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This article provides an overview of key differences between ISO 14001:2004 and 14001:2015. Some new requirements include terminology such as evaluating risks and opportunities, while others expand on existing terminology (i.e. interested parties). You will need to evaluate your existing environmental management system (EMS) and identify the changes and adaptions necessary to be implemented in a timely manner. All existing systems must be re-certified prior to the September 15, 2018 deadline.

To ease the transition, you are encouraged to certify to 2015 by spring of 2018. Your registrar may offer an audit to the 2015 standard during your 2004 surveillance audit. It is important you communicate with your registrar for specifics. Some registrars are offering these “up” audits during 2004 surveillance audits and may be up to an additional half day for facilities with less than 500 employees and up to a full day for facilities with more than 500 employees.

By taking advantage of the “up” audit and having your 2015 certification in the spring of 2018 you will allow yourself ample time to respond to any findings with objective evidence without affecting your ability to meet the 9/15/18 certification deadline.

Noteworthy new requirements in ISO 14001:2015:

Interested Parties: Section 2015:4.2 Understanding the needs and expectations of interested parties expands on this term that was introduced in Section 2004:4.43 Communication. Consideration shall be given to whom the internal and external interested parties might be. Examples of internal interested parties are employees, suppliers, contractors and management teams. Examples of external interested parties include consumers, communities, and regulators.

Your organization is expected to gain a general understanding of the expressed needs and expectations of those interested parties that have been determined by the organization to be relevant. Relevant needs of interested parties may then become compliance obligations [compliance obligations is an enhanced term for legal and other requirements]. When determining your interested parties, it would be good practice to create a “register of interested parties”.

Risks and Opportunities: Section 2015:6.1 Actions to address risks and opportunities introduces the new term. The purpose is to integrate the environmental aspects and compliance obligations into the business of the organization by applying risk based thinking to the EMS. The viability of a business and its EMS is contingent on its ability to evaluate risk and capitalize on opportunities.

Risks are defined as the effects of uncertainty on objectives or potential scenarios associated with adverse environmental impacts. Risk based thinking shall be applied to environmental aspects, objectives and compliance obligations. An example of an aspect and compliance risk assessment would be evaluating the risk of engineering and procurement approving the purchase and use of an unapproved paint that results in the organization exceeding VOC limits. In this scenario a new control to mitigate that risk would be to involve environmental in the raw material approval process.

Life Cycle Perspective: This term shows up in 2015:6.1 Actions to address risks and opportunities and 2015: 8.1 Operational planning and content. The identification of aspects and impacts and controls now need to consider a life cycle perspective. Consistent with risk based thinking, it has been made explicit to take into account abnormal and emergency situations.

When determining environmental aspects, the organization considers a life cycle perspective – this does not require a detailed life cycle assessment. A life cycle perspective includes consideration of the environmental aspects of an organization’s activities, products and services that it can control or influence. Stages in a life cycle include acquisition of raw materials, design, products, transportation/delivery, use, end of life treatment and final disposal.

You’re encouraged to review your copy of the ISO 14001:2015 standard, including the Annex, for more information on other new terminologies such as indicators, outsource, process and context of the organization. As well as new emphasis placed upon environmental conditions, communication/awareness and requirements for top management to maintain accountability of the system and integrate the EMS into the business process and strategic planning.

Publication Date: March 2, 2017
Version: 01
Author: Tony DeMarco, Vice President of Consulting Services

NEWSLETTER: BCA ENVIRONMENTAL CONSULTANTS

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