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Implementation checklist for ISO 14001:2015 transition


Companies that implemented the 2004 version of ISO 14001 must make the transition to the 2015 version by September 2018. The new version
of the standard brings a lot of changes, and all of them need to be identified and understood before the transition project can begin. For more
information about the changes, see: Infographic: ISO 14001:2015 vs. 2004 revision What has changed?

Identifying changes is only the beginning; all of them need to be translated into a series of tasks and activities to be completed in order to
achieve full compliance with ISO 14001:2015 (see also: 12 steps to make the transition from ISO 14001:2004 to 2015 revision). Keeping an eye
on what is done and what steps are ahead is crucial for the success of such projects therefore, we hope youll find this checklist useful.

What needs to be done? Completed Note


1) Define context of the organization
Determine how to identify internal and Determining context of the organization requires identifying all internal and
external issues. external issues relevant to the EMS. Depending on size and complexity of the
organization, you will need to decide who will be involved and how often the
context shall be examined. For more information, see: Determining the context
of the organization in ISO 14001.
Make a decision about documenting the Considering that this is a new requirement, it can be beneficial to document the
requirement. Procedure for Determining Context of the Organization and Interested Parties,

which will define those elements of the context to be analyzed, who will take part
in it, and how often the review will be conducted.
Identify internal and external issues. The organization needs to determine internal and external issues that can affect
the ability of the company to achieve its objectives; this can include the condition

of the environment, environmental legislation, and customer requirements
regarding environmental protection.
2) List all interested parties
Identify interested parties relevant to the Interested parties can have a great impact on the organization, and it is

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EMS. important to determine who the interested parties are, as well as their needs and
expectations regarding the organizations EMS.
Determine relevant needs and expectations Interested parties can have different requirements regarding different aspects of
of the interested parties. the company. In regards to ISO 14001, it is important only to identify needs and
expectations that relate to the Environmental Management System.
Decide which of these needs and Interested parties and their needs and expectations that the organization
expectations will become compliance determines to be relevant to its EMS become compliance obligations, which the
obligations for the organization. organization must fulfill. These usually include environmental legislation and
requirements of the customers. For more information about interested parties,
see: How to determine interested parties according to ISO 14001:2015.
Make a decision about documenting The organization must monitor and review information about the interested
interested parties and their needs and parties and their relevant requirements. This is usually done by documenting a

expectations. List of Interested Parties, Legal and Other Requirements and additionally, the
organization can document the procedure that will describe the process in detail.
3) Review the scope of EMS
Determine whether the changes in the If the organization implemented the previous version of the standard several
company locations, processes, and products years ago, it is possible that the document about the scope of the EMS has not
are reflected in the scope of the EMS. been revised since, and the company opened new branches, developed new
products, or introduced new technologies. The transition is a good chance to
review the scope and adapt it to the organizations current needs. For more
information, see: How to determine the scope of the EMS according to ISO
14001:2015.
Revise the document about the scope if If there were any changes to the scope of the EMS, they need to be documented.
necessary. The scope is usually documented in the EMS Manual, or in a separate document

called the Scope of the Environmental Management System defining all activities,
products, and services of the organization within the scope.
4) Leadership and review of the Environmental Policy
The top management demonstrates Getting the top management involved in the EMS is one of the biggest challenges

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commitment and leadership by taking in the implementation and maintenance of the system. If the top management is
accountability for EMS effectiveness. familiar with the benefits of ISO 14001 and knows what their responsibilities are,
they are more willing to actively participate and commit to the EMS. For more
information, see: What are the responsibilities of top management in the EMS
according to ISO 14001:2015?
The EMS is integrated into the organizations The only way to ensure that the EMS is really implemented and applied is to
business processes. integrate its activities with everyday business activities. The transition is a great

opportunity to review existing EMS activities and see how to make them more
simple and natural to the employees to ensure they are performed as defined.
Resources needed for EMS functioning are The biggest problem with requirements regarding the leadership is that they
available. cannot be met by simply writing the policy or procedure; they must be met by
taking actions. The top management must provide sufficient resources in terms
of human and financial resources for the operational controls that require them
in order to ensure the effectiveness of the EMS.
Top management supports persons to One of the most important roles of the top management in the EMS is to raise
contribute to the EMS and promotes awareness and demonstrate to its employees that the EMS is important for the
continual improvement. company. If the top management doesnt care about the EMS, neither will the
employees. The top management must also support relevant management roles
to demonstrate leadership in their areas of responsibility.
The Environmental Policy is appropriate to The existing Environmental Policy needs to be updated to reflect the purpose and
the purpose and context of the organization context of the organization and to provide a framework for setting the

and provides a framework for setting EMS Environmental Objectives.
objectives.
The Environmental Policy includes a Requirements regarding the Environmental Policy havent changed significantly,
commitment to the protection of the but the policy must be reviewed to ensure it contains a commitment to the
environment, including prevention of prevention of pollution, commitment to fulfillment of compliance obligations and
pollution, fulfillment of compliance continual improvement. For more information about the policy, see: How to
obligations, and continual improvement. write an ISO 14001 environmental policy.

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The Environmental Policy is documented, Once the policy is documented or the new version is published, it must be
communicated, and available to interested communicated within the company so that the employees are aware of it, and it
parties. must be made available to interested parties. Making the policy available to
interested parties includes publishing it on the companys website or providing it
to the interested party by request.
5) Align EMS objectives with the companys strategy
EMS objectives are established at relevant The top management should be involved in defining environmental objectives.
functions and levels, taking into The objectives should take into consideration the significant environmental
consideration significant environmental aspects, compliance obligations, and risk and opportunities in order to be

aspects, compliance obligations, and risks appropriate to the company and realistic. They should be defined at appropriate
and opportunities. levels and functions in the company. For more information, see: Ensuring that
environmental objectives are aligned with the companys strategic direction.
EMS objectives are consistent with the In order to contribute to the improvement of the EMS, the objectives need to be
Environmental Policy and the S.M.A.R.T. aligned with the policy. They also need to be specific, measurable, achievable,
principle. realistic, and timed in order to enable the organization to evaluate whether they
are achieved. For more information about the objectives, see: How to Use Good
Environmental Objectives.
Actions to achieve the objectives are defined Once the objectives are defined, the organization must define actions to ensure
and the objectives are documented. that the objectives will be achieved. Planning actions includes defining what will
be done, who will do it, what resources are needed, and what the deadlines are.
Plans for achieving the objectives are often documented in the record
Environmental Objectives and Plans for Achieving Them.
6) Assess risks and opportunities
Make a decision on the methodology for The organization needs to determine risks and opportunities related to
identification of risks and opportunities. environmental aspects, compliance obligations, and context of the organization.
The standard doesnt require the organization to adopt a methodology for risk
assessment; however, it can be beneficial for bigger companies with more
complex products, services, or processes. For more information about risks and

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opportunities, see: Risks and opportunities in ISO 14001:2015 What they are
and why they are important.
Identify risks and opportunities. Identification of risks and opportunities is not the same as identification of
environmental aspects. The risks and opportunities should be observed on an
organizational level of the company and its processes. The key is to determine
what can jeopardize or enhance the environmental performance regarding
environmental aspects, compliance obligations, or context of the organization.
For more information, see: ISO 14001 risks and opportunities vs. environmental
aspects.
Take actions to address risks and The organization needs to take actions to address risks and opportunities in order
opportunities. to provide assurance that the EMS will deliver the intended results, prevent or

reduce undesired effects, and continually improve the EMS. The actions should
be integrated with EMS processes and evaluated for their effectiveness.
Make a decision on documenting risks and The organization needs to document risks and opportunities to be addressed and
opportunities. information about the process of identifying and addressing them. Depending on
the methodology the company selected, different levels of documented

information will be required. For small and mid-size organizations, it can be
merged with the Procedure for Identification and Evaluation of Environmental
Aspects and Risks.
7) Identify and evaluate environmental aspects
Review existing methodology for If the standard was implemented a long time ago, the transition can be a good
identification and evaluation of chance to review the existing methodology for identification and evaluation of
environmental aspects. environmental aspects and see if it can be improved. Adopting a new

methodology can help the organization to decrease the amount of
documentation and create a more efficient process. For more information, see: 4
steps in identification and evaluation of environmental aspects.
Examine lifecycles of products and services The organization must examine the lifecycles of its products and services,

and identify environmental aspects in each determine environmental aspects, and define operational controls considering

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phase of the cycle. the influence the company has at different lifecycle stages. For more information,
see: Lifecycle perspective in ISO 14001:2015 What does it mean?
Document environmental aspects and The organization is required to document criteria for determining significant
associated impacts, criteria for determining aspects, and this is done with the Procedure for Identification and Evaluation of
significant environmental aspects, and Environmental Aspects and Risks. Significant environmental aspects and the
significant environmental aspects. aspect evaluation are usually recorded in a document like this Process Aspects
Chart.
8) Determine compliance obligations
Determine and provide access to relevant Identification of compliance obligations can be done as a part of identifying
compliance obligations. interested parties and their needs and expectations, whereas the interested
party will be the legislative authority, and needs and expectations will be
compliance obligations. The organization also must provide access to the relevant
compliance obligations, and this can be done by providing links to the relevant
people of the relevant legislation. To find out more about legal requirements,
see: Demystification of legal requirements in ISO 14001.
Determine how these compliance obligations As a part of determining compliance obligations, the organization will also have
apply to the organization. to determine how these obligations apply to the organization and what processes

and elements of the EMS must be updated to be aligned with the obligations. For
more information, see: How to achieve regulatory compliance in ISO 14001.
Document the compliance obligations. The organization needs to maintain documented information on its compliance
obligations, and the easiest way to do it is through a List of Interested Parties,
Legal and Other Requirements.
9) Control documented information
Identify all requirements for documents and With the change of the standard came the change in documentation
records. requirements. Most of the existing documentation can still be used in the EMS,
but it is important to identify the documents that are not mandatory anymore
and to make a decision on whether to keep them as a part of your EMS. At the
same time, there are some new documentation requirements, and they also

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need to be taken into account when making the transition. For more information
about documentation requirements, see: List of mandatory documents required
by ISO 14001:2015.
Revise and update the existing document and The new version of the standard has more precise requirements regarding
record control process. document and record control. It defines requirements for creating and updating
documents, and the retention and disposition of the documents. The existing

document and record control process needs to be reviewed to determine
whether it is compliant with the new version of the standard. For more
information, see: A new approach to documented information in ISO 14001:2015.
Revise and update existing EMS All documentation must be updated; some of it will require comprehensive
documentation. changes, but others will only need a change in reference to the clause of the
standard. Regardless of the level of changes required, it is also beneficial to
review all documents and discard redundant parts of the documentation.
Download a free preview of the ISO 14001:2015 Transition Toolkit to gain some
perspective on the amount of changes needed on the existing EMS
documentation.
10) Operational control
Review and update existing operational The organization needs to review existing operational controls to determine
controls. whether they are aligned with the new requirements of the standard, and update
them accordingly. Also, if a new methodology for identification and evaluation of

environmental aspects is adopted, and new significant aspects emerge, the
company needs to establish controls for those aspects. For more information,
see: Defining and implementing operational control in ISO 14001:2015.
Control or influence outsourced processes. Outsourced processes also need to be under control. Depending on the
relationships with the suppliers or subcontractors, the type and extent of the
controls may vary, but they must be established.
Establish operational controls consistent with The organization must establish operational controls at appropriate stages of the

the lifecycle perspective. lifecycle to prevent or reduce environmental impact. In some stages, the

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company has the full control, but when the product reaches the customer, the
control is significantly reduced. In any case, the company has to do its best to
decrease the impact on the environment. For more information, see: Defining
and implementing operational control in ISO 14001:2015.
Communicate relevant environmental Once the company has established the control of outsourced processes,
requirements to suppliers and contractors. products, and services, it needs to communicate its requirements to suppliers
and contractors to make sure they are received and understood. This can be
done by contract, training, or awareness-raising sessions for suppliers and
contractors.
Make a decision on documenting operational Documenting operational controls can be done in different ways: the company
controls. can either document the Procedure for Operational Control of Significant

Environmental Aspects, or amend the process procedures with requirements for
operational controls.
11) Environmental performance
Establish Key Performance Indicators (KPIs) The company needs to monitor, measure, analyze, and evaluate its
for the EMS. environmental performance. To do so, the company must determine the Key
Performance Indicators that will show the condition of the EMS and point out the
weaknesses of the system. For more information, see: How to define EMS key
performance indicators (KPIs) according to ISO 14001.
Determine methods for monitoring and When the KPIs are defined, the company must determine how those KPIs will be
measuring. monitored, measured, and evaluated. For more information, see: Environmental
performance evaluation.
Monitor the KPIs. As part of monitoring and measuring, the company must determine their
frequency. The results of monitoring and measuring of the KPIs are important
inputs for later management review and improvement of the EMS. For more
information, see: 5 Tips to improve your environmental management system
performance.
12) Measuring and reporting

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Conduct an internal audit. The internal audit process will be the same as it was in the previous version of the
standard, but the requirements to be audited will be different. The standard
doesnt require internal auditors to get additional certificates for ISO 14001:2015,

but it can be beneficial for internal auditors to take an ISO 14001:2015 Internal
Auditor Course to become familiar with the standard and refresh their knowledge
on auditing.
Conduct the management review. The management review process will stay the same; the only difference is that
the inputs and outputs of the management review have changed. There are now
additional requirements for reviewing context of the organization, as well as the
effectiveness of actions taken to address risks and opportunities, define
opportunities for improvement, and improve integration of the EMS with other
business processes. For more information on management review, see: The
importance of management review in the ISO 14001:2015 process.
Conduct corrective actions. In case of nonconformities during the internal audit, or if the management review
resulted in opportunities for improvement, the corrective actions need to be
initiated and conducted to achieve full compliance with the standard and
improve the EMS. For more information, see: How to proceed once a corrective
action is initiated in the EMS.

Sample documentation
You can download an ISO 14001:2015 Transition Documentation Toolkit. This will allow you to see a sample of the policies and procedures
required to make the transition to the ISO 14001:2015 standard and see what changes should be made to your existing documentation.

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