ISO 14001:2015 an Opportunity to Start Fresh
The changes required for the transition are significant but there is no need to throw out everything that you already have and start again. So to avoid being swept up in the last minute dash for transition dates read this blog...
The book ‘The Hitchhiker’s Guide to the Galaxy’ talks of a travel guide that tells you everything you need to know about anything and is described as "the standard repository for all knowledge and wisdom". To help readers in its use and to guide them into making sense of its contents, the front of the book is shown like this:
I have often thought that presentations on ISO standard amendments should also carry the same logo. I hope to show in this blog that the above sentiment also applies to the changes to ISO 14001 that you are required to make and that a logical re-appraisal of existing controls can be one way of addressing some of the changes.
As I sit down to write this blog we are into the final 12 months of the three year transition period that was allowed for organizations to make the changes required to meet the new version of ISO 14001.
Despite being two-thirds of the way through the allowed time, nowhere near two-thirds of our clients have made that transition and we are therefore expecting an avalanche of applications in the final few months. I guess much of this is down to priorities. In September 2015, the three year deadline seemed ages away and like most things, it has crept up upon us and we have less than 12 months to go.
It may well be that there is a sense of apprehension - what does “Protection of the Environment” actually mean for example? One MD who shall remain nameless said to me “I suppose I’ll have to start fitting bird-boxes around the site then”. My response was don’t let me stop you! This however this typifies the misconceptions that seem to be out there.
The changes required for the transition are significant but there is no need to throw out everything that you already have and start again. The standard requires that a number of key areas have to be examined and in many cases a re-evaluation of the existing controls is what is needed.
The following is a list of key areas where there have been changes to the requirements and I would certainly suggest evaluating existing controls against these areas rather than starting out afresh.
Strategic Environmental Management
- Higher profile for the role of strategic planning within the system. Managing change using the EMS and highlighting opportunities to manage or mitigate risk.
Risk Based Thinking
- Building on the above point and prioritising those actions that can reduce environmental impact.
- A new requirement building on the previous requirement of ‘management commitment’. Senior staff, in the area of the EMS need to provide hands-on leadership and not just pay lip service to it.
Protecting the Environment
- The standard does not define this requirement. It however a much more proactive approach to improving your environmental impact and includes areas such as sustainable resource usage, carbon reduction, end-of-life disposal of products etc.
- Organizations need to think about the lifecycle of their product or service. Interestingly the standard says you only have to look at areas that you can control of influence. So a full cradle to grave approach may not be either appropriate or indeed necessary.
- One of the rationales for the way the new standard was written was to allow easier integration with other standards written in the same format (ISO 9001 for example). It is also now a requirement that the EMS does not ‘stand-alone’ but becomes part of the wider business model operated by the company.
On the face of it, many of these areas seem new and in some cases a bit ‘radical’. But if you stop, think, take a deep breath and measure where you currently are you may be pleasantly surprised.
One of key areas that has to be carried out from scratch, but will certainly allow you then re-evaluate your existing controls is the very first auditable clause - ‘The Context of the Organization’.
This require you to determine external and internal issues relevant to your organization’s purpose and that affect your ability to achieve the main expected outcome of the standard - Improved Environmental Performance. In other words:
What is going to help you achieve this?
What is going to get in the way of us achieving this?
To some extent, the rest of the standard is all about helping you maximize those things that can help and minimize or mitigate those that get in the way. Taken from a slide I use in one of our transition webinars, the following gives a good guide to the areas to consider:
If you then judge your current controls for their continuing suitability to be able to help you achieve an improvement in Environmental Performance you be pleasantly surprised. There are new, more specific requirements that relate to the control or influence exercised over outsourced processes - these may to some extent be covered via exiting purchasing arrangements and at worst may only need amending to add in a degree of environmental decision making into the process.
Many guides to the transition process explicitly state that you should ‘Assume every control will need to be changed’. I would personally alter that to:
Assume that every control will have to be re-evaluated to judge its continuing suitability.
ISO 14001:2015 does not require you to dispose of your existing environmental management system and start again from scratch. The intention has always been that many existing controls are perfectly adequate and can simply be carried across.
Interestingly, what has changed is the need for fully documented processes. The new standard now allows you to document those controls in a way that suits your organization and in some cases remove the written controls completely and rely on the competence of your staff - so long as those required competencies are documented.
So to avoid being swept up in the last minute dash for transition dates and the risks that go along with that, take a deep breath, step back and just have a look at your existing controls. Think about what will help you achieve improvement in environmental performance and what will hinder you. Judge your existing controls against this criteria but above all:
The NQA website contains additional transition guidance and our YouTube channel has recordings of transition presentations covering both ISO 14001 and ISO 9001.