FDIS ISO 14001:2015 on the home stretch
The most recent developments in the Revision of ISO 14001:2015 as well as parallel trends at the level of the European Union
In mid-April, a basic agreement could be reached after an additional five-day marathon round of negotiations. In Tokyo, it had in, February 2015, been possible to process about 350 comments among 1,300 comments. At an additional meeting held in London, it was a matter of guaranteeing that the timetable for the ISO 14001:2015 Revision, according to which publication is intended by September 21, 2015, can be kept.
The pressure of going through the large number of comments and new suggestions and reaching an international consensus was correspondingly high. Negotiations were held until recently. The qualityaustria experts Thomas Szabo and Axel Dick represented Austria and were present in London. All over the world, about 300,000 organizations are concerned. In Austria, more than 1,000 organizations are concerned.
Now the draft of FDIS is in place and has already been edited. This means that linguistic subtleties have already been clarified. Then a final matching will take place in Delhi/India in early September 2015. Therefore, it will be possible to keep the publication date, which is intended for September 21, 2015.
The most important lessons learned
Basically ISO 14001:2015 follows the High Level Structure (HLS) just as much as ISO 9001. This will help to make integration easier. The future ISO 45001, (which will supersede OHSAS 18001), will also follow this structure.
The requirement for analyzing the context of the organization (Clause 4) is aimed at helping organizations to better understand their own organizations conceptually and more comprehensively, for example as far as internal and external interested parties are concerned, and to identify their needs and expectations and possible influencing factors. The context also includes the need to take the environmental condition into account. For this condition influences the organization while the organization, for its part, influences the environmental condition because of its activities, products and services. The context of the organization must be seen as being closely linked to internal communication. Up to now, many companies have already dealt with the internal and external target groups or stakeholders. Nevertheless, a survey recently made by Quality Austria shows the following for the requirement for considering the environmental condition when analyzing the context: On the whole, there are still many unclear points when it comes to understanding what this requirement actually means.
Top Management is asked to demonstrate leadership (Clause 5) even more. This means that the environmental aspects need to be integrated in the business processes, strategic planning and decision-making. The role played by Top Management is becoming more significant. This is not only due to the fact that Top Management is required to act as a role model and assume an active leadership role. Top Management also needs to be more active and involved in this respect because the classical Environmental Representative no longer is required. In practice, however, the Environmental Representative will continue to be there in order to meet the many different and comprehensive technical, legal, normative and ecological requirements.
Due to the High Level Structure, the risk-based approach can be found in ISO 14001:2015. However, the following should be noted: This section has meanwhile been slightly modified linguistically, and the wording has, in Clause 6.1, come closer to that of ISO 9001 again at the ISO Meeting in Tokyo in February. The wording “threats” has been removed. Now the Clause is called “Actions to address risks and opportunities”. In this respect, this approach includes the identification of risks and opportunities from the perspectives of analysis of the context of the organization, environmental aspects and impacts, legal requirements as well as emergency preparedness and response.
“Compliance with legal requirements” is superseded by “Compliance obligations”. The term of “Compliance obligations” denotes compliance with legal requirements, additional burdens as well as voluntary self-commitments (industry standards, contracts and agreements, ethical standards). In this respect, it fundamentally only is wording that has changed. In practice, nothing will change as compared to the way to handle legal management that has been required up to now.
Environmental performance needs to be improved. Basically the term is not new. Environmental performance is the measurable output of management of the environmental aspects within an organization. In the Revision, it is indicators that play a role now. An indicator is the measurable visualization of the condition or status of a functional process, management or conditions. The term of indicator is used in Clause 9 “Performance evaluation” several times. As for this specification, ISO 14031:2013 is simultaneously hinted at in the Annex. ISO 14031 makes a distinction between performance indicators relating to management policies and programmes, compliance with regulations, financial performance correlated with environmental performance, performance indicators referring to the relations to the community, operational performance indicators and indicators for the environmental condition.
The requirement for a “life cycle perspective” for products and services is a new requirement that draws a red-thread path throughout the Standard. It is true that no detailed life cycle analysis like that in ISO 14044 is required. Nevertheless, it should be noted that all the phases of the life cycle need to be considered and that the companies need to review to what extent they can control and influence these phases. As the case may be, this will affect deliberations about the environmental aspects and impacts if it also is tried to determine environmental aspects and impacts for all phases of the life cycle. Thus the identification of significant environmental aspects and relevant environmental impacts might also change. Moreover, the local or regional environmental condition can influence this specification and lead to a different assessment result.
Awareness and competence are separate Sub-Clauses in Clause 7 Support and are thus upgraded as compared to earlier times.
Internal and external communication becomes more important. Internal communication is closely linked to the internal context. In analogy, external communication is closely linked to the external context. External communication is demanded so that a dialogue with the external target groups about environmental performance achieved can help to boost confidence.
Context and environmental condition
In the draft of ISO 14001:2014, the following is stated in Clause 4.1 “Understanding the organization and its context”: “The organization shall determine external and internal issues that are relevant to its purpose and that affect its ability to achieve the intended outcome(s) of its environmental management system. Such issues shall include environmental conditions being affected by or capable of affecting the organization.” Due to this, the organization will, in future, also have to ask the following questions: What environmental factors, e.g. climate change or scarcity of water, have an effect on the organization? How does the organization, for its part, influence the environment based on its activities, products and/or services, e.g. because of emissions of greenhouse gases or water consumption? However, this also means that indicators for the environmental condition become important to adequately acquire the starting point, the effect on the organization and the organization’s impact on the environmental condition.
Life cycle consideration - developments in ISO 14001:2014 and at the level of the European Union
This requirement draws a red-thread path through the Standard. In 3.3.3, “life cycle” is defined as follows: “consecutive and interlinked stages of a product (or service) system, from raw material acquisition or generation from natural resources to final disposal”. Life cycle consideration is addressed in the scope (Clause 1), in connection with the environmental aspects (Clause 6.1.2) as well as relating to operational planning and control (Clause 8.1). However, no detailed eco-balance is required. A simple life cycle consideration is sufficient. Here the following central question arises: What steps in the life cycle can be controlled or influenced by the organization? Still this question will, in future, be given an additional dimension if the endeavours at European level, which are taking place and are future focused, are conceptually taken into account just as well.
EU Commission - Zero Waste Initiative
For autumn 2015, a new suggestion with revised objectives for the Zero Waste Initiative may be expected. Background: Europe is a continent poor in resources. This is why a strategy for keeping raw materials in the economic cycle as long as possible, even after the first “period of life” (phase), is being worked at. If waste is exported again, these raw materials will also be lost. Besides the revision of the objectives, an action programme lasting for 2 to 4 years is expected. Waste law will be affected by this. Still other motives for “circular economy” are the following:
- reduction of adverse environmental impacts;
- exhaustion of resources;
- preservation of bio-diversity;
- reduction of water pollution
The strategy paper provides for four axes of a circular economy:
- extraction/winning of the raw materials;
- product design;
- waste management at the end of the circle
As for product design, there are three pillars:
- minimizing of material input during production;
- minimizing of resource consumption during use;
There is a second development: The Eco-Design Directive should not only be extended to additional products and thus, in future, also cover B2B (Business to Business) products. Besides the criterion of energy efficiency, that of material efficiency should also be taken into account.
The third development can be described as an “EU Internal Market for Green Products”. In this respect, it is a question of the Product Environmental Footprint as a tool of consumer information. In future, standards for organizations and products are to be derived from this. In addition to the “classical” categories on environmental impacts, such as Global Warming Potential, Ozone Depletion Potential (ODP) or Human Toxicity Potential, such topics as PM10 (Particulate Matter), radiation or exhaustion of resources (water, fossil fuels) should also be taken into account. In 2013, 27 pilot projects were started. These projects are intended to be finalized by 2016.