Steve Williams System and Governance Manager at Lloyd’s Register Management Systems, and ISO/TC 207/SC1 committee member, shares his thoughts about the revised EMS, the key areas that organisations are talking about and the transition process.
Compared to ISO 14001:2004, what do you consider to be the biggest difference in the approach that organisations are taking towards the adoption and implementation of ISO 14001:2015?
The new and changed areas in ISO 14001:2015 are making organisations look very closely at what they do and how they do it, with particular emphasis on their supply chains and outsourced processes.
In addition to this change, the emphasis which has been placed upon leadership means that senior management teams now have to become much more involved with the implementation and management of their organisation’s EMS.
The most significant changes that organisations will face when implementing ISO 14001:2015, come from the adoption of the common high level structure, introduced by Annex SL.
What is Annex SL and what does it mean for my management system?
Annex SL is the High Level Structure applicable to ISO Management System Standards (MSS). It features 10 clauses as well as common terminology and definitions. We have seen many organisations not only transitioning their EMS but also their quality management system standard ISO 9001:2015 (QMS) thereby saving them time and money.
This common structure means that it is now far simpler for management system controls on disciplines such as quality and information security - as an example - to be integrated into a single ‘business management system’.
Annex SL has led to changes in relation to the term ‘Documented Information’ rather than procedures or records. In addition, Annex SL has led to the incorporation of management systems into the strategic thinking of the organisation and increased responsibilities on top management.
Over the past couple of years, whilst conducting transitional audits, have you noticed any trends in the areas that organisations are asking the most questions about?
Over the course of the revision process, there are three key areas which have consistently raised questions from organisations looking at the new standard; Leadership, Life Cycle Perspective and the Assessment Process.
As the Leadership clause was new to ISO 14001:2015, it’s natural that organisations have been asking questions. Senior management teams have to be involved in their organisation’s EMS more than they ever have and internal auditors have a key role to play in order to make sure that the changes to the standard are understood and embedded into the culture of the organisation.
This will mean that auditors will need to be prepared to question senior management and potentially raise nonconformities. As for the assessment process, and questions about the lifecycle perspective, assessors will be looking for the justification behind decisions made by organisations, particularly around the areas of Context, Interested Parties, Life Cycle Perspective and Control or Influence, they will be using the term “show me” quite a lot.
They will be looking at these decisions to see that they are fact based and supported by the processes employed by the organisation.
The incorporation of the Life Cycle Perspective is new to ISO 14001:2015, but the new standard isn’t calling for a full analysis, so organisations don’t need to be fearful. Annex A within ISO 14001:2015 states that “thinking carefully about the life cycle stages that can be controlled or influenced by the organisation is sufficient.” Assessors will be looking to see that an organisation has developed a management system that addresses all of the potential environmental risks throughout the Life Cycle of their product or service, this brings in such elements as design, procurement, outsourcing, product realisation processes, product/service use and end of life, over which they have control or influence.
What impact does ISO 14001:2015 have when considering interested parties?
Annex SL introduces a section on context of the organisation (clause 4) that means a company has to have a process in place to identify internal and external interested parties.
This includes recognising the views that are key to the environmental performance of the organisation and take those into account when they are looking at designing their EMS. As a result, this has become an important part of the revised requirements.
Does the revision to ISO 14001:2015 affect organisations in exactly the same way –irrespective of their size or geographical location?
The potential organisational impact of the revisions is dependent upon the organisation and their individual management system.
Factors such as the maturity and complexity of their existing management system, the existence of other management systems and the organisation’s current evaluation and management of risk will heavily influence the degree of change that an organisation will need to undertake to meet the requirements.
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