ISO 14001:2015

Comparison and Guidance Matrix

© URS 2015 Page 1 of 28

 Contents

1.Introduction Page 3
2.Terminology Pages 2-5
3.URS Expectations Page 5
4.URS Strategy For Certification Transition Page 6-9
5.Comparison and Guidance Matrix Pages 10-28

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 1. Introduction

This ISO 14001:2015 Comparison and Guidance Matrix has been written with the aim to assist clients and auditors to understand the URS
approach and interpretation of the revised standard.

Of course there will be minor differences in interpretation between Certification Bodies but URS needs to have a common approach so
that clients can have confidence in our auditors and how they should interpret the standard.

This document is not a prescriptive one because client systems have to be developed to suit their own needs but if the requirements are
fulfilled in whatever way the client chooses, then certification will be recommended. In this document we simply interpret the standard so
that those who do not fully understand the language used by the standard, have some guidance in how to implement the requirements.

2. Terminology

Much of the terminology in the 14001 is the same as ISO 9001 but one that is new is life cycle which is defined as ‘consecutive and
interlinked stages of a product (or service) system from raw material acquisition or generation from natural resources to final disposal.’

Throughout the standard, there are some words and phrases that can cause confusion or are difficult to understand. The following
interpretations are URS’ interpretations but are hopefully useful in understanding what the standard requires.

A. Documented Information

A.1 There are many references to Documented Information throughout the standard. Where the standard states that Documented
Information shall be established and maintained then:

A.1.1 Means that a description of an activity (process) needs to be documented. It also needs to be maintained (document
control) to ensure it is up to date.

A.1.2 The format of the description of a process is entirely up to the client but should contain sufficient information to provide
enough guidance to (i) satisfy the requirements of the standard and (ii) ensure the effective implementation of the activity.

A.2 There are also reference to documented information being retained. This means that records are to be kept to provide evidence
that activities were performed (correctly or incorrectly).

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 B. Determine

B.1 There are many references to Determine Information throughout the standard. Where the standard states Determine information,
then:

B.1.1 This means that the client has to understand something and provide ‘documented information’ of their understanding. For
example, the standard requires that the client ‘determines’ the processes needed for the environmental management system and
their application …. This means that the client has to identify all the processes within the EMS and provide some form of
documented ‘overview’ of this. This could be in the form of a process map. The need for, and the content of the documented
description of each process needs to be decided by the client and to help make that decision, rather than the client just
documenting everything, there is a process that the client goes through to make the decision ‘Do we need to produce a
‘documented’ process? If yes, how much detail should there be?

C. Issues

C.1 There are many references to Issues throughout the standard. Where the standard states issues, then:

C.1.1 This means ‘an actual or potential threat’ to the effective implementation and control of one or more activities or an
actual or potential threat to the client’s ability to manage an EMS that meets the requirements of the standard and any regulatory
and statutory requirements.

D. Understanding the organisation and its context

D.1 There are references to Understanding the Organisation and its Context in the standard. Where the standard states
Understanding the Organisation and its Context, then:

D.1.1. The client demonstrates compliance to this clause (4.1), in a number of ways.

 Firstly, if the client produces an organisation chart or similar which show the functions and lines of reporting – step 1.
 A process map (see Determine above) would demonstrate an understanding of the processes (core business and
management support) and their interactions – step 2

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  In addition, if the client conducts a risk assessment, it will clearly show a true understanding of their processes and
threats/opportunities – step 3. (Aspects table could be structured to show interested parties with scores for effect on
employees (health and safety related, company concerns e.g. pollution incidents that affect image environmental
reporting) community concerns (nuisance related usually e.g. litter noise bright lights at night)

E. Environmental Objectives and Planning to Achieve Them

E1Now clearly states about compliance obligations so for example if targets have been set for the packaging regulations or climate
change agreements these should appear in the objectives and planned to achieve them.
E1.1 So objectives should show allocation of resource, who will be responsible, completion dates and should cover protection of the
environment as well as prevention of pollution

3. URS Expectations

1. There is a need for clients to revisit their aspects table to show not only risks to pollute but to also now to protect the environment and
also there may be positive impacts on the environment.
2. Legal compliance checks now need to be much more thorough and show evidence of what’s been checked the legal register needs to
be company specific rather than a simple list of current statutes.
3. Objectives and targets are required to be managed more transparently showing allocation of resources and proper project
management eg
4. Waste reductions through recycling programmes need to show measurables either waste volumes or weights.
5. Operational procedures should clearly show process controls for water treatment, waste management etc.
6. These are some of the key areas but check through our guidance document as the above is by no means exhaustive.

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 4. URS Strategy for Certification Transition

A) Transition Process Steps

A.1 Transition for Existing Registered Clients – Option A:

A.1.1 An on-site¥ stage 1 “Gap Analysis” shall be performed by the Lead Auditor for 0.5 days at the next scheduled
surveillance. The purpose of the GAP Analysis is to determine whether the client’s existing system addresses the new
requirements of the standard. Formal notes of the GAP Analysis shall be recorded in the client report.
A.1.2 Should the GAP Analysis be successful, arrangements shall be made to conduct the formal audit to the 2015 version of
the standard at the subsequent surveillance+, normally 12 months later.
A.1.3 Upon receipt of the audit referenced in A.1.2+ and subject to closure of any concerns raised, a new certificate shall be
issued to the 2015 version of the standard.

Important Notes:

In order to allow a transition process which minimizes the administration and maintains effective control via URS’ internal workflow
system (CMS), please note:

1. When the auditor contacts the client for the next scheduled surveillance to ISO 14001: 2008, he/she shall ask the client do
they wish the GAP Analysis visit to be conducted for the upcoming surveillance.
2. If the client does request the above option, the auditor shall contact the URS Local Office and an extra half day shall be
added to the Job Instruction (by means of a special visit) and at this point the half-day GAP Analysis invoice shall be issued
to the client (for example in the UK this fee will be £325 + VAT).
3. The half –day visit will be conducted either the day before, or day after the planned surveillance visit – the effectiveness of
the GAP Analysis visit shall be commented on in the normal Client Report – which is left with the client – under the section
Auditor Summary.
Any findings resulting from the GAP Analysis will be recorded under the Comments Section of the report as Potential Non-
Compliances (PNC) or Opportunities for Improvement (OFI).
4. Should the auditor and client agree that the GAP Analysis and findings are minor to allow the transition visit to proceed, then,
unless otherwise agreed, this will be performed at the following routine surveillance (usually 12 months later) for the existing
certification, with no further cost – i.e.: it shall be part of the next annual certification and surveillance fee.
5. Under option (4) above, the auditor shall again comment in the Client Report, under the section Auditor Summary, whether
the client can be upgraded to the new version of standard (noting any findings to the new version of the standard, at this
visit, may be recorded as Concerns – Non- Compliances (NC) and/or Discrepancies (D).
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 6. Once the report has been reviewed by the Local office and any Corrective Actions etc., are accepted, then a new Certificate
of Registration shall be issued to the 2015 version of the standard.

6.1 In order to ensure the Certification cycle and certificate life are maintained – any new revised Certificate of Registration
issued to the new standard shall reflect the current certificate expiry date.
6.2 The above means that should the Client transfer within the life of their current ISO 14001:2008 certificate, the new
Certificate of Registration (to ISO 14001:2015) shall have the same expiry date as that of the “old” ISO 14001:2008
certificate.

Option A Process Summary:

1. Client agrees to an additional 0.5 day to the scheduled Surveillance Audit.

2. A pro-forma invoice will be issued - £325* + VAT.
3. The auditor completes the 0.5 day GAP Analysis Review either the day before or after the scheduled Surveillance Audit.
4. The auditor leaves a report with the client.
5. The client shall submit Corrective Actions to URS for review (if recommended by the auditor).
6. The next planned Surveillance Audit will then be completed without additional time required. ISO 14001: 2015 will be
audited during this Audit.
7. If successful, or when Corrective Actions and Evidence for any concerns raised during the Surveillance Audit have been
successfully “closed-out” a certificate will be issued to ISO 14001: 2015.
8. Normal certification cycle resumes.

A.2 Transition for Existing Registered Clients – Option B:

A.2.1 If a client determines a GAP Analysis visit is required before their next surveillance is due, then the client should
request this in writing to their Local URS Office.
A.2.2 On receipt of the written request from the client, the Local URS office shall raise a Special Job Instruction for the client’s
nominated auditor.
A.2.3 The steps as stated in A.1.2 and 3 above, will then follow as indicated.

Option B Process Summary:

1. Written request has been received from the client.

2. A pro-forma invoice will be raised for £325* + VAT.
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 3. The auditor will schedule a GAP Analysis Review with the client.
4. The auditor leaves a report with the client
5. The client shall submit Corrective Actions to URS for review (if recommended by the auditor).
6. The following planned Surveillance Audit will then be completed without additional time required. ISO 14001: 2015 will
be audited during this Audit.
7. If successful, or when Corrective Actions and Evidence for any concerns raised during the Surveillance Audit have been
successfully “closed-out” a certificate will be issued to ISO 14001: 2015.
8. Normal certification cycle resumes.

A.3 Transition for Existing Registered Clients – Option C:

A.3.1 If a client determines a GAP Analysis is required before their next surveillance is due and the client would like to have
their transition visit also before their next surveillance is due, then:
A.3.1.1 Then the steps stated in A.2.1 and A.2.2 shall apply.
A.3.2 However, after the GAP Analysis visit and report, the auditor and client shall agree a mutually suitable date for a one-
day transition audit to be conducted.
A.3.3 A special visit shall be raised and associated invoice, the fee being based again on the normal fees stated in the
accepted quotation for the existing certification.
A.3.4 On a satisfactory transition visit and closure of any Corrective Actions etc., a new Certificate of Registration shall be
issued to the new 2015 version of the standard.

Important Notes:

The same rules shall apply as those stated in Important Notes above – items 6.1 and 6.2.

Option C Process Summary:

1. Written request has been received from the client.

2. A pro-forma invoice will be raised for £825¥* + VAT.
3. The auditor will schedule a GAP Analysis Review this will be for 0.5 day.
4. Corrective Actions shall be submitted to URS for review (if recommended by the auditor).
5. The auditor schedules the Special Audit*. The Audit Plan will be to the ISO 14001: 2015 version of the standard.
6. The Transition audit will be conducted at a mutually convenient date to the auditor and client.
7. If the transition audit is successful, or when any Corrective Actions and Evidence for concerns raised, during the Transition
Surveillance Audit have been successfully reviewed, a certificate will be issued to ISO 14001: 2015

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 8. Normal certification cycle resumes.

A.4 Summary Notes regarding Transition for Existing Clients:

It cannot be stressed enough, that the changes in approach to the 2015 version of the standard are significant and that the most
important elements of the revisions are:

A.4.1 Have a meaningful Process flow/Map.

A.4.2 Conducting Risk Assessments for the stated Processes.
A.4.3 Measuring the effectiveness of the Processes.

Whilst the stated Transition Option process for existing clients will not vary, please be aware, that the indicated GAP Analysis
visit and/or transition visit man-day durations stated above, assume that existing clients will maintain their existing systems, as
currently registered and update their systems to address A.5.1, A.5.2 and A.5.3 above.

1. Should a client determine a full re-write of their system is required then the transition visit may include more time than
currently scheduled or indicated above.
2. All the options above must be completed before the end of the transition period – i.e.: 3 years after publication of the
2015 version of ISO 14001. If not, any current ISO 14001:2008 certificate will be invalid.
3. ¥ Under extenuating circumstances the GAP Analysis Review Visit can be performed off-site, however, the stated fee
will still apply.

A.5 Transition for NEW Registered Clients:

A.5.1 Any Client that is not currently ISO 14001, but wishes to be registered, may apply directly to the 2015 version of the
standard, once it is formally published. Under such circumstances, the existing stage 1 and stage 2 process shall apply as
currently stated.
A.5.2 Any Client that is not currently ISO 14001, but wishes to be registered to the 2008 version of ISO 14001, may do so, but
applications for this version of the standard shall not be accepted after 2 years from the published date of the 2015 version of
the standard.

After the 2 year period has elapsed, applications from clients must be to the 2015 version of ISO 14001.

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 4. Comparison and Guidance Matrix (ISO 14001:2015 versus ISO 14001:2004)

ISO
ISO 14001:
ISO 14001:2015 What the standard requires What should clients do? What does URS have to do?
14001:2015 2004
Requirement
Clause Clause
Context of the The organization shall determine external and Evaluate their position with respect to trade See evidence that an evaluation has been
organization internal issues that are relevant to its purpose associations, customer requirements, carried out on their current issues
and that affect its ability to achieve the intended Climate change agreements, compliance
outcomes of its environmental management schemes
4 system. Such issuesshall include environmental Local issues with air quality for example,
conditions being affected by or capable of Sensitive receptors nearby e.g. salmon river
affecting the organization.

Understanding The organization shall determine:

This is not a new requirement but is now Auditors must check there is evidence
the organization
more explicit -stakeholder concerns that the company have evaluated what
and its context a) the interested parties that are relevant to are the needs of interested parties
the environmental management system; A stakeholder could be a packaging waste
particularly important are where there
4.1 b) the relevant needs and expectations (i.e. compliance scheme how does the company
are legal obligations such as the
requirements) of these interested parties; ensure their obligations fulfilled in the
submission of data to the Environment
collection of data (and indeed its accuracy)
c) which of these needs and expectations Agency for IPPC
become its compliance obligations.

Understanding The organization shall determine the boundaries

Again not new but better defined; The auditor should check the scope of
the needs and and applicability of the environmental
activity covers things like permit
expectations of management system to establish its scope. Make sure you have a site plan
conditions for a site eg for a waste
interested parties External issues may be movement of goods, management licence
When determining this scope, the organization
shall consider: Impact on local community noise nuisance It should cover buildings such as on an
industrial estate the unit numbers it
That processes are understood in
a) the external and internal issues referred to applies to
manufacture and the effect on emissions
4.2 in 4.1;
discharges (internal issues) If the company has delivery on its scope
b) the compliance obligations referred to in then it should cover its logistics
4.2; Compliance: IPPC permit conditions for operation.
c) its organizational unit(s), function(s), and example
physical boundaries; Please note this scope is NOT the
Activities-processes again scope that appears on the ISO 14001
d) its activities, products and services; certificate but is the scope of controls
Products-life cycle issues see later
e) its authority and ability to exercise control to be covered under the documented
and influence Upstream and downstream influence e.g. ems
customers and suppliers
Determining the The organization shall determine the boundaries Scope now should be determined usually in a Auditor will need to review the
scope of the and applicability of the environmental top tier policy document or in preparatory documented information and see that it
4.3 environmental management system to establish its scope. environmental review (PER) has been circulated or made available to
management their interested parties
system When determining this scope, the organization

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 ISO
ISO 14001:
ISO 14001:2015 What the standard requires What should clients do? What does URS have to do?
14001:2015 2004
Requirement
Clause Clause
shall consider:

a) the external and internal issues referred to See 4.1

in 4.1;
b) the compliance obligations referred to in 4.2;
c) its organizational unit(s), function(s), and
physical boundaries;
d) its activities, products and services;
e) its authority and ability to exercise control
and influence

Once the scope is defined, all activities, products

and services of the organization within that scope
need to be included in the environmental
management system.

The scope shall be maintained as documented

information and be available to interested parties. Needs to be documented hence suggestion
to put in a top tier manual or similar

Environmental To achieve the intended outcomes, including
management enhancing its environmental performance, the
system organization shall establish, implement, maintain
and continually improve an environmental
management system, including the processes
needed and their interactions, in accordance
with the requirements of thisInternational
4.4
Standard.
Reference to processes now explicit and the Auditor must evaluate the processes
recognition the part they play e.g. have you a needed to manage the ems
process for waste management
Intended outcome for example to maintain
your waste hierarchy and meet the duty of care
And achieve your targets on recycling
(improvement)

The organization shall consider the knowledge
gained in 4.1 and 4.2 when establishing and
maintaining the environmental management
system.
5 Leadership
Leadership and Top management shall demonstrate leadership
commitment and commitment with respect to the
environmentalmanagement system by:
5.1
a) taking accountability for the effectiveness
of the environmental management system;
b) ensuring that the environmental policy and
environmental objectives are established
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i.e. remember the extent and scope of your
system which may include supplier
development e.g. transport/logistics reducing
journeys choosing routes that avoid congestion
zones
More involvement from people at the top The auditor must ensure any objectives
and targets link up to strategic
objectives
Auditors cannot demand there is a
management rep
Reviews (these don’t have to be one There should be evidence that the
meeting any more mentioned in guidance) system is supported with allocation of
 ISO
ISO 14001:
ISO 14001:2015 What the standard requires
14001:2015 2004
Requirement
Clause Clause
and are compatible with the strategic
direction and the context of the
organization;
c) ensuring the integration of the
environmental management system
requirements into theorganization’s
business processes;
d) ensuring that the resources needed for the
environmental management system are
available;
e) communicating the importance of
effective environmental management and
of conforming to the environmental
management system requirements;
f) ensuring that the environmental
management system achieves its intended
outcomes;
g) directing and supporting persons to
contribute to the effectiveness of the
environmental management system;
h) promoting continual improvement;
i) supporting other relevant management
roles to demonstrate their leadership as it
applies to theirareas of responsibility.
NOTE Reference to “business” in this
International Standard can be interpreted
broadly to mean those activities that are core to
the purposes of the organization’s existence.
Environmental Top management shall establish, implement and
Policy maintain an environmental policy that, within
thedefined scope of its environmental
management system:
What should clients do? What does URS have to do?
Policy should align with group policy for resources BUT there is no requirement
example if the company is a member of a for this to be documented!
trade group do they have any special During an audit it is expected that the
direction similarly could have an annual auditor will interview Directors/Senior
report to shareholders Management
Integration is now easier so consider
processes that control quality and health
safety information security etc.
Resources should be allocated budgets,
manpower, etc.
Transparency that the system is effective
Noticeboards, newsletters etc.
Target setting (now much more
prescriptive)
No longer a management rep but
recognition it may be a team of people
Again transparency
E.g. with example earlier support of
procurement for choice of logistics
company
Policy should documented and auditor
therefore should review this against 5.2
And note in his audit trail its current
status (issue date etc)

a) is appropriate to the purpose and

context of the organization, including
5.2 the nature, scale andenvironmental
impacts of its activities, products and
services;
b) provides a framework for setting
environmental objectives;
c) includes a commitment to the protection of Main change here is protection of the
the environment, including prevention of
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 ISO
ISO 14001:
ISO 14001:2015 What the standard requires What should clients do? What does URS have to do?
14001:2015 2004
Requirement
Clause Clause
pollution and other specific commitment(s) environment not just prevention of pollution
relevant to the context of the organization; Requirement to commit to any other
business requirements related to the
NOTE Other specific commitment(s) to protect environment
the environment can include sustainable
resource use, climate change mitigation and
adaptation, and protection of biodiversity and
ecosystems.

d) includes a commitment to fulfil its

compliance obligations;
e) includes a commitment to continual
improvement of the environmental
management system to enhance
environmental performance.

The environmental policy shall:

be maintained as documented information;
be communicated within the organization;
be available to interested parties
Organisational Top management shall ensure that the Now no specific management rep but can Auditor should check evidence of
roles, responsibilities and authorities for relevant roles split the roles and responsibilities allocation of responsibility and
responsibilities are assigned and communicated within the evidence of reporting mechanisms
and authorities organization. being in place

Top management shall assign the responsibility

and authority for:

5.3 a) ensuring that the environmental

management system conforms to the
requirements of this International
Standard;
b) reporting on the performance of the
environmental management system,
including environmental performance, to
top management.

6 Planning
Actions to
address risks
6.1 associated with
threats and
opportunities

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 ISO
ISO 14001:
ISO 14001:2015 What the standard requires What should clients do? What does URS have to do?
14001:2015 2004
Requirement
Clause Clause
General The organization shall establish, implement and
The aspects table always did look at Auditor needs to see Risks and
maintain the processes needed to meet the
potential to pollute now needs to look at opportunities have been identified and
requirements in 6.1.1 to 6.1.4.
protecting the environment more generally documented
e.g. climate change
When planning for the environmental
management system, the organization shall Now mentions opportunities e.g.. an
consider: Processes needs to have been
insulation company selling its product is in
identified e.g. Compliance schemes,
fact encouraging energy conservation so
consent to discharge/treatment
a) the issues referred to in 4.1; there is recognition there are positives to
processes, scrubbers/afterburners
b) the requirements referred to in 4.2; consider as well as negatives
maintenance and monitoring
c) the scope of its environmental Any stakeholder concerns needs to be
management system; and determine the addressed
risks and opportunities, related to its:
Always did have to look at emergencies but
d) environmental aspects (see 6.1.2); now specifically mentions ‘potential
e) compliance obligations (see 6.1.3); emergencies’ that could be external issues
f) other issues and requirements, identified in like a train crash or river flooding most
4.1 and 4.2; that need to be addressed to: companies usually look currently only at fire
g) give assurance that the environmental and spillage.
management system can achieve its
intended outcomes;
6.1.1 h) prevent, or reduce, undesired effects, External conditions here again could be
including the potential for external flooding the affect on a local neighbourhood
environmental conditions to affect the with traffic congestion etc.
organization;
i) achieve continual improvement.

Within the scope of the environmental

management system, the organization shall
determine potential emergency situations,
including those that can have an environmental
impact.

The organization shall maintain documented

information of its:

a) risks and opportunities that need to be

addressed;
b) processes needed in 6.1.1 to 6.1.4, to
the extent necessary to have This small paragraph has potentially the
confidence they are carried out as most significance BUT like the quality
planned. standard the company must decide on the
level of documentation required based on

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 ISO
ISO 14001:
ISO 14001:2015 What the standard requires What should clients do? What does URS have to do?
14001:2015 2004
Requirement
Clause Clause
knowledge and competence of people and
the degree of control currently
Environmental Within the defined scope of the environmental
Life cycle perspective is a significant change
Aspects management system, the organization shall
so company must show they have
determine the environmental aspects of its
considered this e.g. what about the ultimate
activities, products and services that it can control
disposal of their product –for example
and those that it can influence, and their
WEEE directive and the effect this has had
associated environmental impacts, considering a
on disposal of PCBs
life cycle perspective.
Upstream and downstream influences need
When determining environmental aspects, the to be considered.
organization shall take into account:

a) change, including planned or new Any new processes could seriously affect
developments, and new or modified impact on the environment
activities, products and services;
b) abnormal conditions and reasonably
foreseeable emergency situations. Normal abnormal and emergency conditions
was in the original BS7750 and now its back
The organization shall determine those aspects more transparently!
that have or can have a significant
environmentalimpact, i.e. significant
6.1.2 environmental aspects, by using established
criteria.

The organization shall communicate its significant

environmental aspects among the various levels
and functions of the organization, as appropriate.

The organization shall maintain documented

information of its:
Clear that you have to have a documented
a) environmental aspects and associated process and an aspects table
environmental impacts;
b) criteria used to determine its significant
environmental aspects;
c) significant environmental aspects. This was always a requirement but the need
for positive aspects was not highlighted
NOTE Significant environmental aspects can
result in risks and opportunities associated with E.g. a company remanufacturing toner
either adverse environmental impacts (threats) or cartridges for printers is reducing the
beneficial environmental impacts (opportunities). amount of product reaching end of life.
Compliance The organization shall:
6.1.3 The usual way in the past was to have a Auditor must check there is evidence

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 ISO
ISO 14001:
ISO 14001:2015 What the standard requires What should clients do? What does URS have to do?
14001:2015 2004
Requirement
Clause Clause
Obligations a) determine and have access to the legal register this recognises the information that the company has evaluated its
compliance obligations related to its could be more remote i.e. as long as you legal obligations and stated what they
environmental aspects; can access the information this is OK are and show how they tie up with its
b) determine how these compliance b) this is to stop standard lists of legal
aspects (not a new requirement)
obligations apply to the organization; statutes which doesn’t actually state what
c) take these compliance obligations into you have to do to comply
account when establishing, implementing,
c) is to take into account where legal
maintaining and continually improving its
obligations are required e.g. waste
environmental management system.
packaging regulations requirement for
reducing and recycling waste
The organization shall maintain documented
information of its compliance obligations. or IPPC where permit conditions require
improvements
NOTE Compliance obligations can result in
risks and opportunities to the organization.

Planning action The organization shall plan:

Actions may not be improvements in an Auditor should ask for evidence of
objectives and targets sense but may be to planning activities for the management
a) to take actions to address its: monitor the process to see if the process of significant aspects and meeting legal
remains in its parameters then the aspect obligations
1) significant environmental aspects; significance could diminish
2) compliance obligations;
Dosing/water treatment is a good example
b) risks and opportunities identified in 6.1.1; of 2) to meet a consent to discharge again a
how to: process control

6.1.4 1) integrate and implement the actions into

its environmental management system So the above would become controls within
processes (see 6.2, Clause 7, Clause 8 the ems
and 9.1), or other business processes;
2) evaluate the effectiveness of these
actions (see 9.1).
BATNEEC is considered here i.e. if the
When planning these actions, the organization
actions are too costly and not in the best
shall consider its technological options and its
interests business wise then the company
financial, operational and business requirements.
can opt out
Environmental
objectives and
6.2
planning to
achieve them
Environmental The organization shall establish environmental
6.2.1 This whole area is now much more Auditors should check for evidence of
objectives objectives at relevant functions and levels, taking
prescriptive and requires SMART targets documented objectives
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 ISO
ISO 14001:
ISO 14001:2015 What the standard requires What should clients do? What does URS have to do?
14001:2015 2004
Requirement
Clause Clause
into account the organization’s significant
The requirements are self explanatory
environmental aspects and associated
compliance obligations, and considering its risks
and opportunities.
Targets need to be tracked and if something
The environmental objectives shall be: changes then it should be communicated
Transparency again of actions and progress
a) consistent with the environmental policy;
b) measurable (if practicable);
c) monitored;
d) communicated;
e) updated as appropriate.
Needs to be documented
The organization shall maintain documented
information on the environmental objectives.

Planning actions When planning how to achieve its environmental

Self explanatory prescriptive much clearer The auditor should check for
to achieve objectives, the organization shall determine:
requirements documented information on how the
environmental planning of meeting objectives is stated
objectives a) what will be done; KPI approach familiar to many.
b) what resources will be required;
c) who will be responsible;
d) when it will be completed;
e) how the results will be evaluated, including
6.2.2 indicators for monitoring progress toward
achievement of its measurable environmental
objectives (see 9.1.1).

The organization shall consider how actions to

achieve its environmental objectives can be
integrated into the organization’s business Encourages integrated objectives e.g.
processes. reduce scrap-reduce waste

7 Support
Resources The organization shall determine and provide the Level of resource applied to the system needs Auditor should check for adequate
resources needed for the establishment, to be determined resourcing (can be by interview)
implementation, maintenance and continual
7.1
improvement of the environmental management
system.

Competence The organization shall: Auditor needs to check for Competence

evaluations
7.2
a) determine the necessary competence of This is saying you need to go through the
person(s) doing work under its control that process of formally looking at key tasks and

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affects its environmental performance and work out the competence required and where
its ability to fulfil its compliance obligations; necessary provide training to ‘raise the bar’ to
b) ensure that these persons are competent on the required level.
the basis of appropriate education, training or But it does recognise the role of the consultant!
experience;
c) determine training needs associated with
its environmental aspects and its
environmentalmanagement system;
d) where applicable, take actions to acquire
the necessary competence, and evaluate
the effectiveness of the actions taken.

NOTE Applicable actions can include, for

example, the provision of training to, the
mentoring of, or the re- assignment of currently
employed persons; or the hiring or contracting of
competent persons.

The organization shall retain appropriate

documented information as evidence of
competence.
Records of competence have to be on file
Awareness The organization shall ensure that persons doing Auditor should sample interview
work under the organization’s control are aware This area has been reinforced all employees personnel during the walk round
of: and agency staff/sub contractors have to To establish that awareness has been
show they know and understand what the addressed.
a) the environmental policy; issues are :significant aspects
b) the significant environmental aspects and And how they might affect them positively and
related actual or potential environmental negatively
impacts associated with their work;
7.3 c) their contribution to the effectiveness of
the environmental management system,
including the benefits of enhanced
environmental performance;
d) the implications of not conforming with
the environmental management system
requirements,including not fulfilling the
organization’s compliance obligations.

7.4 Communication
General The organization shall establish, implement and This is recognising the development of Communications should be audited by
maintain the processes needed for internal and various means of communication more looking for evidence of legal compliance,
7.4.1
external communications relevant to the prescriptive self explanatory. Supply of data/information to clients on
environmental management system, including: Requires process approach request

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on what it will communicate;

a) when to communicate;
b) with whom to communicate;
c) how to communicate.

When establishing its communication process(es),
the organization shall:
a) take into account its compliance obligations;
b) ensure that environmental information
communicated is consistent with
information generated within the
environmental management system, and is
reliable.
The organization shall respond to relevant
communications on its environmental
management system.
This requires the process to defined on how
for example the company collects and
communicates data on waste packaging,
Meeting schedule requirements to the
Environment Agency
And indeed that the information is
accurate/reliable.
But equally it may be the collection and
transmission of information on carbon
footprint /CO2 emissions
The importance here is now has to be
documented

The organization shall retain documented

information as evidence of its communications, as
appropriate.

Internal The organization shall:

Communication This can be audited in the process of
a) internally communicate information No requirement to document! auditing the company’s environmental
relevant to the environmental processes.
management system among the various
levels and functions of the organization,
7.4.2 including changes to the environmental
management system, as appropriate;
b) ensure its communication process(es)
enable(s) persons doing work under the
organization’s control to contribute to
continual improvement.

External The organization shall externally communicate See 7.4.1 on communication of data Auditors should check in particular for
Communication information relevant to the environmental May also be complaints follow up evidence of communications with
7.4.3 management system, as established by the regulators where fulfilment of legal
organization’s communication process(es) and as obligations are required.
required by its compliance obligations.
Documented
7.5
information

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General The organization’s environmental management
The company can have additional Where documented information is a
system shall include:
information that they think is important requirement of the standard the auditor
included in the ems shall check for evidence and note it on the
a) documented information required by this
audit record
International Standard;
b) documented information determined by the
organization as being necessary for the
effectiveness of the environmental
management system.

NOTE The extent of documented information for

7.5.1 an environmental management system can differ
from one organization to another due to:
This is like the new ISO 14001:2015 in
a) the size of organization and its type of
that the documentation required is based
activities, processes, products and services;
upon the skill base the company have
b) the need to demonstrate fulfilment of its
and how complex the processes are
compliance obligations;
c) the complexity of processes and their If people are competent then process
interactions; mapping may be quite simplistic
d) the competence of persons doing work
under the organization’s control.

Creating and When creating and updating documented

This is not new but is now clearly defined rather Essentially requires the auditor to see all
updating information, the organization shall ensure
than implied documented information is suitably
appropriate:
controlled
a) identification and description (e.g. a title,
7.5.2 date, author, or reference number);
b) format (e.g. language, software version,
graphics) and media (e.g. paper, electronic);
c) review and approval for suitability and
adequacy.

Control of Documented information required by the Now refers to documented information rather
documented environmental management system and by this than documents
information International Standard shall be controlled to
ensure: Covers information security.
Recognises some media deteriorate over time
7.5.3 a) it is available and suitable for use, where But controls remain largely unchanged
and when it is needed;
b) it is adequately protected (e.g. from loss of
confidentiality, improper use, or loss of
integrity).
c) For the control of documented information,
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the organization shall address the
following activities as applicable:
d) distribution, access, retrieval and use;
e) storage and preservation, including
preservation of legibility;
f) control of changes (e.g. version control);
g) retention and disposition.

Documented information of external origin

determined by the organization to be necessary
for theplanning and operation of the Statutes pollution prevention control guidelines
environmental management system shall be etc need to be controlled and kept up to date
identified, as appropriate, and controlled.

NOTE Access can imply a decision regarding Access doesn’t mean the document is
the permission to view the documented company’s intellectual property
information only, or the permission and authority
to view and change the documented information.

8 Operation
Operational The organization shall establish, implement, control The ems was never previously as Auditor needs to check that documented
planning and and maintain the processes needed to meet prescriptive about process control information is adequate to maintain
control environmental management system requirements, control obviously if there is evidence of
and to implement the actions identified in 6.1 and 6.2, pollution, breaches in legislation then an
by: auditor can raise a concern but care
should be exercised as it may also be
a) establishing operating criteria for the down to competence of personnel.
process(es);
b) implementing control of the process(es), in
accordance with the operating criteria.

NOTE Controls can include engineering

8.1
controls and procedures. Controls can be
implemented following a hierarchy (e.g.
elimination, substitution, administrative) and can
be used individually or in combination.
The organization shall control planned changes
and review the consequences of unintended
changes, taking action to mitigate any adverse
effects, as necessary.
The organization shall ensure that (an)
outsourced process(es) is (are) controlled or
‘Downstream’ activities need to be controlled
E.g. surface treatments like galvanising,
painting often done by sub contractors and
which potentially have significant
environmental impacts need to be controlled
Similarly because this now considers life
cycle it should cover activities like shipping,
logistics etc.
WEEE and similar legislative controls now
come into play much more e.g. End of life
vehicle controls etc.

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influenced. The type and extent of control or Aspects tables therefore cover much more
influence to be applied to the process(es) shall than the factory environment.
be defined within the environmental
management system.

Consistent with a life cycle perspective, the

organization shall:

a) establish controls, as appropriate, to ensure

that its environmental requirement(s) is (are)
addressed in the design and development
process for the product or service, considering
each stage of its life cycle;
b) determine its environmental requirement(s)
for the procurement of products and
services, as appropriate;
c) communicate its relevant environmental
requirement(s) to external providers,
including contractors;
d) consider the need to provide information
about potential significant environmental
impactsassociated with the transportation
or delivery, use, end-of-life treatment and
final disposal of its products and services.

The organization shall maintain documented

information to the extent necessary to have
confidence that the process(es) has (have) been
carried out as planned.
Emergency The organization shall establish, implement and Most companies have addressed these for fire Auditor must check to see there is
preparedness maintain the processes needed to prepare for and spillages but traffic accidents, rail crashes documented evidence of emergency
and response and respond to potential emergency situations etc. have generally not been covered planning
identified in 6.1.1. remember the previous section has alluded to
external issue of transport logistics etc.
The organization shall: The section is more expressive about ‘lessons
learned’
a) prepare to respond by planning actions to
8.2
prevent or mitigate adverse environmental Documented evidence is required that the
impacts from emergency situations; system or process is working.
b) respond to actual emergency situations;
c) take action to prevent or mitigate the
consequences of emergency situations,
appropriate to the magnitude of the
emergency and the potential environmental
impact;
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d) periodically test the planned response
actions, where practicable;
e) periodically review and revise the
process(es) and planned response actions,
in particular after the occurrence of
emergency situations or tests;
f) provide relevant information and training
related to emergency preparedness and
response, asappropriate, to relevant
interested parties, including persons working
under its control.

The organization shall maintain documented

information to the extent necessary to have
confidence that the process(es) is (are) carried out
as planned.

Performance
9
evaluation
Monitoring,
measurement,
9.1
analysis and
evaluation
General The organization shall monitor, measure, analyse
and evaluate its environmental performance. The Auditor needs to check for documentary
organization shall determine: evidence of monitoring and
Many small companies have not addressed measurement
this area well in the past but now they must
a) what needs to be monitored and measured; measure how they are performing so waste
b) the methods for monitoring, generation amount of recycling occurring
measurement, analysis and evaluation, needs to be actually recorded.
as applicable, to ensure valid results;
c) the criteria against which the organization Solvent reduction amount by how much etc.
will evaluate its environmental performance, Analysis of course could be management
9.1.1 and appropriate indicators; review (doesn’t say how you analyse)
d) when the monitoring and measuring shall be
performed;
e) when the results from monitoring and
measurement shall be analysed and
evaluated.

The organization shall ensure that calibrated or

verified monitoring and measurement equipment
is used and maintained, as appropriate.

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The organization shall evaluate its
environmental performance and the
effectiveness of the environmental management
system.

The organization shall communicate relevant This harks back to EMAS about publicly
environmental performance information both declaring data (many companies now have
internally and externally, as identified in its
statements in their year-end accounts)
communication process(es) and as required by its
compliance obligations. Similarly if the company is IPCC they are
legally obligated to provide this information-
The organization shall retain appropriate companies were doing this.
documented information as evidence of the
monitoring,measurement, analysis and evaluation
results.

Evaluation of The organization shall establish, implement and

maintain the processes needed to evaluate Most small companies have evaluated Auditor shall check for legal compliance
compliance
fulfilment of its compliance obligations. compliance in as much as checking their results and evidence of actions taken if
The organization shall: legal register was up to date but there was breaches are evident
no requirement to actually have a process
a) determine the frequency that compliance will with corrective action follow up
be evaluated; c) is clearly saying you not only need to
9.1.2 b) evaluate compliance and take action if know what statutes apply but what the
needed; company’s specific obligations are.
c) maintain knowledge and understanding of
its compliance status. The compliance check needs to be
documented
The organization shall retain documented
information as evidence of the compliance
evaluation result(s).
9.2 Internal Audit
General The organization shall conduct internal audits at Audit schedule
planned intervals to provide information on
whether the environmental management system:

a) conforms to:
Audit to company’s processes as well as the
9.2.1
1) the organization’s own requirements for standard
its environmental management system;
2) the requirements of this International
Standard;
Check no issues
b) is effectively implemented and maintained.

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Internal audit The organization shall establish, implement and Internal audit programme has to say how Auditor shall check for evidence of audits
programme maintain an internal audit programme(s), including often and how the audit will be conducted being planned and evidence of their results
the frequency, methods, responsibilities, planning and how its reported
requirements and reporting of its internal audits.

When establishing the internal audit programme,

the organization shall take into consideration Most companies already comply with these
the environmental importance of the processes requirements
concerned, changes affecting the organization
and theresults of previous audits. But transparent requirements self-
explanatory
The organization shall:
9.2.2
a) define the audit criteria and scope for each
audit;
b) select auditors and conduct audits to ensure
objectivity and the impartiality of the audit
process;
c) ensure that the results of the audits are
reported to relevant management.

The organization shall retain documented

information as evidence of the implementation of
the audit programme and the audit results.

Management Top management shall review the organization’s Auditor shall check for evidence of
review environmental management system, at planned actions and outputs from management
intervals, to ensure its continuing suitability, reviews doesn’t actually say they have to
adequacy and effectiveness. be minuted as such so take care! But
there must be documented information
The management review shall include maintained!!
consideration of:

a) the status of actions from previous

9.3 management reviews;
b) changes in:

1) external and internal issues that are Change management

relevant to the environmental
management system;
2) the needs and expectations of interested
parties, including compliance obligations;
3) its significant environmental aspects;
4) risks and opportunities;
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c) the extent to which environmental objectives

have been achieved;
d) information on the organization’s
environmental performance, including trends Most companies did trend analysis but
in: didn’t report in detail
So the objectives and targets need to be
1) nonconformities and corrective actions; better reported for example
2) monitoring and measurement results;
3) fulfilment of its compliance obligations;
4) audit results;

e) adequacy of resources;
f) relevant communication(s) from interested New requirement about resourcing
parties, including complaints;
g) opportunities for continual improvement.

The outputs of the management review shall Much more evidence of decision making
include: and action follow up

a) conclusions on the continuing suitability,

adequacy and effectiveness of the
environmental management system;
b) decisions related to continual improvement
opportunities;
c) decisions related to any need for changes to
the environmental management system,
including resources;
d) actions, if needed, when environmental
objectives have not been achieved;
e) opportunities to improve integration of the
environmental management system with
other business processes, if needed;
f) any implications for the strategic direction of
the organization.

The organization shall retain documented

information as evidence of the results of
management reviews.
10 Improvement
General The organization shall determine opportunities for Not new
10.1
improvement (see 9.1, 9.2 and 9.3) and

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implement necessary actions to achieve the
intended outcomes of its environmental
management system.
Nonconformity When a nonconformity occurs, the organization Auditor shall ensure that there is
and corrective shall: documented evidence of the raising of non-
action conformances and the outcomes (results of
a) react to the nonconformity and, as corrective action)
applicable: Much more analytical and in line with
b) take action to control and correct it;
automotive/aerospace thinking e.g. FMEA root
c) deal with the consequences, including cause 5 whys etc.
mitigating adverse environmental impacts;
d) evaluate the need for action to eliminate the
causes of the nonconformity, in order that it
does not recur or occur elsewhere, by:
e) reviewing the nonconformity;
f) determining the causes of the
nonconformity;
g) determining if similar nonconformities exist,
or could potentially occur;
h) implement any action needed;
10.2
i) review the effectiveness of any corrective
action taken;
j) make changes to the environmental
management system, if necessary.

Corrective actions shall be appropriate to the

significance of the effects of the nonconformities
encountered, including the environmental
impact(s).

The organization shall retain documented Documented info required

information as evidence of:

a) the nature of the nonconformities and any

subsequent actions taken;
b) the results of any corrective action.

Continual The organization shall continually improve the System improvements required as well as Auditors should look for evidence of the
Improvement suitability, adequacy and effectiveness of the reduction in impacts ems improving in such a way that
10.3 environmental management system to enhance environmental performance has been
environmental performance. enhanced.

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