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A New Environment?
A detailed briefing note on the revision of ISO 14001:1996 to ISO DIS 14001:2003,
prepared for LRQA customers by Dr Anne-Marie Warris, LRQA Global Product
Manager EMS, and UK expert to ISO 14001 revision.

Introduction
LRQA customers who have an Environmental Management System certified to ISO
14001:1996 will be aware that this standard is being currently revised and will be
replaced by ISO 14001:2004 at the end of 2004.

The Draft International Standard (DIS) 14001:2003 has been published and the
international standard writers will meet in March 2004 to review and finalise the
standard to FDIS (Final Draft International Standard) status. A final ballot will be
held and any comments submitted by standardisation body members will be
reviewed at the same meeting. Publication of the standard is expected to be towards
the end of the year.

In the meantime, as part of LRQA’s promise to keep its customers informed of

developments that will affect them, this briefing note considers the changes that are
expected and what action will be required by an organisation with an accredited
certified ISO 14001 system.

LRQA will continue to provide guidance when the Standard is published as the
FDIS version.

Overview
The DIS features clarification of requirements, alignment with ISO 9001 and changes
to the text to make the standard more user friendly. Some changes are likely to
require organisations to review and perhaps amend their system to ensure
conformance with the final version of the new standard.

The changes to the standard are detailed below. They cover:

• Scope
• Policy
• Environmental Aspects Identification
• Legal and Other Requirements
• Resources, roles, responsibility and authority
• Competence Training and Awareness
• Communication
• Environmental Management System Documentation
• Document Control

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 • Emergency Preparedness and Response
• Evaluation of Legal Compliance
• Non conformance, Corrective and Preventive action
• Other minor changes.

For clarity each change is referred to by its relevant paragraph number in ISO
14001:1996 and includes recommendations for action.

One noticeable change has been that documented procedures are no longer required,
except for procedures required under the clause relating to operational control.
However, organisations still need to ‘establish and maintain’ procedures to
implement and manage their EMS.

Scope – clause 4.1

An organisation is now required to define the scope of its EMS. This scope directly
links the management system with the organisation’s activities, products and
services. The words ‘and determine how it fulfils these requirements’ related to
requirements in ISO 14001 have been added to the clause 4.1.

You need to do two things. Firstly define the scope of your EMS, including what
activities, operations, services and products are included within it. This needs to be
documented possibly in the environmental policy. Secondly you need to evaluate
and document how your EMS fulfils the requirements of ISO 14001. This could be
done as part of the internal audit or as part of management review, as long as it is
traceable. Please note just stating that your internal audit cycle covers all
requirements may in many cases not be sufficient, unless it demonstrates how you
meet them.

Definitions
There are changes to several of the definitions which impact on an organisation’s
system, these are highlighted below.

Auditor – This definition is new and is taken from ISO 9001:2000 and links to the
concept of competence of auditors. You will need to demonstrate that your auditors
are competent. Most LRQA customers already do so but you are recommended to
check that auditor competence is defined in your system.

Continual Improvement - Slight changes remind users that the process is ‘recurring’.
For most organisations this is already clear but you are recommended to ensure that
your continual improvement process is not a one off approach.

Environmental Management System Audit - Changes to the wording underline the fact
that audits must be independent and switches the emphasis of the audit scope from
determination of conformance of the EMS to determination of conformance with the
environmental management system audit criteria. You therefore need to be sure that
your audit criteria are defined and clear. Since internal audits already require

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determination of audit criteria and lay down what needs to be audited, this should
not be a major issue.

Environmental Performance - The focus has changed from the management system to
an organisation’s management of its environmental aspects. The effect will depend
on what you use to demonstrate environmental performance improvement. You are
recommended to check the processes that you use to ensure they are in accordance
with the clarified definition.

Prevention of Pollution - The wording has been clarified to reflect methods and
options for the prevention of pollution. More options are now listed and the
definition of pollution includes ‘creation, emissions and discharge of any type of
pollutant’. You need to look at your definition of prevention of pollution, and its
scope, to ensure it covers the new concepts. This applies specifically if you have
paraphrased prevention of pollution rather than used the term itself in your policy
and other documents.

Policy – clause 4.2

An organisation’s environmental policy has to be consistent with the scope of its
EMS and its scope can not be wider than the actual scope of the EMS. This allows
interested parties asking for the environmental policy to gain information about the
scope of the EMS and to learn what is and what is not covered in the organisation’s
management system.

Several changes now require an organisation to review its environmental policy. You
need to do this to ensure that your policy:
• is developed by top management
• covers the scope of your EMS and does not imply a wider scope than that
• covers all activity, products and services within the scope of your EMS
• notes change to terminology related to legislative and regulatory
requirements
• reflects other environmental requirements your organisation may have
subscribed to
• is distributed to everyone working for, or on behalf of, the organisation, such
as sub-contractors, contractors, temporary staff, and remote workers.

Environmental Aspects Identification - clause 4.3.1

The famous (or infamous) ‘or’ has been removed and changed to ‘and’, but within
the scope of the organisation’s EMS. The requirement has been clarified as to which
aspects an organisation can influence. Also as a result of other changes to clauses,
aspects associated with projects now forms part of this clause of the standard.

A number of text changes mean that aspect identification now covers all activities,
products and services within the scope of the organisation’s EMS. It also separates
control and influence, and introduces planned and new developments, new and
modified activities, products and services. Significant aspects will now be considered

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in the development, implementation and maintenance of the EMS. There is also a
reminder to document this information.

The wording regarding influence has changed from ‘… over which it can be
expected to have an influence’ to ‘… those which it can influence’. You now need to
identify aspects which your organisation can influence rather than those over which
it can be expected to have an influence.

You need to review your procedure for identifying environmental aspects to ensure
that it covers all activities, products and services within your defined EMS scope.
Also that it covers aspects that you can control and influence and that it covers
changes, new and planned developments, new and modified activities, products and
services.

You also need to make sure that the significant aspects derived from the revised
procedure are considered in developing, implementing and maintaining your EMS.
Please note that there is now a stipulation that aspects ‘information’ is documented.
This was part of the overall concept in the ‘Records’ clause in ISO 14001:1996 edition
just not so clearly. Most LRQA customers have documented aspects but you need to
be aware that some kind of aspects documentation must be demonstrable.

Legal and Other Requirements – clause 4.3.2

The first point to note is the general change from the confusing usage of legislative,
regulatory and legal requirements to ‘environmental legal requirements’. The word
‘legislative’ is changed to ‘legal’. This differentiates between ‘legislative’, which
refers to a law passed by parliament, and ‘legal’ which is much broader and covers
regulatory, court decisions and others. This does not mean that because a piece of
legislation is not in the Environmental Protection Act it is not relevant to the EMS.
For example, Control of Major Accidents and Hazards (COMAH in the UK, Seveso
in EU) is an environmental legal requirement where it is applicable to a site.

Organisations need to have procedure(s) to determine how environmental legal

requirements and other environmental requirements to which the organisation
subscribes apply to the organisation’s environmental aspects. You must consider
such requirements in developing, implementing and maintaining the EMS.
Therefore, you need to look at your overall EMS and ensure that it reflects its
environmental legal requirements and other environmental requirements.

Resources, roles, responsibility and authority- clause 4.4.1

The new title emphasises the importance of resources, roles and authority as well as
responsibility. Paragraphs have been reorganised and the replacement of the word
‘provide’ with ‘ensure the availability’ could be significant for organisations
experiencing high staff turnover, particularly where this involves the loss of
‘provided’ auditors. You will be expected to have contingency plans in place to
ensure that alternative auditors are available - for example, a consultant, sub-
contractor or an auditor from an affiliated organisation.

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Competence, Training and Awareness - clause 4.4.2
A new term has come into use: ‘persons working for, or on behalf of, the
organisation’. This is broader than just employees – or the old ‘members’ – and care
needs to be taken to ensure that all relevant persons have been covered, for example,
in terms of competence.

A new title reflects a change in the order of paragraphs and highlights the order of
importance of these subjects. Competence now extends in two directions: firstly to
‘potential significant impacts’ and secondly to cover persons working for, or on
behalf of, the organisation.

You need to make sure that your competence evaluation covers all persons working
for, or on behalf of, the organisation, such as sub-contractors, contractors, temporary
staff and remote workers, and that significant impact also covers potential impacts.

The new first paragraph now allows organisations with established training needs to
provide the training themselves or take other action such as recruiting or sub-
contracting.

Communication – clause 4.4.3

The changes clarify what organisations need to do if they decide to communicate
externally about their environmental aspects. This will affect your management
system only if you decide to communicate in this way – in which case you need to
establish methods for communication.

Environmental Management System Documentation - clause 4.4.4

The title has been changed to ‘Documentation’ to reflect the fact that the
requirements are now in common with ISO 9001:2000 and the list of required
documents and records has been extended. As an LRQA customer, your
management system probably already covers this but you should confirm that you
have identified all documents and records necessary to ensure effective planning,
operation and control of processes related to your significant environmental aspects.

Document Control – clause 4.4.5

The title has been changed to be in line with ISO 9001:2000 and the wording has
been changed completely to reflect ISO 9001:2000. However, in reality the changes
are minimal. The key relevancies relate to external documents and the need to
identify changes to documents issued by the organisation. Other changes are in the
wording rather than in practice.

This means you need to review your document control procedure and update its
wording to comply with the DIS wording. Implementation and operation of the
management system is not likely to be affected. However, you do need to identify
distribution control for documents of external origin such as legal requirements,
licences to operate and other environmental requirements to which your
organisation subscribes. You should also ensure that you can identify the changes in

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versions of documents issued by the organisation by tracking changes, revision
index and so on.

Emergency Preparedness and Response - clause 4.4.7

The 1996 text has been refocused and a bullet list provided. You should check that
your existing emergency and accident procedure covers ‘identification of potential
emergency situations and potential accidents that can have (an) impact(s) on the
environment, and how it will respond to them’; and decide how you wish to
respond to actual emergency situations and accidents and prevent or mitigate
associated environmental impacts.

Evaluation of Legal Compliance – new clause 4.5.2

The most obvious change in ISO DIS 14001:2003 has been to bring the last paragraph
4.5.1 into a separate clause to highlight the importance of periodic evaluation of legal
compliance. In addition, the text has been amended to cover compliance evaluation
of environmental legal requirements and other environmental requirements to
which your organisation subscribes. The ‘record’ clause (4.5.4 in DIS) now links the
need for results of this periodic evaluation to be recorded.

The rationale for the evaluation of legal compliance has been defined as being
required ‘to meet the organisation’s commitment to compliance…’. You will need to
amend your procedure for evaluation of environmental legal compliance to include
other environmental requirements to which your organisation subscribes. You will
also need to ensure that evaluations carried out include ‘other environmental
requirements’.

Non Conformance, corrective and preventive action – now clause 4.5.3

This section has benefited from clarification. There are two clear cases of preventive
action – one to prevent re-occurrence and one to prevent potential non-conformities.

You need to look at your current procedure and implementation of this clause to
ensure it meets the clarified requirements.

Additionally the concept of potential nonconformity has been brought to the

forefront. It was already in the 1996 edition but its focus is much clearer in this DIS
version. This may require you to look again at your process to ensure that it
determines ‘action to eliminate the causes of potential nonconformities to prevent
their occurrence’.

Other changes
Records – now clause 4.5.4
The order of the wording has been changed. ‘Records’ now has a catch-all statement
to say an organisation needs records to demonstrate its implementation of
procedures and results achieved. You will need to look at the records you have
identified to support your EMS and this International Standard and ensure they
demonstrate compliance to the EMS, procedures and results. Records include – but

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are not limited to – evaluation of compliance records. Recorded retention times are
no longer required, although record retention still has to be specified.

Environmental Management System Audit – now clause 4.5.5

The title has been changed to align with ISO 9001:2000, although the main part of
the requirements remains largely unchanged. The changes mean that you are
recommended to check that your audit procedures comply with the requirements,
that your audit process delivers the requirements and that your audit and auditors
are impartial and objective.

You should also ensure that your audit programme is ‘maintained’ by ensuring that
the programme is updated if audits slip or are rescheduled. Please note your new
responsibility for ‘planning’ audits – this must be addressed in the audit procedure.

Management Review- clause 4.6

As with previous clauses, the wording has been aligned with ISO 9001:2000 and
provides a more detailed checklist for inputs and outputs from the management
review. Management reviews are to be conducted at ‘planned intervals’ rather than
‘intervals it determines’ and new additions for management review include
opportunities for improvement and targets – not just objectives.

Therefore, you should ensure your current management review process covers the
inputs and outputs provided for in the requirements and ensure that additional
inputs and outputs critical to the operation of your EMS are also covered. Also be
aware of the need to document more explicitly decisions and actions arising from the
management review.

Conclusion
There have been many comments and debates about the forthcoming revision to ISO
14001 and despite press reports that predict ‘business as usual’, organisations must
be aware that changes will be required to their management system in order to
ensure conformance with the new standard.

This briefing note sets out those changes and how they are likely to affect LRQA
customers and their Environmental Management Systems. Please send any enquires
to enquires@lrqa.com.

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