ISO 14004 To Offer Practical Guidance
More examples and alignment to be among the improvements
by Marilyn Block
The release of ISO 14004 accompanied the publication of ISO 14001, the environmental management standard, in 1996. ISO 14004 was billed as a general guideline on environmental management principles, systems and supporting techniques.
That initial guidance effort was limited by an inability to draw on actual experiences--ISO 14004 was written concurrently with ISO 14001 and was published before organizations began implementing environmental management systems (EMSs) that conformed to ISO 14001 requirements. As a result, ISO 14004 has been viewed by many as having little to offer organizations with more than the most rudimentary approach to environmental management.
Like its ISO 14001 counterpart, ISO 14004 is now being revised. Unlike ISO 14001, ISO 14004 is in the process of undergoing significant cosmetic and substantive changes. In fact, readers familiar with ISO 14004:1996 will find the new committee draft no longer bears a strong resemblance to its predecessor.
A general characteristic of the ISO 14004 revision is far greater emphasis on practical information based on user experience during the last five years.
Connie Glover Ritzert, chair of the U.S. Technical Advisory Group to ISO Technical Committee 207's subcommittee 1 on environmental management systems and subcommittee 1 working group expert, explains: "As part of this emphasis, we have added more examples, including some cross-cutting ones that tie key parts of the EMS together in illustrations."
One of the major challenges in revising ISO 14004 has been staying consistent with ISO 14001, which is a moving target at present. The two standards are on the same revision schedule, so it has been difficult to reach consensus on issues that are strongly influenced by the direction taken in ISO 14001.
Because ISO 14004 is a guidance document, it can go beyond the concepts in ISO 14001 as long as it presents the same basic picture of an EMS. Ritzert says, "We are making a concerted effort to maintain consistency while not portraying ISO 14004 as an interpretation of ISO 14001."
One of the ways ISO 14004 shows consistency between the two standards is by aligning its clauses more directly with ISO 14001. ISO 14004 also continues to use the definitions presented in ISO 14001 and describes the same continual improvement model.
The most significant changes in the revised draft are:
- Elimination of the five principles.
- Use of help boxes.
- Presentation of five approaches to pollution prevention.
- Expansion of the environmental aspects clause.
- Agreement on the need for a broader view.
- Provision of help on compliance commitment and expansion of emphasis on objectives and targets.
Elimination of the five principles. The current version of ISO 14004 begins with a discussion of five principles (commitment and policy; planning; implementation; measurement and evaluation; and review and improvement). It then inserts them into a modified version of the EMS model that appears in ISO 14001.
ISO 14004 then uses the five principles to group EMS elements. As part of the effort to be more practical, discussion of these five principles has been removed. Instead, the standard begins with a discussion of the EMS's PDCA (plan, do, check, act) model. ISO 14004 has been revised so this model (see Figure 1) is now the same as in ISO 14001
Use of help boxes. ISO 14004 contains a series of practical help boxes with suggestions to assist readers in conducting activities required by their EMS. For example, one box on prevention of pollution has been added to support the clause on environmental policy.
Presentation of five approaches to pollution prevention. The proposed text presents a hierarchy of approaches:
1. Source reduction (including material substitution; process, product or technology changes; and efficient use and conservation of resources.
2. In-process recycling or reuse.
3. Other recycling or reuse.
4. Treatment and recovery.
The text suggests organizations employ incineration or other forms of disposal only after the options offered in this hierarchy have been considered.
Expansion of the environmental aspects clause. The clause on environmental aspects has been greatly expanded to help organizations better understand what is meant by and involved in identifying environmental aspects and evaluating their impacts.
It has been difficult to revise this clause because there are a variety of understandings and experiences among practitioners and users of the standard. ISO 14001 defines an environmental aspect the same way ISO 14001 does: any element of an organization's activities, products or services that can interact with the environment.
Agreement on the need for a broader view. Although consensus has not been reached on a number of points around the issues of identifying aspects, evaluating impacts and assigning significance, it has been agreed a broader view is warranted than was expressed in the 1996 standard. Ritzert notes, "Working group experts did reach agreement that criteria for 'significance' could include consideration of environmental and legal concerns and the concerns of interested parties..."
The committee draft document had specifically asked for comments on two proposed methods for determining aspects, impacts and significance. It also asked whether the final standard should contain more than one example of methods for determining aspects. It is likely this clause will be subject to a great deal of debate before final language is established.
The clause on legal and other requirements has been expanded. Proposed language clarifies what is meant by "access to" these requirements. A new section differentiates between legal and other requirements by explaining what "other" comprises.
Provision of help on compliance commitment and expansion of emphasis on objectives and targets. To more clearly establish the link between this clause and the environmental policy (which is required to commit to compliance with legal and other requirements, per ISO 14001), a practical help box on commitment to compliance has been added.
Readers of ISO 14001 know environmental objectives and targets must reflect the environmental policy. Moreover, significant environmental aspects and legal and other requirements are among the issues that must be considered.
Therefore, more emphasis has been placed on the process of setting objectives and targets, and the table of examples has been expanded. A new section on the need to evaluate organizational performance in achieving objectives and targets incorporates concepts from ISO 14031, a guideline for creating internal management processes and tools to provide ongoing information to determine whether an organization is meeting established criteria.
Other clauses that have benefited from expanded discussions include:
- Communications. This clause has been reformatted to distinguish among general benefits of communication, internal communication, external communication and processes to enhance communication.
- Operational control. This clause now addresses identifying the need for controls and establishing and evaluating them.
- Monitoring and measurement. This clause clarifies the purposes of monitoring and measuring activities and offers a table of examples.
- Evaluating regulatory compliance. ISO 14001:1996 addresses the need to periodically evaluate regulatory compliance as part of the clause on monitoring and measurement. The revised ISO 14001 document moves this paragraph out of monitoring and measurement into its own numbered clause. For consistency, ISO 14004 proposes a new clause on evaluating compliance.
- Nonconformance and corrective and preventive action. Considerable text has been added to this clause, which is only two sentences in the current version of ISO 14004. The revision addresses the need for a systematic approach in identifying and responding to nonconformances. It also provides examples of nonconformances.
- Continual improvement. This clause has been reformatted into three separate sections: establishing the purpose of continual improvement, identifying opportunities for improvement and implementing continual improvement. A new practical help box provides examples of improvements.
- Annex A. In the 1996 standard, this annex provided two examples of international guiding principles: The Rio Declaration on Environment and Development, produced at the United Nations Conference on Environment and Development in Rio de Janeiro in June 1992 and The Business Charter for Sustainable Development, created in Paris in 1991 by the International Chamber of Commerce.
The new Annex A illustrates the implementation of an EMS by presenting three examples--an activity, product and service--and showing a commitment in the environmental policy, significant environmental aspect, objective and target arising from the policy and aspect, and method for monitoring environmental performance for each example.
Although a great deal of wordsmithing is likely to result after comments on the committee draft are received, it appears the format, tone and focus of ISO 14004 are well-established.
Efforts to enhance the utility of ISO 14004 by aligning it more directly with ISO 14001, clarifying language and concepts, and incorporating a variety of examples that reflect actual experience suggest ISO 14004 is well on the way to becoming what it was always intended to be: a guidance document that assists in implementing an effective environmental management system.
ISO 14004 is expected to be released in early 2003.
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.