3. Changes and what an Auditor
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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!
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4. Changes and what an Auditor
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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.
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5. 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.
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6. 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
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7. Changes and what an Auditor
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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
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8. Changes and what an Auditor
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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.
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9. Changes and what an Auditor
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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.
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10. Changes and what an Auditor
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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.
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11. Changes and what an Auditor
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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.
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12. Changes and what an Auditor
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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.
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13. 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.
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