ISO 14001 2015 7 requirements

Contents
Introduction3
The new requirements for the context of the organisation 5
Addressing the principles of environmental sustainability 7
Integrating environmental management into business processes 8
Approach to risk 9
The focus on the value chain 10
Preparing top management and others for the transition 11
Compliance obligations and compliance status 12
Conclusions14
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Introduction
Background
The ISO 14001:2015 standard was published on 15th
September 2015, and its new requirements will
result in many organisations making substantial improvements to their EMSs, reflecting the nature of
their activities and the adequacy of existing management practices. This provides an opportunity for
organisations to determine what they want their EMSs to accomplish and how they can be more effective.
The topics in this booklet aim to help you understand the implications of the new requirements and how
they can be applied in your EMS to add value.
Timescales
ISO has allowed for a three-year transition timetable for organisations to meet the requirements of
the 2015 standard. From September 2018, ISO 14001:2004 certificates will cease to be valid. In the
intervening period, organisations can continue to be certified to the 2004 version of the standard, which
will help those not yet ready for the transition. However, any organisation wishing to be certified to ISO
14001 beyond September 2018 must by then meet the requirements of ISO 14001:2015.
If you are reading this in January 2016, 10% of the available time since publication of ISO 14001:2015 will
have passed. 2016 is the time to start to make serious plans for your transition.
Where can I find out more?
GHD’s environmental management systems specialists can help in the ISO 14001 transition process, by
interpreting the new 2015 requirements and supporting organisations in planning for their transition. Nigel
Leehane, GHD’s UK technical leader in EHS Management Systems services, was a member of the ISO
working group responsible for the revision, and is well placed to help organisations understand what they
need to do to benefit from the new standard. Nigel can be contacted at nigel.leehane@ghd.com or +44
(0)115 965 6700 if you would like to know more about the changes to ISO 14001 and the implications for
your organisation. Alternatively, click here to watch a video in which Nigel explains the key issues of the
2015 standard with the British Standards Institute (BSI).
GHD is an IEMA-approved training provider and is certified by IEMA to deliver its one-day workshop,
Making the Transition to ISO 14001:2015. Details of the course and GHD’s latest available training dates
can be found on the GHD website at the following link: www.ghd.com/isocourseuk
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“The revised and reinvigorated
ISO 14001:2015 encourages
organisations to consider
environmental performance
strategically, offering
opportunities to generate real
value from effective environmental
management.”
Nigel Leehane, GHD

The new requirements for the
context of the organisation
An important element of the ISO14001:2015 standard is the new clause 4
concerning the “context of the organisation”. This deals with the strategic
consideration of high level issues, which contribute to determining the scope of the
EMS. This is a logical step, one that organisations must take in order to develop
an effective EMS that focuses on strategically-important environmental issues of
relevance to the business.
The text distinguishes between the general context of the organisation and the
needs and expectations of interested parties, or stakeholders. The general context
refers to external and internal issues, which can be categorised as:
• Environmental conditions, including sensitive environments that the organisation
could damage, and environmental factors that could impact on the organisation
• External context, including cultural, social, political, legal and economic issues
• Internal characteristics, including activities, products and services, but also
culture and organisational capabilities
The expectations of interested parties can include regulatory requirements,
which are mandatory, and also contractual relationships, customer or investor
expectations, trade association standards, community agreements or other
expectations. Those which the organisations decides to adopt become compliance
obligations, and the EMS must be developed and maintained to ensure
conformance with them (see Figure 1 below).
Having an appreciation of context is important in establishing an effective EMS, and
many organisations already are considering their external context and stakeholder
requirements. Perhaps not enough attention is given to internal issues, including
overall business strategy and business culture and processes. The former may have
implications for the scope of the EMS, whereas the latter should determine how the
system is designed and implemented.
Consideration of
issues - internal and
external context and
stakeholders
Wider business strategy
Wider business
processes
Scoping, development
and application of EMS
processes
1
Figure 1: Context of the organisation
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Example of context – water scarcity
A multi-national food processing company, with operations in water-stressed
regions, has many contextual issues to consider:
• The lack of water may be an operational constraint, reducing output (impact
on the business from an environmental condition)
• Use of water may damage a sensitive habitat or deprive local communities of
water (adverse impact on the environment)
• NGOs are campaigning against the company due to the impacts of its
operations, and investors are concerned by this and the reduced revenue
resulting from lost production (needs and expectations of interested parties)
• The company has the technological expertise to use less water in production,
but does not have the business culture necessary appreciate that this is an
effective solution (internal context)
• Climate change will result in greater water scarcity, with increased pressure
on the organization to take action (changing external environmental
conditions)
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Addressing the principles of
environmental sustainability
An important theme of the 2015 standard is the approach taken to environmental
sustainability. The 2004 edition of the standard very much focussed on pollution
prevention, with a specific requirement that the environmental policy should include
a commitment to this. Although sustainable development and environmental
protection are mentioned briefly in the introduction, these terms did not feature
subsequently in the standard.
ISO 14001:2015 takes a very different approach. The introduction opens with an
explanation of the “three pillars” of sustainability and sustainable development,
and states explicitly that the standard provides a framework for protecting the
environment and responding to changing environmental conditions in balance with
socio-economic needs. It goes on to explain that this systematic approach, which
takes a lifecycle perspective and recognises the need for sustainable development,
provides the basis for “achieving financial and operational benefits...that strengthen
the organization’s market position”.
The 2015 standard includes a requirement for the organisation’s environmental
policy to make a commitment to “the protection of the environment, including
prevention of pollution and other specific commitment(s) relevant to the context
of the organization”. This dramatically broadens the emphasis from pollution
prevention, which can be interpreted narrowly as managing hazardous substances,
to a fundamentally wider consideration of environmental sustainability. The deliberate
reference to organisational context implies that the policy should focus the EMS not
just on key environmental risks, but also risks and opportunities for the organisation.
These can include the consequences of poor environmental management, which
may result in additional operating costs, disruption to operations and reputational
damage, and also the impacts on the organisation from changing external
environmental conditions, including from climate change.
ISO 14001:2015 also emphasises the benefits of determining where in the
value chain the organisation can control or influence performance, so that the
consequences of environmental aspects can be reduced or mitigated. Again, this
is not intended as an onerous imposition on organisations, but rather the objective
is to encourage the consideration of external opportunities for improvement, which
may result in lower costs from the supply chain or greater marketing opportunities,
as a consequence of addressing environmental issues.
The intent of the revised standard is to encourage a holistic approach to the
management of environmental aspects, with integration into organisational strategy
and business processes. The outcome should be one that encourages the adoption
of environmentally sustainable practices to deliver sustainable businesses.
2
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Integrating environmental
management into business processes
The ISO Future Challenges study made a number of recommendations for
integrating environmental management with mainstream strategic and operational
processes in the new 14001 standard. One of these was that prior to the
2015 revision, ISO 14001 focused on operational management, and did not
encourage strategic consideration of environmental issues (which could be risks
or opportunities). This is addressed by ISO 14001:2015 in a number of areas,
including the new requirements for considering organisational context and the
needs and expectations of interested parties. The more explicit responsibilities for
top management, and the requirement for the management review to provide input
to business strategy, also help to elevate environmental sustainability to a strategic
level.
Future Challenges also advocated “horizontal integration” with other functions, such
as design, procurement and engineering, whose decisions can have significant
environmental consequences. This is incorporated in the 2015 standard, with an
explanation in the Annex of the importance of integration, involving those steps
shown in Figure 2 below. The management review is now expected to make
recommendations for integration, if needed, with other business processes.
The context of the organisation must now be considered when establishing the
scope of the EMS and planning its development, with environmental issues being
managed as necessary by other business processes. A simple example of this could
be:
• Context - the organisation is under pressure from customers to reduce costs
• EMS - environmental aspects, involving resource use and waste, are identified
as having cost implications
• Business processes - Design, procurement and engineering functions work
together to consider how to modify processes; taking a lifecycle perspective to
reduce resource consumption, waste and cost (without compromising any other
imperatives, such as producing high quality and desirable products).
In establishing its context, the organisation should not just focus on external drivers,
but should also consider internal factors such as its own culture, capabilities and
strategic direction. ISO 14001:2015 has been developed to encourage organisations
to recognise that environmental issues should be managed holistically with all other
business risks, internal and external, to deliver the optimum outcome.
It must also not be forgotten that ISO is modifying all of its management systems
standards to follow a new standard structure and to include common core text. This
should further facilitate the management of more than one discipline (environment,
health safety, quality, energy, information security, etc.) by an integrated
management system, to deliver efficiencies and improve effectiveness.
Context
Business
Processes
EMS
Figure 2: Horizontal integration
3
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Approach to risk
The ISO common structure and core text for management systems standards has
introduced a definition for risk and a clause on “risks and opportunities”. It has also
introduced a requirement for strategic consideration of “context” and the needs and
expectations of interested parties. Together, these new requirements focus attention
on both strategic and operational risk.
The contextual level focuses on identifying key issues related to what the
organisation does, its internal culture and capabilities and the external social,
environmental and economic factors. The needs and expectations of interested
parties can be adopted by the organisation to become “compliance obligations”, to
which it must conform.
The clause on risk includes:
• Establishing a process to determine risk and opportunities
• Identifying environmental aspects and determining if they are significant, based
on whether or not they cause a significant environmental impact
• Determining compliance obligations, in detail. This includes legal compliance
• Planning to take action
The ISO 14001 working group initially modified the core text terminology of “risks
and opportunities” to “risk of threats and opportunities”, to align more closely with
the approach traditionally taken to environmental risk. However, in ISO 14001:2015
the original text of risk and opportunity was reinstated, together with the following
new definition of risks and opportunities, “potential adverse effects (threats) and
potential beneficial effects (opportunities)”.
The risks are also related to the organisation, rather than just the environment
(addressed in considering aspects). Here, the focus is on:
• Risk to the organisation resulting from causing environmental impacts
• The risk that the EMS may not be effective
• Risk to the organisation from external environmental conditions
By addressing organisational risk, the 2015 standard encourages organisations to
take a far more pragmatic approach to its interaction with the environment. Taking
action to minimise impacts can be justified on the basis of the associated business
risks, rather than solely the potential, often indirect, environmental outcomes. This is
far more likely to encourage organisations to take action, thereby improving business
performance and reducing environmental impact.
ISO 14001:2015 does not specify that determination of environmental aspects and
the determination of other risks are two separate processes, so it is for organisations
to decide if they address this as a single, or in separate, process(es).
4
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The focus on the value chain
Previous drafts of ISO 14001 included a separate sub-clause, 8.2, on the value
chain. However, owing to concerns in some quarters regarding the understanding of
the terminology, it was agreed to drop the term “value chain”. The lack of a clause
title, resulted in the decision being taken to incorporate the text on procurement and
design in the operational control clause, 8.1.
Although some concerns have been raised that this diverts emphasis away from
the value chain concept, there is a sound basis for amalgamating all elements of
control in the one clause. There has always been difficulty in satisfactorily explaining
the approach to the control and influence of aspects outside the organisational
boundary (i.e. elsewhere in the value chain), as opposed to those within it. For
example, applying a life-cycle perspective to design (where the design function
itself could be outsourced), can minimise the impacts from environmental aspects
within the organisational boundary and elsewhere in the value chain. The important
concept is that consideration is given to life-cycle aspects, to identify genuine
opportunities where the organisation can exert some form of control or influence.
In order to secure support for new initiatives or improvement actions, it is
important that a robust business case can demonstrate the resultant benefits to
the organisation, for example cost reduction, improvements in product quality or
reliability, process efficiency, reputational benefits or improved compliance, or other
tangible positive outcomes. The degree of confidence in the scale of benefits may
depend on the capacity and capability of the organisation itself, or where and how
the aspects manifest themselves in the value chain.
The potential for exercising control or influence will very much depend on
circumstances. For example, it is entirely feasible to use a contract to control
the performance of a contractor who is taking on responsibility for managing an
effluent treatment plant on the organisation’s site. There may be far less potential
to control or influence those aspects resulting from outsourcing manufacture to a
company in another country. In some cases, the focus should be on controlling
the characteristics of the materials or processes involved, whereas in others the
objective should be to influence partner organisations to change and improve their
own performance and ultimately their culture for managing environmental issues.
ISO 14001:2015 requires the application of a lifecycle perspective, not detailed life
cycle analysis (although that should not be ruled out). Much can be done simply to:
• Identify significant environmental aspects throughout the value chain
• Determine those that can be controlled or influenced
• Develop business cases to explain the benefits of action
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Preparing top management and
others for the transition
ISO 14001:2015 incorporates ISO’s new common text that will be applied to all
management systems standards, including requirements in a new “Leadership”
clause. This applies to “top management”, which is defined as those directing
and controlling an organisation at the highest level[2]
. There are numerous new
requirements imposing accountability for the performance of the EMS, and these
will require top managers to have a greater holistic awareness and understanding of
environmental sustainability issues and the role of the EMS in addressing them, both
operationally and strategically.
They need to:
• have sufficient knowledge to effectively communicate the importance of
environmental performance and continual improvement
• be capable of supporting managers and staff in addressing their environmental
responsibilities
• ensure that resources are made available and that the EMS achieves its
intended outcomes
• ensure that the environmental policy and objectives are compatible with broader
organisational strategy
• ensure the integration of EMS requirements into the organization’s business
processes
Some of this responsibility can be delegated, but top management will have to
demonstrate an understanding of strategically-important environmental issues and
the implications for the business. They will also need to appreciate the implications
for middle managers, and the support and encouragement they will need in order
to deal effectively with environmental issues. They will have to make resources
available, and this implies that they will be sufficiently aware of environmental and
sustainability issues to prioritise the allocation of resources, in accordance with
business needs.
In short, the new requirements should push top management into a position of
greater involvement in environmental strategy development and decision-making,
which in turn should ensure that staff appreciate the importance of taking action.
This greater emphasis on responsibility throughout the organisation also means that
a far broader range of managers and staff will be called upon to consider seriously
environmental performance in relation to their functions, parts of the business or
roles. Although the revised standard does not state explicitly that there will be a
need for a new approach to competence-building, it is inevitable that organisations
will have to upskill if they are to derive the potential business benefits that ISO
14001:2015 encourages. There is nothing new in eco-efficiency, climate change
adaptation, eco-design or sustainable supply chains, but too many organisations fail
to recognise the opportunities that these elements of environmental management
have to offer. The new standard, if properly adopted and applied, should change
this.
[2]
The standard explains that if an EMS applies to only a part of an organisation, a site or a business
division, for example, then the clause applies to those directing and controlling that part of the business.
This could involve people sitting outside, for example where company directors take financial or other
decisions directly related to the part of the business with the EMS, or where it forms part of the portfolio
of a manager or director at a higher organisational level.
6
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7
Compliance obligations and
compliance status
ISO 14001:2004 seemingly provided a robust set of requirements to ensure
organisations appreciated their “Legal and other requirements”, and that they had
processes with which to maintain compliance. However, there has been concern
that organisations with certified EMSs regularly fail to maintain compliance with legal
requirements, and that many have paid little attention to the need to focus on “other
requirements”.
The annex to the implementation guidance for ISO 14001:2004 merely advises that
organisations should be able to demonstrate that they have evaluated compliance.
This has resulted, in many cases, in organisations undertaking a periodic, perhaps
only annual, evaluation of compliance. This snapshot does not provide any
guarantee of compliance in the interim, with the result that organisations can fail
to recognise imminent risks of non-compliance and potential prosecution. The
lack of emphasis on addressing “other requirements” also means that stakeholder
expectations may not be identified and addressed adequately.
The revised standard takes a fundamentally different approach and in a number of
ways. It requires organisations to:
• take a high level look at their “compliance obligations”, which include both
regulatory requirements and voluntary commitments (for example to industry
standards, demands from commercial contracts and agreements with
communities or NGOs)
• determine risks and opportunities associated with compliance obligations.
This could be the risks of the EMS failing to maintain compliance, the scale of
penalties resulting from non-conformance or the benefits accruing from meeting
commitments
• plan actions to address compliance obligations, and to integrate these actions
into the EMS or other business processes
• determine competence requirements that are needed to meet compliance
obligations and ensure these are satisfied
• ensure that awareness-raising and communications programmes take account
of compliance obligations
• maintain processes for evaluating fulfilment of compliance obligations, undertake
evaluation and take action after evaluation, and maintain knowledge and
understanding of compliance status
• consider trends in the fulfilment of compliance obligations (in the management
review); subtly different from the 2004 version
These requirements are far-reaching. They require organisations to develop an
understanding of their compliance obligations, both regulatory and voluntary.
There is more emphasis on understanding the expectations of stakeholders, and
determining those that should be addressed. These could range from commitments
to investors or customers about carbon emissions, applicable industry performance
standards, local community agreements, and any other commitments made by the
organisation.
ISO 14001:2015 requires more rigour in identifying risks associated with non-
compliance, at strategic and operational levels, and in establishing means of control.
A fundamental change is being able to demonstrate compliance status. This is
not a one-off exercise, but a process that provides almost real-time knowledge
and understanding of how the organisation is performing with regard to regulatory
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compliance and voluntary commitments.
Many organisations, especially those subject to detailed regulatory scrutiny,
may already have reliable and ongoing mechanisms for checking compliance.
Such mechanisms can range from continuous emissions monitoring, to daily
housekeeping checks and weekly or monthly reviews of performance against
improvement targets aimed at delivering conformance to compliance obligations.
These organisations typically have a more complete understanding of their current
regulatory compliance performance and are able to identify any risks to continuing to
fulfil these obligations; however, they may neglect voluntary commitments.
Organisations meeting the new compliance requirements of ISO 14001:2015 are
considered to be in a far better position to understand their compliance risks, and
to reap the benefits from being able to demonstrate to stakeholders that they are
fulfilling their commitments to environmental sustainability.
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The ISO 14001 standard has been revised thoroughly, and the ISO 14001:2015 requirements should
encourage organisations to take a more holistic approach to addressing environmental sustainability.
Hopefully, the explanations we have provided in this Infobook demonstrate that these new requirements
should not be considered in isolation. They inter-relate to provide the basis for developing a far more
effective EMS, that itself is integrated with business strategy and management processes (IEMA refers to
the requirements as a “spiders web”).
Organisations adopting the spirit of ISO14001:2015 will be able to improve their EMSs and related
business processes to take advantage of the opportunities provided by evolving environmental drivers
and derive real business benefits, including:
• Enhanced focus of the EMS to improve the management of significant aspects and other risks,
and to take advantage of opportunities (improved compliance, reduced emissions, greater resource
efficiency, lower energy costs, etc);
• Greater resilience to changing environmental conditions (resource cost and availability, energy
security, climate change impacts, supply-chain failure, etc);
• Enhanced reputation and brand, from more relevant improvement objectives and better
communication of results, reflecting stakeholder expectations; and
• Overall enhanced organisational performance, adding value and contributing to environmental
sustainability and a sustainable business.
Conclusions
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ISO 14001 2015 7 requirements

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