title ISO 9001:2000, "Quality management systems--Requirements.
Clause 4.4.1, structure and responsibility, would be renamed "Resources, roles, responsibility and authority." It is somewhat unclear why this change is categorized as achieving greater compatibility with ISO 9001:2000, because the quality standard devotes one clause (5.5) to responsibility, authority and communication and another (6) to resource management. However, it would clarify the requirements imposed.
Clause 4.4.4, EMS documentation, would undergo significant modification to reflect the general documentation requirements (clause 4.2.1) in ISO 9001:2000. The proposed revised clause says the environmental management system documentation should include:
- Documents required by this international standard.
- Documents needed by the organization to ensure the effective planning, operation and control of processes that relate to its environmental management activities.
- Records required by this international standard (see 4.5.4).
- Reference to related documents.
Unlike ISO 9001:2000, this clause would not require an EMS manual; and unlike the current version of ISO 14001, it would not require a description of EMS core elements.
Clause 4.5.3, records, would be modified in two ways. First, the records procedure would have to be documented. Second, in order to achieve compatibility with ISO 9001:2000, the procedure would be expanded beyond identification, maintenance and disposition of environmental records. Maintenance would be replaced by "storage, protection and retrieval of records."
It is important to note the changes presented here are far from conclusive. Readers familiar with the ISO standards-writing process know every word will be examined in excruciating detail.
Equally important, however, is the message conveyed by this first set of recommendations: There is unlikely to be any substantive change to ISO 14001, either in terms of content or formatting (numbering).
Individuals who were worried the new version of ISO 14001 would bear little resemblance to the old are likely to be pleased with this initial effort at improvement. Organizations in the process of designing or that have already implemented an environmental management system based on ISO 14001:1996 will find they have to make relatively few modifications to demonstrate conformance to the revised version.
Those who hoped the revision effort would impose additional documentation requirements or require greater attention to regulatory compliance and external communication are likely to be disappointed.
MARILYN R. BLOCK is president of MRB Associates, an environmental management system consulting firm. She earned a doctorate in human development from the University of Maryland, College Park. Block co-authored the 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.