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IEMA ISO14001 - External Auditors viewpoint

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Delivered as a representative of the IIOC, find out what external auditors are looking for when auditing the newly revised ISO 14001 standard.

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IEMA ISO14001 - External Auditors viewpoint

  1. 1. ISO 14001:2015 Significant Changes and what the Auditor will look for.
  2. 2. Changes and what an Auditor will be looking for IEMA Manchester Conference 2015 3.3.2 documented information A new term that replaces the words ‘documentation’ and ‘record’. – Where the standard uses the phrase ‘retain documented information as evidence of…’ it means records. – Where the standard uses the phrase ‘maintained documented information’ it means documentation other than records. If you have a procedure or a record currently in your system that you feel you need or which meets the new requirements, don’t throw it away! 3
  3. 3. Changes and what an Auditor will be looking for IEMA Manchester Conference 2015 4.1 Understanding the organization and its context This is a new requirement. Although the text does not require a procedure or specific documented information, the organisation will need to demonstrate that the requirement has been carried out, and the outcome fed into other requirements of the standard such as in clause 4.4 (the EMS) and 6.1. (Actions to address Risks & Opportunities) Techniques used may include PESTLE analysis, and SWOT analysis, and others simpler method, it depends of the size & complexity of the organization. Considerations are not solely limited to environmental factors, but should include other business factors that could impact on the EMS. Some organisations will have carried out dedicated climate change mitigation studies – a good start, but it must cover all relevant issues. Compliance may be achieved during a periodic review meeting, or via an on-going process. Typically, the leadership of smaller organizations tends to be closer to their activities, so they will have a much clearer idea as to the context in which the organization operates, who their interested parties are and what they wish their EMS to deliver. 4
  4. 4. Changes and what an Auditor will be looking for IEMA Manchester Conference 2015 4.2 Understanding the needs and expectations of interested parties This is a new requirement. The text does not require a procedure or specific documented information; however, the organisation will need to demonstrate that the requirement has been carried out, and the outcome fed into the other requirements of the standard in clauses 4.4 and 6.1. Some process will be required for identifying needs and expectations expressed by interested parties. Some organisations may have well-established stakeholder management processes while others may be less formalised. The process should be appropriate, understood, and effective. 5
  5. 5. Changes and what an Auditor will be looking for IEMA Manchester Conference 2015 5.1 Leadership and commitment Nine specific requirements are listed, and top management are accountable for ensuring that they are performed, but responsibility may be delegated to others. 1) Leadership now has direct accountability for the system effectiveness and cannot rely purely on delegated responsibility. 2) Perhaps the most fundamental new requirement is the second and the link with ‘strategic direction’. In other words, early consideration should be given to implications on the EMS when making important business decisions such as planning future strategy, resource planning, acquisitions and mergers, and developing new products and services. Many organisations fail to do this, and the result is that the EMS is not fully integrated into the organisation business processes (3rd requirement). 3) Where the business has established processes (such as procurement), the environmental procedure requirements should be integrated into business processes. 4) Resources – such as financial, technical, time, infrastructure, expertise 6
  6. 6. Changes and what an Auditor will be looking for IEMA Manchester Conference 2015 5.1 Leadership and commitment Cont’d 5) Communicating – also see relevant associated clauses in square brackets 6) Outcomes – those specified in the policy and objectives 7) A range of persons may contribute to the effectiveness of the EMS (not just the environmental manager if there is one). 8) Continual improvement - no interpretation needed 9) The ninth bullet point ‘supporting other relevant management roles’ is a change in emphasis from reliance on one environmental representative. This is both necessary and desirable because ISO 14001:2015 has greater implications for other departments such as design and procurement. Evidence will be required to demonstrate that top management meets each requirement of this clause. However, again this clause does not require a procedure or specified documentation. In addition to carrying out a top management interview, an auditor will look for evidence for some of these requirements have been considered alongside their most relevant associated clause 7
  7. 7. Changes and what an Auditor will be looking for IEMA Manchester Conference 2015 6 Planning, 6.1 Actions to address risks and opportunities , 6.1.1 General This is a new requirement in ISO 14001:2015. It is also the first clause that starts with the words “establish … a process”. Some clients may struggle to understand the differences between aspects identification, and risk and opportunities – the two are not mutually exclusive, but risk and opportunities must be applied to more than just aspects. Auditors will have to verify that the organization’s assessment is sufficiently comprehensive and includes risks and opportunities related to aspects, compliance obligations, context, and interested parties. This clause specifically requires documented information to be maintained. 8
  8. 8. Changes and what an Auditor will be looking for IEMA Manchester Conference 2015 6.1 Actions to address risks and opportunities, 6.1.2 Environmental aspects Whilst this clause is almost the same text as in ISO 14001:2004 except that a procedure is not required, but documented information must be maintained, and addition of the key words “considering a life cycle perspective”. Although this clause does not require either a procedure or a process, documented information is required for the criteria used, aspects, impacts, and significant impacts. It is expected that some organizations will be more advanced in understanding their life cycle impact than others. Also, some organizations (due to their size, influence, and expertise) will have greater ability to influence life cycle aspects. Organisations that do not carry out any design (such as subcontract metal fabricators) will have less ability to include the environmental impact of the product. These same organisations may also have their hands tied by the customer when it comes to procurement of raw materials. It is therefore important to have a good understanding of the organisation does when it comes to assessing this clause. 9
  9. 9. Changes and what an Auditor will be looking for IEMA Manchester Conference 2015 6.1 Actions to address risks and opportunities, 6.1.4 Planning action This is a new clause for ISO 14001:2015, however, ISO 14001:2004 did require significant aspects and legal and other requirements to be taken into account when establishing the EMS. The addition is to plan to address risks and opportunities, and also evaluate the effectiveness of these actions. Unfortunately (from an assessment point of view) this clause does not require a documented plan. Nevertheless, the organisation will have to demonstrate that the requirements have been carried out. Typically a sampling approach will be used, asking for evidence that issues from a) 1-3 have been actioned, and seeking evidence of the effectiveness of these actions. 10
  10. 10. Changes and what an Auditor will be looking for IEMA Manchester Conference 2015 8.1 Operational planning and control Operational control was previously clause 4.4.6 in ISO 14001:2004. There is a new requirement for the organisation to ensure that outsourced processes are controlled or influenced. The organization will need to determine what control or influence they have over outsourced process, an auditor will look at the way that this has been addressed; measure to control or influence may include: requesting and reviewing compliance and performance information, specifying competency requirements, undertaking supplier audits, and/or requiring third party certifications. 11
  11. 11. Changes and what an Auditor will be looking for IEMA Manchester Conference 2015 8.1 Operational planning and control Cont’d There are more specific requirements in this clause for controlling significant aspects at the appropriate stage in their life cycle: design and development, procurement, direct operational processes, delivery, use, and end-of-life. Auditors will have to make an informed judgement as to whether the extent of the life cycle controls applied are sufficient to meet the new requirements based on factors such as: – the importance of the life cycle impacts of the client’s products and services – the level of control and influence that the client has (up and down the supply chain) – the level of knowledge, competence and resources – improvement opportunities available Design and development decisions can have a positive, or negative environmental impacts in areas such as: – raw material selection: embodied energy and water, material efficiency, toxicity, and other upstream impacts – product characteristics: such as energy and water efficiency in use, durability, weight, ease of maintenance, modularity, functionality, biomimicry, and noise – packaging characteristics: weight, type, toxicity, recyclability – cleaner production techniques – design for reuse, recovery, upcycling and recycling for example by facilitating easy disassembly, labelling parts, avoiding mixing biological and non-biological (technical) materials – Environmental procurement controls vary greatly across organisations and sectors from questionnaires, to audits, to collaborative problem-solving workshops. – Environmental product information may include information about correct installation, servicing and maintenance to ensure maximum efficiency, to end-of-life disposal options or take-back schemes. 12
  12. 12. Tools that will be used by the auditor IEMA Manchester Conference 2015 Auditors will make much more use of the definitions in section 3 of the standard and the interpretative guidance given in the Annex. Organization need to bear this in mind and make use of these as well, ISO 14004 will be published soon (early 2016) and will give further guidance on implementation. 13
  13. 13. IEMA Manchester Conference 2015 Any further questions? 14

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