CD Iso 14001 Ebook

REVISION OF ISO 14001
Key Changes Proposed in the March 2013 Draft

This report was prepared by: Nigel Leehane and reviewed by: Bryan Hughes
Bringing sustainability and safety to the

worlds most complex environments
Revision of ISO 14001

TABLE OF CONTENTS
1.0 Introduction
3
3
1.1 Background
1.2 Where can you find out more?
2.0
Greater Expectations for Top Managements Leadership and
Commitment
3.0

How to Address Strategic Environmental Issues, the Interests of

Stakeholders and the Direction of the Business
4.0

What commitments to make to sustainable development and

social responsibility?
5.0

Extending environmental influence into the value chain, with

implications for procurement
6.0
Environmental Design as a Tool for Improvement
10
7.0
Demonstrating Environmental Compliance Status
11
8.0
Using performance indicators to track improvement
12
9.0
Timeline and Milestones for the Revision Process
13
9.1
9.2
Opportunities for Responding to Consultation

Timescale for Conforming to a Revised Standard
13
13
10.0
How can CRA help with the transition to ISO 14001:2015?
14
LIST OF APPENDICES
Appendix A
Future Challenges Recommendations
18
Appendix B

Relationships between the Clauses of ISO 14001:2004 and

the March 2013 Revision Draft
20
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1.0 INTRODUCTION
1.1 Background
ISO 14001:2004 is being revised. The International
Organisation for Standardisation (ISO) working group
responsible for revising the text met in early February
and has produced a Committee Draft which is being
circulated for comment to its member bodies.
When published, ISO 14001:2015 will have a new
structure and common text, following ISO rules
for all management systems standards. It will also
address the recommendations from the ISO Future
Challenges study (Appendix A), for the adoption of
various new approaches and methods in the field of
EMS, and to meet the needs of stakeholders in the
future.
This is a fundamental revision of the standard, with far
greater implications for organisations than the previous
revision in 2004. This report, which identifies seven
major changes proposed in the current draft, aims to
help you appreciate the key themes of the revision,
and what auditors may expect from you once
ISO 14001:2015 is released:
Some of these new requirements are addressed by

changes to the structure of the standard, which will
include new clauses on:
Understanding the organisation and its context;
Understanding the needs and expectations of
interested parties;
External communication and reporting;
Value chain planning and control; and
Continual improvement.
Many of the other clauses have been strengthened and
the order of many in the standard has changed. For
example, awareness is no longer part of competence
and training, but is a separate sub-clause.
Non-conformance now sits between management
review and continual improvement, a new sub-clause
which provides greater emphasis on improvement
at the end of the standard. Tables showing the
relationships between the clause structure of the 2004
edition and the proposed new structure are provided in
Appendix B.
1. Greater expectation for top management to

understand the organisations environmental
issues, support the EMS and champion improved
performance;
The anticipated timescales and key milestones in the

revision process, including opportunities to respond to
consultations, are set out in Section 9.0.
2. Broader strategic consideration of the

organisations environmental context, including the
interests of stakeholders and the direction of the
business;
1.2 Where can you find out more?
3. Making specific commitments to sustainable

development and social responsibility;
4. Extending environmental influence into the supply
chain, with implications for procurement;
5. Embracing opportunities for using environmental
design as a tool for improvement;
6. Being able to demonstrate an understanding of the
organisations environmental compliance status at
all times; and
CRA will be publishing briefings throughout the revision

process. If you would like to receive them, then please
subscribe to our quarterly newsletter via our website.
Existing subscribers will automatically receive the
newsletters and any other ISO 14001 briefings.
Nigel Leehane is one of the UKs technical experts
appointed to the ISO working group revising 14001.
Please contact him on 0115 965 6700 or
nleehane@cra.co.uk if you would like to know more
about the changes to ISO 14001 and the implications
for your organisation.
7. Using performance indicators to track

improvement.
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2.0 GREATER EXPECTATIONS FOR TOP MANAGEMENTS LEADERSHIP

AND COMMITMENT
ISO 14001:2015 will include new clauses on leadership
and the commitment of the organisation, which expand
significantly on the requirements of the current version
of the standard.
The current version of the standard requires
top management (those who control or direct
organisations at the highest level) to define the
environmental policy, appoint a management
representative responsible for the EMS and reporting
back to them, and undertake the management
review. This has allowed top management to become
divorced from meaningful environmental management,
instead relying on its delivery by an environmental
management function.
The revised standard will require much more of top
management, including:
Understanding the organisations context (in
terms of its environmental risks, opportunities
and stakeholder expectations);
Ensuring that the environmental policy and
objectives are compatible with the strategic
direction of the organisation;
Considering environmental performance in
strategic planning;
These are far more onerous responsibilities for top

management, aimed at encouraging them to be
more involved in environmental management and
supporting environmental management efforts. These
robust criteria provide effective ammunition to auditors
to allow them to test the involvement and support
from top management, which is needed to foster
organisational behaviour change.
Additionally, the new requirements should lead to
greater integration of environmental management
into business processes, and ensure environmental
issues are considered at a strategic level, including in
the context of longer term planning. These measures
should encourage organisations to derive greater
business benefits from improved environmental
performance and crucially help to remove barriers to
environmental improvement by harmonising business
and environmental goals.
How will your organisations top management respond
to these challenges? Consider what they will need to
do to demonstrate to an auditor that they are fulfilling
these obligations. What evidence will auditors need to
verify that environmental performance is considered in
strategic planning or that the EMS is being integrated
into the organisations business processes?
Ensuring the integration of the EMS into the

organisations business processes;
Ensuring adequate resources are available;
Communicating the importance of effective
environmental management;
Ensuring that the environmental management
system achieves its intended outcomes and
promotes continual improvement; and
Directing and supporting staff to contribute to
the effectiveness of the EMS, and supporting
those responsible for environmental
management.
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3.0 HOW TO ADDRESS STRATEGIC ENVIRONMENTAL ISSUES,

THE INTERESTS OF STAKEHOLDERS AND THE DIRECTION
OF THE BUSINESS
ISO 14001:2015 will include new opening clauses
concerning the context of the organisation and
understanding the needs and expectations of
stakeholders. This is an important development, aimed
at ensuring the organisation considers high-level,
strategic drivers when establishing the scope of its
EMS, making its core commitments, and developing its
environmental policy.
The revised edition does both, with requirements for

high level consideration of risk and also operational
environmental aspects evaluation. This is an important
distinction, separating strategic and operational
environmental issues, and ensuring that appropriate
attention is now also given at the strategic level. This
should be undertaken when planning the system and
also periodically, in the same way that operational
environmental aspects are considered.
There is a clear shift in emphasis from the 2004 edition,

in which the only explicit requirement to identify
environmental issues is in the context of identifying
and assessing environmental aspects, after the policy
has been established. In the Annex, it is suggested
that an initial review, including of the environmental
aspects, should be undertaken before developing the
policy, but there is no suggestion that this should be at
a strategic, rather than operational, level.
STRATEGIC LEVEL
Consider
context and
stakeholders
Determine
system scope &
define policy
Review and
improve
Implement
system
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3.0 HOW TO ADDRESS STRATEGIC ENVIRONMENTAL ISSUES,

THE INTERESTS OF STAKEHOLDERS AND THE DIRECTION
OF THE BUSINESS
OPERATIONAL LEVEL
Assess
environmental
aspects
Implement
operational
controls
Review and
improve
Monitor
performance
The new clause for understanding the organisation

and its context requires the determination of internal
and external issues relevant to its purpose and
which may influence the effectiveness of the EMS. It
also specifically refers to the implications of external
environmental conditions, which is a subtle nudge
towards addressing climate change adaptation.
The use of the term purpose of the organisation
is important, in that it directly relates environmental
management to the raison detre of the organisation,
implicitly requiring strategic consideration of anything
environmental that may have a bearing on broader
organisational goals. This fulfils the Future Challenges
recommendation that environmental management be
integrated with business strategy.
The new clause for understanding the needs and
expectations of interested parties, or stakeholders,
simply requires the identification of relevant parties
and their requirements, in relation to the environmental
900002 April 2013
management system. Stakeholder needs and

expectations clearly can vary in significance from
one organisation to another and, rightly, the standard
does not prescribe how or when these needs and
expectations should be evaluated.
The output of both of these evaluations, of context
and stakeholders, should provide an input into the
determination of the scope of the EMS. Additionally,
the environmental policy should also reflect the
direction of the organisation, or its broader strategic
policy.
These new requirements will pose some interesting
challenges for organisations, potentially requiring
a greater degree of consideration of environmental
matters at strategic level. It will be interesting to see
how far external auditors will go to obtain evidence
that these requirements are being fulfilled.

4.0 WHAT COMMITMENTS TO MAKE TO SUSTAINABLE DEVELOPMENT

AND SOCIAL RESPONSIBILITY?
The Future Challenges study recommended that
consideration be given in the revision of ISO 14001
to the content of ISO 26000 Guidance on Social
Responsibility, which considers the environment as
the planet element of the People, Planet and Profit
model. Future Challenges suggests that 14001 should
address the environmental principles in ISO 26000 and
also consider aligning its language.
The four environmental themes considered in
ISO 26000 are:
Prevention of pollution (waste and emissions);
Sustainable resource use (materials, energy and
water consumption);
Climate change and mitigations (GHG); and
Protection of the environment and restoration
of natural habitats (ecosystems, biodiversity,
land and natural resources, urban and rural
development).
Prevention of pollution is already a key principle of
14001, to which a commitment must be made in the
environmental policy. This is retained in the revised
text, but with the additional requirement to support
environmental protection specific to the context of
the organisation, and decide if other commitments
should be made. The use of the term context
refers to the new clauses 4.1 and 4.2, which require
the consideration of the organisations internal
and external issues and stakeholder needs and
expectations.
It also includes the catch-all or other relevant

environmental issues, which, for organisations
involved in agriculture, for example, could be water
scarcity.
Although there is no mandatory requirement to
address these sustainability principles in the policy,
organisations should determine if they would
benefit from doing so, taking account of the broader
business implications. One of the requirements of
top management is to ensure that the environmental
policy is compatible with the strategic direction of the
organisation, and so they should be sufficiently well
informed to decide if commitment is needed to any
specific sustainability principles.
Should specific commitments be made, then the
system needs to provide the tools to fulfil them. The
revised text provides substantially greater drivers for
this, including:
Setting objectives consistent with the policy;
More detailed requirements for external
reporting (compatible with the Global Reporting
Initiative, etc.);
Adopting a life cycle perspective;
Requiring the use of key performance indicators
for measuring progress towards objectives; and
Value chain planning, control and monitoring.
This is not a detailed operational aspects assessment,

but a high level, strategic review, intended to identify
broader risks and opportunities. The outcome will
depend very much on the nature of the organisations
activities, products and services, the value chain and
geographic factors, among others. The revised text
incorporates the three ISO 26000 topics, with some
modifications:
Sustainable resource use;
Climate change mitigation and adaptation; and
Protection of biodiversity and ecosystems.
900002 April 2013

5.0 EXTENDING ENVIRONMENTAL INFLUENCE INTO THE VALUE CHAIN,

WITH IMPLICATIONS FOR PROCUREMENT
The current edition of ISO 14001 recognises the need
to address the impacts of activities, products and
services, but the emphasis is very much on controlling
the organisations own activities. The ISO Future
Challenges report suggests that the need to think
more broadly outside the organisational control box
is implied in the current standard, rather than being
explicit, and it recommends that the revised standard
should:
Address life cycle thinking and the value chain
perspective more clearly in the identification
and evaluation of environmental aspects related
to products and services; and
Include clear requirements/guidance related to
strategic environmental considerations, design
and development, purchasing, marketing and
sales activities.
The working group has made some progress
incorporating these concepts, including a generic
requirement for organisations to consider how they
can control or influence upstream and downstream
processes in the value chain. There are specific
requirements to address environmental issues in
procurement and outsourcing, for:
Evaluating the supply of goods, services and
outsourced processes, taking a lifecycle
perspective;
Specifying environmental requirements as
appropriate for the procurement of goods and
services or outsourced processes;
Communicating requirements to suppliers,
including contractors; and
Monitoring key characteristics of the value
chain.
There is no expectation that organisations would need
to carry out detailed life-cycle assessments.
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The revised text makes it clear that the consideration

of value-chain issues should be related to significant
aspects, and this should be the starting point
for organisations to determine if they do have
opportunities for control or influence in the value
chain. The revised text provides definitions of the
value chain, supply chain and lifecycle (see the Value
Chain/Lifecycle model below), which are helpful in
considering where and how organisations can exert
control or influence.
Generally, organisations have more opportunity to
control, and a greater sphere of influence over the
characteristics and resultant environmental aspects
of materials, products and services that they procure
and ultimately supply, than they do over the activities
of other organisations forming the value chain. The
opportunity to influence other organisations should not
be ignored, but the tools and approaches may be very
different (softer communications and engagement),
from those used for specifying materials.
How will external auditors test the processes applied
to the planning and control of the value chain? The
approach used for assessing the significance of value
chain aspects will be a starting point, but also the
auditors will be interested in how the organisation
determines those significant aspects it can or should
control or influence. As a minimum, this could include
the process by which procurement decisions are
taken, and whether they involve the consideration of
the environmental characteristics of the purchased
materials or services. More advanced approaches
would address the opportunities to influence suppliers,
not only to improve the environmental characteristics
of the materials and services, but also to adopt better
environmental management practices throughout
the organisation. However, it must be recognised
that organisations may have limited opportunities for
influencing the behaviours of suppliers. SMEs may feel
that they have no influence, but even so they do have
the opportunity to decide what they buy and from who.

5.0 EXTENDING ENVIRONMENTAL INFLUENCE INTO THE VALUE CHAIN,

WITH IMPLICATIONS FOR PROCUREMENT
VALUE CHAIN AND LIFE CYCLE
Organisations in Value Chain
Upstream Suppliers, etc,

defined as the
Supply Chain
Our Organisation
Downstream Customers, etc
Life-cycle of a material/product
through the value chain
900002 April 2013

6.0 ENVIRONMENTAL DESIGN AS A TOOL FOR IMPROVEMENT

The latest draft includes short but potentially powerful
statements relating to the design, development and
change of products and services, and the need to
communicate information relating to potential impacts
associated with the use and end-of-life of products,
and the delivery of services. This is in contrast to
ISO 14001:2004, where the first reference to design
is in the single Annex, so addressing environment in
design currently is not a requirement of the standard.
So, although there will be no requirement for

organisations to undertake detailed life-cycle analysis
of all inputs and outputs, there will be an expectation
to identify and assess the significance of key aspects
in the value chain, and to consider how these can
be managed to reduce impacts. It will be up to the
organisation to decide and justify its approach, but
clearly it should be expected that external auditors will
be looking for evidence that:
The revised text introduces requirements for:
Key value chain aspects have been identified

and evaluated;
Identifying the environmental aspects of its

activities, products and services that it
can control and those that it can influence
considering a life cycle perspective; and
Considering the result of the evaluation of
significant environmental aspects as input
in the process of the design, development or
change of its products and services.
The Annex also explains that the organisation
should consider how it will integrate environmental
management system requirements into its various
business functions, such as design & development. It
also makes reference to product, process and facility
design and development.
900002 April 2013
Decisions have been made in relation to

managing them, where feasible, to reduce value
chain impacts;
Mechanisms exist within the organisation to
ensure that design functions consider these key
value chain aspects;
Consideration is given to minimising direct
environmental impacts through considering
process and facility design.
Many organisations already recognise the business
benefits of reducing operating costs through process
and facility design, but the expectation of the revised
text clearly is to extend these drivers into the value
chain, potentially to the benefit of the organisation,
their partners, suppliers, customers and end-users in
the value chain.
10

7.0 DEMONSTRATING ENVIRONMENTAL COMPLIANCE STATUS

The Future Challenges study recognised that, while
it is difficult for organisations to maintain complete
compliance at all times with environmental legislation,
they need to know when they are not, so that they can
plan to restore compliance as soon as possible. This is
not intended as a dilution of the requirement to comply
with legislation; it is a pragmatic acknowledgement
of what can be achieved, as a part of value added,
through the effective application of an EMS. This also
harmonises the ISO 14001 stance with that of many
jurisdictions where the commitment to compliance is
seen as a pledge, rather than a guarantee of perpetual
compliance.
The revised text retains the requirement to identify
applicable legislation and understand the compliance
requirements. However, rather than simply imposing
a requirement of periodically evaluating compliance
with applicable legal requirements, the revised text
stipulates that the organisation must:
Evaluate compliance at pre-determined
frequencies;
The Annex provides more information, explaining that

the evaluation of compliance should not only involve
periodic compliance audits, but also comprises:
Site inspections and observations;
Review of records; and
Comparing the results of monitoring against
regulatory requirements.
So, compliance evaluation is also part of everyday
inspection and monitoring activities. It is important that
the results of these checks are reviewed by competent
individuals, capable of identifying actual or potential
non-compliances and instigating action to remedy
them. This will be nothing new to many organisations
that already have comprehensive compliance
monitoring and evaluation mechanisms in place;
however, the new requirements should encourage
external auditors to review that these processes are
effective in maintaining knowledge and understanding
of compliance status.
Take any necessary action (i.e. to address

non-compliance, actual or potential); and
Maintain knowledge and understanding of its
compliance status.
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11

8.0 USING PERFORMANCE INDICATORS TO TRACK IMPROVEMENT

The Future Challenges study report states that the
objective of ISO 14001 should be the improvement of
environmental performance itself, and argues that the
current text, which implies that this improvement is
achieved only by improving the EMS, is confusing to
the users of the standard. The report recommends:
Clarification of the requirements for improving
environmental performance, and
Strengthening performance evaluation,
potentially through the use of indicators.
The first of those recommendations has not yet been
addressed, with adherents of the traditional stance
successfully arguing for the retention in clause 10.2
Continual improvement of:
The organization shall continually improve the
suitability, adequacy and effectiveness of the
environmental management system to enhance its
environmental performance
The second recommendation has been addressed,

with a specific requirement to establish one or more
indicators for each objective set by the organisation.
Secondly, there is a generic expectation that indicators
will be used for monitoring and measuring performance
against specified criteria (for example discharge
consent limits or energy intensity targets). The Annex
refers to ISO 14031 Environmental management
Environmental performance evaluation, and its
approach to sub-dividing environmental performance
indicators (EPIs) into:
Management performance indicators (MPIs);
Operational performance indicators (OPIs); and
potentially
Environmental condition indicators (ECIs).
The selection of indicators is at the discretion of the
organisation, and can be aligned with any regulatory
requirements, expectations of stakeholders and, as
specified in the revised text, its objectives.
It is to be hoped that the aspirations of Future

Challenges for the emphasis to be on environmental
performance improvement can be incorporated before
the final draft is completed.
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12

9.0 TIMELINE AND MILESTONES FOR THE REVISION PROCESS

9.1 Opportunities for Responding to

Consultation
The current draft (a committee draft, in ISO
terminology) is circulated by ISO to its members
bodies (BSI in the UK). Members of the BSI
environmental management systems committee can
circulate it within the organisations they represent.
Comments from the UK are collated by BSI and
submitted to the ISO secretariat, which in turn collates
comments from all its member bodies globally and
presents these to the working group to consider.
The next meeting of the working group is planned for
the end of June 2013, with the likely output being a
more refined committee draft, which will be circulated
to the same audience, in August/September. This
time, in addition to providing comments on the text,
members (i.e. BSI) are asked to vote for the draft to
progress to the next stage.
In November, the working group will reconvene,
hopefully to prepare a Draft International Standard,
which will be circulated for public comment, probably
in early 2014, with a three-month consultation period.
Again, members vote on proceeding to the final stage,
a Final Draft International Standard.
Again, assuming all goes to plan, the working group

will reconvene in early summer 2014 to address the
latest round of comments and prepare the final draft.
Once this is completed, it is circulated to member
bodies to vote to accept it for publication (members
can submit minor editorial comments at this stage).
Assuming the vote is positive, the secretariat arranges
for the standard to be finalised and translated into
various languages, for publication in January 2015.
9.2 Timescale for Conforming to a Revised

Standard
Typically, ISO allows 18 months for organisations
to meet the requirements of a revised management
systems standard. A longer period may be granted
in this case, owing to the substantial scale of the
proposed changes, but that cannot be guaranteed.
Assuming that the publication target date of January
2015 is achieved, organisations should be prepared to
comply with the new requirements by mid-2016.
ISO 14001 Revision Timescales

Working Group Dates
Feb 2013
Jun 2013
Nov 2013
Jun 2014
Output
Committee Draft 1
Committee Draft 2
Draft International
Standard
Final Draft
International
Standard
Consultees
ISO Members and

their committees
ISO Members and

their committees
ISO Members and

the public
ISO Members
Probable Consultation
Period
Mar-Apr 2013
Aug-Sept 2013
Early 2014
Late Summer 2014
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13

10.0 HOW CAN CRA HELP WITH THE TRANSITION TO ISO 14001:2015?
CRA is in a unique position to provide support to
organisations with the transition from ISO 14001:2004
to ISO 14001:2015. Participating in the ISO working
group carrying out the revision means that we have
insights into the potential direction of future drafts
leading up to 2015. We can also appreciate the
intentions and reasoning behind the changes to the
standard. CRA can help organisations, such as yours,
develop a plan to review and modify their systems to
meet the requirements of ISO 14001:2015.
Gap Analysis
The starting point is to undertake a gap analysis of
existing systems being used by the client, not only
the EMS, but other related business processes, with
which ISO 14001:2015 will expect a greater degree of
integration. Owing to the increased emphasis on higher
level business management, this should also include
processes for strategy development.
Additional Services
CRA can provide support in all aspects of system
redevelopment, but at an early stage clients may wish
to consider:
Briefings to senior management on the
implications of the revised standard; and
Training EMS staff in carrying out detailed
review and system modification tasks.
For Further Information
Nigel Leehane is one of the UKs technical experts
appointed to the ISO working group revising 14001.
Please contact him on 0115 965 6700 or
nleehane@cra.co.uk if you would like to know more
about the changes to ISO 14001 and the implications
for your organisation.
The gap analysis would focus on all the areas of

change set out in the earlier sections of this report.
It would also explore how the new structure (based
on the ISO high level structure for all management
systems) can be accommodated. It is not a
requirement to adopt the new clause numbering
system, provided the new requirements are
incorporated into the organisations system. We can
provide guidance on how these requirements can be
interwoven with an existing management systems
structure.
The output of the gap analysis would include:
Recommendations for addressing the new
requirements of ISO 14001:2015;
Guidance on integrating these and existing
EMS arrangements further into other business
processes;
An appropriate and achievable timeline for
system redevelopment; and
Recommendations for developing and
empowering a system review team.
900002 April 2013
14
APPENDICES


APPENDIX A
The ISO Future Studies report made the following
recommendations for the revision of ISO 14001:
EMS as part of sustainability and social responsibility
Consider inclusion of practical tools to address
sustainability in ISO 14004
EMS and (improvement of) environmental performance
Clarification of the requirements of (improving)
environmental performance in ISO 14001
Strengthen performance evaluation as part of
4.5.1 in ISO 14001 (e.g. use of indicators)
EMS and compliance with legal and other external
requirements
Clearly describe and communicate the
approach/mechanism of achieving legal
compliance in ISO 14001 (e.g. in the Annex)
Address the concept of demonstration of the
commitment to legal compliance
Consider to include the concept of
demonstrating knowledge and understanding of
the organisations compliance status
EMS and overall (strategic) business management
Pay attention to strategic considerations of
environmental management, the benefits and
opportunities of it for organisations, not only in
introduction, but also in the requirements
Strengthen (on a strategic level) the relationship
between environmental management and
the core business of organisations, i.e. its
products and services and the interaction with
stakeholders (including clients and suppliers)
EMS and conformity assessment

Draft clear and unambiguous requirements in
ISO 14001
Provide where necessary clearer guidance
in Annex A (according to its current aim: to
prevent misinterpretation of the requirements)
EMS and the uptake in small organizations
Maintain the applicability of ISO 14001 to
SME, e.g. by drafting/maintaining simple and
understandable requirements
Consider the guidance given in CEN Guide
17 Guidance for writing standards taking
into account micro, small and medium-sized
enterprises (SMEs) needs
EMS and environmental impacts in the value/supply
chain
Address life cycle thinking and the value chain
perspective more clearly in the identification &
evaluation of environmental aspects related to
products and services
Include clear requirements/guidance related
to strategic environmental considerations,
design & development, purchasing, market &
sales activities in alignment with organisational
priorities
EMS and engaging stakeholders
Building upon the (draft) JTCG identical
text introduce a more systematic approach
for identification of, consultation and
communication with stakeholders on
environmental issues
Use the JTCG identical text on context

of the organisation to strengthen link
between environmental management and the
organisations overall strategic considerations
Consider the implications of new (strategic)
business management models for application of
ISO 14001
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16

APPENDIX A
EMS and parallel or sub systems (GHG, energy)
Communicate the broad applicability of
ISO 14001 as well as the advantages of
considering environmental aspects/issues not
separately but in an integrated way and broader
perspective
Consider developing briefing notes on
application of ISO 14001 for specific aspects/
sectors as alternative to development of new
aspect/sector specific standards (e.g. GHG)
EMS and external communication (including product
information)
The future revision of ISO 14001 should
address a requirement to establish an
external communication strategy, including
communication objectives, identifying relevant
interested parties, description of what and
when to communicate
Provide guidance in the Annex on information
related to environmental aspects of products
and services to external interested parties
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17

APPENDIX B
Relationships between the Clauses of ISO 14001:2004 and the March 2013 Revision Draft
CORRESPONDENCE BETWEEN ISO 14001:2004 AND ISO 14001:201X

ISO 14001:201X
ISO 14001:2004
Context of the organization (title only)
Understanding the organization and its

context
4.1
Understanding the needs and

expectations of interested parties
4.2
Determining the scope of the

environmental management system
4.3
4.1
General requirements
Environmental management system
4.4
4.1
Leadership (title only)
Leadership and commitment
5.1
4.4.1
Resources, roles, responsibility and

authority
Policy
5.2
4.2
Environmental policy
Organization roles, responsibilities and

authorities
5.3
4.4.1

authority
Planning (title only)
4.3
Actions to address risks and

opportunities (title only)
6.1
General
6.1.1
Environmental aspects
6.1.2
4.3.1
Legal requirements and voluntary

obligations
6.1.3
4.3.2
Legal and other requirements
Environmental objectives and planning to

achieve them (title only)
6.2
4.3.3
Objectives, targets and programme(s)
Environmental objectives
6.2.1
4.3.3
Environmental improvement programmes
6.2.2
4.3.3
900002 April 2013
18

ISO 14001:201X
ISO 14001:2004
Support (title only)
4.4
Implementation and operation (title only)
Resources
7.1
4.4.1

authority
Competence
7.2
4.4.2
Competence, training and awareness
Awareness
7.3
4.4.2
Communication (title only)
7.4
4.4.3
Communication
General
7.4.1
4.4.3
Communication
Internal communication
7.4.2
4.4.3
Communication
External communication and reporting
7.4.3
4.4.3
Communication
Documented information (title only)
7.5
4.4.4
Documentation
General
7.5.1
4.4.4
Documentation
Creating and updating
7.5.2
4.4.5
Control of documentation
4.5.4
Control of records
Control of documented information
7.5.3
4.4.5
Operation (title only)
4.4
Operational planning and control
8.1
4.4.6
Operational control
Value chain planning and control
8.2
4.4.6
Operational control
Emergency preparedness and response
8.3
4.4.7
Performance evaluation (title only)
4.5
Checking (title only)
Monitoring, measurement, analysis and

evaluation (title only)
9.1
4.5.1
Monitoring and measurement
General
9.1.1
4.5.1
Evaluation of compliance
9.1.2
4.5.2
Internal audit
9.2
4.5.5
Internal audit
Management review
9.3
4.6
Management review
Improvement (title only)
10
Nonconformity and corrective action
10.1
4.5.3
Nonconformity, corrective action and

preventive action
Continual improvement
10.2
4.1
900002 April 2013
19

APPENDIX B
CORRESPONDENCE BETWEEN ISO 14001:2004 AND ISO 14001:201X

ISO 14001:2014

requirements (title only)
Environmental policy
ISO 14001:201X
4
Context of the organization (title only)
4.1
Understanding the organization and its

context
4.2
Understanding the needs and

expectations of interested parties
4.3
Determining the scope of the

environmental management system
4.4
10.2
Continual improvement
5.2
Policy
6.1
Actions to address risks and

opportunities (title only)
6.1.1
General
4.1
4.2
4.3
4.3.1
6.1.2
Legal and other requirements
4.3.2
6.1.3
Legal requirements and voluntary

obligations
6.2
Environmental objectives and planning to

achieve them (title only)
6.2.1
Environmental objectives
6.2.2
Environmental improvement programmes
Support (title only)
Operation (title only)
900002 April 2013
4.3.3
4.4
20

ISO 14001:2004

authority
Communication
Documentation
Operational control
ISO 14001:201X
4.4.1
4.4.2
4.4.3
4.4.4
4.4.5
4.4.6
7.1
Resources
5.3
Organization roles, responsibilities and

authorities
5.1
Leadership and commitment
7.2
Competence
7.3
Awareness
7.4
Communication (title only)
7.4.1
General
7.4.2
Internal communication
7.4.3
External communication and reporting
7.5
Documented information (title only)
7.5.1
General
7.5.2
Creating and updating
7.5.3
8.1
Operational planning and control
8.2
Value chain planning and control
4.4.7
8.3
Checking (title only)
4.5
Performance evaluation (title only)
9.1
Monitoring, measurement, analysis and

evaluation (title only)
9.1.1
General
4.5.1
4.5.2
9.1.2
Nonconformity, corrective action and

preventive action
4.5.3
10.1
Nonconformity and corrective action
Control of records
4.5.4
7.5.3
Internal audit
4.5.5
9.2
Internal audit
Management review
4.6
9.3
Management review
900002 April 2013
21
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Synergy House, Unit 1, Calverton Business Park,
Hoyle Road, Calverton, Nottingham, UK NG14 6QL
T: +44 (0) 115 965 6700
E: info@cra.co.uk
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REVISION OF ISO 14001

Key Changes Proposed in the March 2013 Draft

Bringing sustainability and safety to the

Revision of ISO 14001

How to Address Strategic Environmental Issues, the Interests of

What commitments to make to sustainable development and

Extending environmental influence into the value chain, with

Environmental Design as a Tool for Improvement

Demonstrating Environmental Compliance Status

Using performance indicators to track improvement

Timeline and Milestones for the Revision Process

Opportunities for Responding to Consultation

How can CRA help with the transition to ISO 14001:2015?

Future Challenges Recommendations

Relationships between the Clauses of ISO 14001:2004 and

900002 April 2013

Revision of ISO 14001

Some of these new requirements are addressed by

1. Greater expectation for top management to

The anticipated timescales and key milestones in the

2. Broader strategic consideration of the

1.2 Where can you find out more?

3. Making specific commitments to sustainable

CRA will be publishing briefings throughout the revision

7. Using performance indicators to track

900002 April 2013

Revision of ISO 14001

2.0 GREATER EXPECTATIONS FOR TOP MANAGEMENTS LEADERSHIP

These are far more onerous responsibilities for top

Ensuring the integration of the EMS into the

900002 April 2013

Revision of ISO 14001

3.0 HOW TO ADDRESS STRATEGIC ENVIRONMENTAL ISSUES,

The revised edition does both, with requirements for

There is a clear shift in emphasis from the 2004 edition,

900002 April 2013

Revision of ISO 14001

3.0 HOW TO ADDRESS STRATEGIC ENVIRONMENTAL ISSUES,

The new clause for understanding the organisation

management system. Stakeholder needs and

Revision of ISO 14001

4.0 WHAT COMMITMENTS TO MAKE TO SUSTAINABLE DEVELOPMENT

It also includes the catch-all or other relevant

This is not a detailed operational aspects assessment,

Revision of ISO 14001

5.0 EXTENDING ENVIRONMENTAL INFLUENCE INTO THE VALUE CHAIN,

900002 April 2013

The revised text makes it clear that the consideration

Revision of ISO 14001

5.0 EXTENDING ENVIRONMENTAL INFLUENCE INTO THE VALUE CHAIN,

Upstream Suppliers, etc,

Downstream Customers, etc

900002 April 2013

Revision of ISO 14001

6.0 ENVIRONMENTAL DESIGN AS A TOOL FOR IMPROVEMENT

So, although there will be no requirement for

The revised text introduces requirements for:

Key value chain aspects have been identified

Identifying the environmental aspects of its

900002 April 2013

Decisions have been made in relation to

Revision of ISO 14001

7.0 DEMONSTRATING ENVIRONMENTAL COMPLIANCE STATUS