Understanding Green Tier Audits

The Wisconsin Department of Natural Resources Green Tier program has requirements for participants to perform different types of audits of their Environmental Management Systems (EMS). Understanding these types of audits and who can perform them will help ensure compliance with Green Tier. The types of Green Tier audits are:

  • EMS Internal audits
  • EMS Outside Audits
  • Regulatory Compliance Audits

Types of Audits and Frequency

EMS Internal Audits

Internal audits can be performed by the participant themselves or by independent auditors. These audits are then used as part of the management review process to help leadership evaluate the performance of the EMS and to decide if any changes are needed to improve it. They must be documented, performed at least annually and conducted by competent objective auditors.

Outside Audits

Outside audits are performed by independent auditors that have been approved by WDNR to perform these audits. Tier 1 participants must perform these audit at least every 3 years. Tier 2 participants need to have an WDNR approved auditor perform these audits at least annually.

Compliance Audits

Compliance audits are different than the Outside Audit described above. These audits check that the organization is meeting the USEPA, WDNR and local legal requirements. These include requirements for emitting pollutants to the atmosphere, water, solid and hazardous waste disposal. Tier 2 participants need to perform compliance audits at least annually and report the results to WDNR. These audits can be internal audits or performed by other independent auditors.

Why Does Green Tier Require Audits?

The Green Tier Law is based on the requirements of ISO 14001 which also requires periodic audits of the EMS. ISO 14001 is itself based on the principals of continual improvement (PDCA). Audits are the checking part of the PDCA cycle.

Who is Qualified to Perfrom External Audits

Only WDNR approved Green Tier auditors are qualified to perform external audits. Green Tier participants should confirm that their auditor is on this approved list. Participants should do this even if they are using an ANAB accredited ISO 14001 certification body to perform their external audits. If you have any questions about Green Tier audits, who is qualified to do audits or want to know how to get the most out of your audit contact us for at kalehner@envcompsys.com or use the form below.

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Will Green Tier Law be Repealed?

A proposed Assembly Bill (AB 1059) would repeal the 20 year old Wisconsin Department of Natural Resources Green Tier program.  Although the bill is a long way from passage, the new law would likely eliminate the Green Tier program.  This article explores potential options Green Tier participants might consider if the Green Tier law is repealed.

The table below compares Green Tier with a few other popular alternatives for organizations wishing to communicate their superior environmental performance to others.  On the left, are the names of the programs including Green Tier.  The top row shows the characteristics of each of the program types.  A discussion of both the program types and the characteristics is below the table.

 Program Type Characteristics
Program TypePDCAAssuranceGlobalIntegrationMessage RecognitionCost to Implement
Green TierXStrong XMediumLow
Green Masters Some  MediumLow
ISO 14001XStrongXXHighMedium
EMASXStrong XMediumHigh
CSR NoneX MediumLow -Medium
CSR Verified StrongX HighHigh
Table showing comparison of Green Tier with other popular options.

PDCA – Plan Do Check Act continual improvement cycle? Most ISO type management systems are based on the PDCA model.

Assurance – Can the information be verified by an independent third party?

Global – Is this type of program globally recognized?

Integration – Does this program type integrate well with other protocols including ISO 9001, 45001 etc.?

Message Recognition – Are interested parties familiar with this type of program and messaging?

Cost – What is the cost to implement and operate this type of program?

Green Tier – A voluntary program modeled on the requirements of ISO 14001.   Green Tier was passed into law in April 16, 2004 to help Wisconsin businesses communicate their superior environmental performance to interested parties. Green Tier is based on the principles of continual improvement that help organizations continually improve performance in many different areas.  Green Tier also has an assurance component requiring participants perform periodic audits by an outside auditor of the organizations Environmental Management System (EMS).  A Green Tier EMS can be easily integrated with quality and occupational health and safety management systems into the organizations overall business management system.  Once accepted into the program, participants can communicate a strong message of superior environmental performance.  Participants have up to one year to implement their EMS making this a relatively low-cost investment to implement the management system.

Green Masters – The Green Master’s Program helps businesses focus on sustainability issues important to them while contributing to bottom line and top line growth. The program also provides a framework to develop, integrate, and grow sustainable practices. It also helps record and track progress in the sustainability action areas. Participants in the Green Master program declare that they meet criteria established by the program.  Green Master participants are recognized in four status levels.

Green Masters Levels

ISO 14001 – A globally recognized international standard based on the principles of continual improvement.  The International Accreditation Forum has established a robust accreditation and certification program that sends a strong message of superior environmental performance to interested parties.  ISO 14001 can also be easily integrated with other ISO management systems including ISO 9001 for quality management and ISO 45001 for Occupational Health and Safety Management Systems.

ISO 14001 Stabdard

Eco-Management and Audit Scheme (EMAS) – EMAS is very similar to the Green Tier program for organizations in the European Union countries.  It is a voluntary environmental management instrument, which was developed in 1993 by the European Commission. It incorporates ISO 14001 as a fundamental component and enables organizations to assess, manage and continuously improve their environmental performance. The scheme is globally applicable and open to all types of private and public organizations. In order to register with EMAS, organizations must meet the requirements of the EU EMAS-Regulation. Currently, more than 4,000 organizations and more than 12,700 sites are EMAS registered 


Corporate Sustainability Reporting (CSR) – Sustainability reporting has emerged as a cornerstone of corporate responsibility.  Reporting can  help businesses demonstrate their commitment to sustainable practices and transparency. The CSR trend is fueled by,  government regulations, heightened stakeholder scrutiny, and a growing recognition of the significance of ESG performance for long-term business success. There are several popular CSR reporting standards  each having their pros and cons.  Here is a list of some most recognized:

CSR reports are not based on a management system standard.  Instead, they are categories or areas of sustainability that the organizations report.  Organizations are not required to seek independent verification of the sustainability claims being made.  This has led to criticism by users of the reports that the information is not reliable and may be considered “greenwashing”.

IASSB and ISO 14019 Sustainability Assurance

Criticism of unverified CSR reporting has lead to development of new standards for verification of sustainability claims in CSR reports.  International Auditing and Assurance Standards Board (IAASB) has recently issued ISSA 5000 to help provide assurance to users of CSR information.   The International Organization for Standardization (ISO) is also developing ISO 14019 for sustainability information verification and validation (VV).  The ISO standards include a pathway for accreditation of VV bodies under ISO 17029.

Although Green Tier is unlikely to be repealed soon,  we hope this information gives Green Tier participants a broader picture of ways to communicate sustainability information to those interested in your performance.  For more information check out or Green Tier Services or you can contact us here or email us kalehner@envcompsys.com.

URGENT ALERT – ISO Climate Change Amendments!

ISO recently amended all ISO management system standards (MSS) to include requirements for organizations to consider the effects of climate change. If your organization holds a current certification to ISO 9001, 14001 or 45001 you can expect to be asked “has your organization determined whether climate change is a relevant issue?” during your next certification audit.

This new requirement is the result of a change to the ISO Harmonized Structure (Appendix 2 of the Annex SL in the ISO/IEC Directives Part 1 Consolidated ISO Supplement). Here is more background on the Harmonized Structure also referred to as the High Level Structure and Annex SL.

ISO announced the new requirement in an IAF/ISO Joint Communique indicating the climate change text highlighted below is effective immediately for all MSS.

ISO HLS revised requirements for context determination

Most organizations certified to ISO 14001 should be able to answer auditors questions about climate change relevance. Other organizations with current certification to ISO 9001 and/or 45001 might find it more difficult to avoid a nonconformity to these new requirements if they don’t act soon. Each organizations context is different and will influence how they address climate change in their MSS

Contact us if you have questions about how these new requirements might effect your organization ISO certification status.

WDNR Green Tier – Internal Audits and Corrective Action

WDNR Green Tier Internal Audits

The WDNR Green Tier program requires participants to conduct periodic “outside” EMS audits to check that the system is functionally equivalent to ISO 14001:2015.  By law, the minimum frequency of these audits is once every three years for Tier 1 participants and annually for Tier 2 participants. 

Many organizations choose to perform WDNR Green Tier audits more frequently than prescribed by the Green Tier law.  Longer than a year between audits result in increased risk to the organization.  Postponing an annual physical from your doctor increases the risk that a medical condition will becoming a bigger medical issue.

WDNR Green Tier audits also provide important information to leadership.  Reviewing Green Tier audit findings during management reviews allows leadership to evaluate how the EMS is functioning and if it is achieving the intended results. Leadership may miss important information when it reviews the results of audits only every three years.

Organizations that invest in their WDNR Green Tier audit program have better performing EMS’s and get a better return on their EMS investment.  ISO 19011:2018, Guidelines for auditing management systems provides guidance for organizations wishing to improve their EMS audits.  This guidance includes:

  • How to establish audit programs
  • How to conduct audits and report audit results
  • What competencies auditors need to possess
  • How to evaluate auditor competence.

Using the results of WDNR Green Tier Audits

WDNR Green Tier EMS audits evaluate audit criteria against audit evidence. Performing WDNR Green Tier audits ensures that “what should be is” and “what should not be is not”.  Examples of audit criteria are requirements of Green Tier functional equivalence, compliance obligations such as permit requirements or requirements such as WDNR universal waste and hazardous waste regulations.  They can also be internal requirements the organization has set for itself.

A robust EMS audit process and procedures coupled with effective corrective action process to address audit findings is critical to the effectiveness of am EMS.  If the audit process or the corrective action process is weak the EMS may not be able to achieve the intended results of the EMS.

WDNR Green Tier Audit Corrective Actions

Green Tier audits are fundamental to superior environmental performance, but audits alone do not make changes that improve performance.  Audits simply identify conformance and nonconformance to the requirements of Green Tier and the organizations internal requirement for the EMS. 

Audits can be good news or bad news.   If an organization is performing audits and find nothing but “good news” that is not especially noteworthy to leadership.  Things are going along well, according to plan, and there is no identified need for action. When audits find nonconformances or bad news, this is good news to leadership because the audit has identified things that need to be fixed.  

If organizations are either not performing effective audits or no audits at all this is bad news for leadership.  Leadership has no way of knowing if the EMS is performing as planned.  “No news” is bad news.

Audit nonconformance findings are good news and a source of EMS performance improvement.  Audit nonconformances are not evidence of failure or reason to find fault. Doing so will create fear of the audit process within the organizations and increase the difficulty in gaining employees trust and cooperation with the audit process.

To benefit from the results of audits organizations also need to fix the nonconformance problems the audits discover. Performing audits and then being unable to correct the problems discovered is often a bigger problem than not performing audits at all.  An example is an audit of regulatory compliance status that discovers a potential noncompliance.  Uncorrected findings later discovered in a regulatory agency compliance audit could result in enhanced “knowing and willful” criminal penalties.  Finding a potential noncompliance problem and not fixing it is worse than not finding it in the first place. To reduce risk, organizations need to take corrective action on audit findings in a timely fashion.

Some organizations struggle to get traction on their corrective action process for two primary reason.

  • A clear process or workflow for performing corrective action has not been defined and or communicated by the organization.
  • The organization has not established a systematic way to keep track of and report on if and how the nonconformance are being addressed.

WDNR Green Tier Audit Corrective Action Workflows

Corrective action workflows for audit nonconformance should be a team effort.  Teams should follow several sequential steps collaboratively and reach consensus on each stage in the workflow. The last stage of the workflow is verification of effectiveness of the corrective action.

This team approach is similar to the collaborative product design process used by industries to develop products. The design process has desecrate points in the process called gates. Design teams agree that each step was completed before the design process can progress through the gate to the next stage

The purpose of this design review workflow is to ensure the design process is proceeding in a systematic fashion and to minimize the potential for design flaws that will become apparent in the production or use stage of product or service.

Figure 1 is an example of a corrective action workflow with approval gates and stages.

Corrective Action Workflow with QApproval Gates
Corrective Action Workflow with Approval Gates

Gates separate some of the stages in the corrective action workflow.  The number of approval-gates in the corrective action process can vary depending on the organizations’ needs.  Stages in the corrective action workflow can include:

Stage 1 – New (Contain and Assign)

Recognition of the problem is the first step in the corrective action workflow. Recognition can occur as the result of an audit or incident.  How the workflow proceeds after recognition depends on the gravity of the problem or incident encountered.   The team leader or gate keeper needs to quickly decide what type of problem it is such as:

  • Easy to Fix – We understand the problem cause and we can just fix it because it is unlikely to recur
  • Not so easy to fix – We do not fully understand the problem but believe that the cause and solution can be discovered without commitment of substantial resources at this stage.
  • Difficult to fix – This type of problem needs significant resource (horsepower) to address it with skill. 

The preliminary evaluation will determine the size and competencies of the team needed to address the problem.

The team should consider Immediate steps to contain the problem (stop the bleeding) and what that containment should be.  Placing lables and dates on the universal waste containers corrects the audit finding.The person assigned to the corrective action task should not delay implementation.

Stage 2 – Investigate (Cause and Corrective Action)

Cause analysis

Putting a band aid on the problem with a short-term correction alone will not address the underlying problem cause and the nonconformance is likely to recur.   Determining the cause of a problem is necessary to find a solution that fixes the problem and prevents recurrence.  The team should investigate why the problem happened in the first place. 

Root cause analysis is a huge topic and there are many approaches to doing a cause analysis, but sometimes asking “why did that happen?” several times can help identify the underlying cause of the problem (5 why analysis).  Other problems can be more complex and require more horsepower than a 5 why analysis can deliver.  These types of problems may need more sophisticated cause analysis techniques such as Six Sigma (DMAIC), 8 Disciplines (8D) or others.

Corrective Actions

The root cause of the problem helps the team discover an effective corrective action that will prevent the problem from recurring. The team should reach consensus that the proposed corrective action is appropriate to the cause before the corrective action is implemented. This will improve the likelihood that the corrective action will fix the problem in a way that it will not happen again..   

Corrective action solutions that are based on one individual’s perception of the root cause and how to fix that problem often oversimplify both the cause and the solution.  The tendency is for individuals to hurry the process and close the nonconformance as quickly as possible.  This leads to weak root cause analysis which in turn compromises the selection of an appropriate corrective action. 

If the corrective action process is not monitored in a team setting the assignee is more likely to close out the issue (get it off their desk) as soon as possible.  A team approach to the corrective action process that use approval-gates can help avoid this consequence. Approval-gates encourage robust cause analysis.  

The following is an example of poor cause analysis and proposed corrective action for the audit finding that universal waste containers were not properly labeled and dated.

  • Proposed Cause –  “The employee had not been trained in how to properly package and label the universal waste”. 
  • Proposed Corrective Action:  Train the employee in how to properly package and label universal waste. 

This cause analysis simply repeats the finding.  It does not describe why the problem happened in the first place and the proposed corrective action is more of a correction than a corrective action.  Implementing this action will not ensure that the same problem does not happen again.

Root Cause Analysis

Figure 2 shows the results of a more appropriate cause analysis of the universal waste packaging and labeling nonconformance.

Example of 5 Why Cause Analysis
5 WHY Analysis

Once the root cause is identified an appropriate corrective action can be proposed that will prevent it from happening again.

Often there are several options for corrective actions that fix the problem in a way that it does not recur.  Some might have potential to be extremely effective but are costly to implement.  An example might be to outsource the universal waste management to a contractor that comes to the site daily to check that the universal waste is being management correctly.  This is highly effective and can transfer some of the risk of universal waste management, but it is expensive to implement.  Before the corrective action is approved the team needs to decide if the proposed corrective action is appropriate for the cause.

An appropriate corrective action decided by the team for this problem and cause might be something like:

  • Leadership will direct the HR department to develop a training matrix that shows competence required for all jobs including temporary fill in positions.
  • The HR department will develop a process(es) that require(s) employees to demonstrate competence to do a job before the employee can be assigned to that job including temporary fill-in positions.

The team should reach consensus that the proposed corrective action is appropriate for the root cause before it is implemented.  Once approved the actions should be implemented without delay.

Stage 3 – Perform (Corrective Action Implementation)

The team implements the corrective action after it is approved by the team and its leadership.  One individual can implement a simple corrective action quickly. Complex problem solutions may require development of a project plan that assigns team members tasks. Task assignee’s need to accomplished these task by established dates. The team monitors progress on the tasks and periodically reports to the team leaders.

Stage 4 – Verification of Effectiveness

Verification confirms that the agreed upon corrective action was implemented as planned.  It also confirms that the corrective action implemented was effective and fixed the problem in a way that it will not happen again. 

Corrective action verification is usually performed by internal or external auditors during regularly scheduled or other audits.  Others in the organization or on the team can perform the verification but it is important that the verifier be independent to the implementation process or the area where the verification is occurring. 

Stage 5 – Closed

Team can close the corrective action after it has been verified. The team may need to invest additional effort if the verification finds that the corrective action implemented did not fix the problem. The team may need to re-investigate the cause and to re-propose and implement another corrective action.

Communicating and Tracking Corrective Action Status 

A significant stumbling block that organizations sometime encounter when addressing nonconformances is the absence of a method to communicate and track the status of completion of the corrective action.  Information about corrective action status has traditionally been paper based or electronic.  These systems assign a corrective action task to someone to investigate and complete. 

The team leader passes the physical or electronic copy of the corrective form to team member responsible for investigating the cause and proposing a corrective action.  Then the paper or electronic copy is passed to other team members to add information or it is returned to the team leader for review and approval.   

Assignee’s can misplace paper or electronic copies of corrective actions.   Paper-based tracking systems require large three ring binders to store the completed corrective action forms and associated supporting documentation such as pictures or other evidence of completion of the corrective action.  Electronic documents are often individually stored in folders located on the organizations servers or in the cloud.

With paper-based systems, communicating the overall status of corrective actions to leadership requires a labor-intensive process of thumbing through the three ring binders and manually recording the status of the corrective actions.  Individual documents stored on servers or in the cloud have similar problems.  Sorting through individual folders and files takes time to to find important information about the corrective action program.   Use of electronic spreadsheets can help here but create other problems that limit the effectiveness of this solution

Corrective Action Tracking Database Apps

Industry 4.0 revolution will soon fundamentally and significantly change almost all business. This revolution is helping organizations store data optimize equipment and operations using the cloud environment.   Organizations will be able to access enormous amounts of information with a click.  Affordable cloud-based applications that track corrective action progress progress of are now becoming available to all types of businesses. Some of these application are easy to use and allow quick access to trends that inform management decisions.

The heart of these cloud based applications are databases that organize and store information.  They help communicate the status of corrective actions to team members and leadership.  These applications make it easy to monitor the approval-gate process and communicate with team members via automated emailing functions when the status of a corrective action changes or is approaching a due date.  Correcttrack.com is a cloud based application that helps organizations keep track of Green Tier audit findings and improve the effectiveness of the corrective action process.


WDNR requires Green Tier participants to periodically audit their Green Tier EMS.   Audits confirm the organization has established and is operating a “Functionally Equivalent” EMS that results in superior environmental performance.  They are the critical “checking” part of an effective functionally equivalent EMS.  If performed with skill the audit results can provide important information that the organizations leaders need to determine if the EMS is achieving its intended results. 

Ensuring the results of audits are addressed in a timely fashion is critical to an effective EMS.  This is especially true for nonconformance and noncompliance audit findings because findings that go unaddressed or with poor corrective actions increase the risk to organizations than if audits had not been done at all. 

ISO 14001:2015 – What is a “Life Cycle Perspective”?

The term” life cycle” is not new to most, but the use of the term “Life Cycle Perspective” (LCP) in ISO 14001:2015 (2015) is one of the bigger changes in the most recent revision.  Organizations transitioning to the revision must think carefully about how to use a life cycle perspective when planning the transition to the 2015 revision.  2015 requires the use of a life cycle perspective when it states:


6.1.2 Environmental aspects
Within the defined scope of the environmental management system, the organization shall determine the environmental aspects of its activities, products and services that it can control and those that it can influence, and their associated environmental impacts, considering a life cycle perspective.

The previous version of 14001 (2004) only mentioned the term life cycle once in the Annex:

The identification of environmental aspects does not require a detailed life-cycle assessment. Information already developed for regulatory or other purposes may be used in this process

In 2015, the term life cycle appears 18 times, 7 of which are associated with the concept of perspective.  2015 does not explicitly define LCP stopping short and providing only a definition of term “life cycle”:

life cycle

consecutive and interlinked stages of a product (or service) system, from raw material acquisition or generation from natural resources to final disposal

Note 1 to entry: The life cycle stages include acquisition of raw materials, design, production, transportation/delivery, use, end-of-life treatment and final disposal.

[SOURCE: ISO 14044:2006, 3.1, modified ? The words “(or service)” have been added to the definition and Note 1 to entry has been added.]

So the major questions are:

  1. How should organizations use a life cycle perspective when planning its EMS?
  2. What sort of evidence will auditors expect to see to confirm a life cycle perspective was used in planning an EMS?

Using a life cycle perspective when planning an EMS.

The introduction of 2015 provides some insight into what the standard means by Life Cycle Perspective when it states:

A systematic approach to environmental management can provide top management with information to build success over the long term and create options for contributing to sustainable development by controlling or influencing the way the organization’s products and services are designed, manufactured, distributed, consumed and disposed by using a life cycle perspective that can prevent environmental impacts from being unintentionally shifted elsewhere within the life cycle.

This statement suggests the purpose of using a life cycle perspective is to prevent the unintentional transfer of environmental impacts.  In order to do this, organizations need to expand their view of the impacts derived from their product and services beyond the property fence line.  Organizations need to look up their supply chain to understand the environmental impacts caused by their suppliers and those supplying their suppliers.   In doing so, the organization may be able to identify environmental impacts of which they had been previously unaware.  Armed with this new information the organization can then consider what, if any, control or influence they have over these supply chain environmental impacts.

Similarly, organizations will need to look down supply chains to identify environmental impacts that derive from the use of their products or services by their customers and end users. Also, they need to  evaluate their ability to control or influence these impacts..

Once these up chain and down chain impacts have been identified, 2015 expects that organizations endeavor to address the environmental aspects that are causing these impacts where practical.  How the organizations choose to address these life cycle aspects depends on several factors including:

  • the level of risk the aspect presents to the organizations
  • the level of risk the aspect presents to the environment
  • the degree of influence or control the organization has over the aspect

The amount of control or influence organizations have over life cycle aspects depends on:

  • how far up or down the supply chain is the aspect
  • how a design change will affect the performance or cost of the product
  • Who controls the design of the product or service

Organizations should also use a life cycle perspective when they are reviewing the potential environmental impacts and aspects from outsourced processes that are performed by other organizations on its behalf.

Evidence of a Life Cycle Perspective During Audits

Proving to an auditor that a life cycle perspective was used to identify the environmental aspects may be more difficult than actually using a life cycle perspective.  Based on early experience with 2015 certifications it is apparent that the certification community has not yet reached consensus on what and how much evidence is required to show conformance with the life cycle perspective requirements.  At minimum we recommend some discussion of how a Life Cycle Perspective was used perhaps in the high level documentation like an EMS Manual or in the documented procedure how the organizations addressed the requirements of Clause 6 Planning.

A graphic such as the one here describing the various life cycle stages may also be helpful in satisfying auditors need for evidence.Life Cycle Perspective ECSI copyright 2016

Unfortunately, and in the short term there is likely to be much variation between certification bodies and individual auditors regarding what is acceptable evidence of conformance the LCP requirements.  We encourage organizations to have a discussion up front with the auditors before the Stage 1 or transition audit about what the Certification Body (CB) and auditor will be looking for when collecting evidence that a LCP has been used in the EMS.

ISO 14001 Continual Improvement Survey 2013 Results

ISO recently published the results of a survey questionnaire circulated last year to the international community .  The purpose of the survey was to help guide the ISO technical committee (TC 207) revision of ISO 14001 scheduled to be released next year.  The survey reached over 5000 organizations or individuals in 110 countries worldwide.  57% of the respondents were in Europe with only 17% responding from North America.  54% of those responding were actual users of the standard such as industries and 45% were either consultants, certification bodies performing audits or other types of organizations.

The survey asked questions about the perceived value of ISO 14001 to Environmental Management and Business Management.  The areas where ISO 14001 was thought to be most valuable were:

  • Ability to meet legal requirements
  • Environmental performance improvement

The areas where ISO 14001 was thought to be of least value were:

  • Providing financial benefit
  • Improvement in supplier environmental performance

The overall average percent of very high to high value responses was 54% with only an average of 15% recording a perceived low or no value for all areas.  This suggests that participants have a generally positive opinion of the value of ISO 14001.

Value of ISO 14001

One  of the puzzling results of the survey was over 75% of respondents rated  ISO 14001 very high or high in its value  for environmental performance improvement but only about 25% believe that the standard provides a significant financial benefit.  Apparently survey respondents do not believe that investing in ISO 14001 as a way to reduce waste and resource use will provide an acceptable  return on investment.

Another surprising result is that almost 70% of respondents rated meeting stakeholder requirements as very high or high but only 27% believe that ISO 14001 has very high or high value when it comes to improving supplier environmental performance.  It’s difficult to tell from the data what survey respondents were thinking when they read “stakeholders”, but in my opinion there is a good chance they were thinking about their customers that require them to have an ISO 14001 EMS.  If 70% believe ISO 14001 improves performance and 60% implemented ISO 14001 to satisfy a customer requirement why are they not making the connection that the purpose of them being required to have an ISO 14001 is a result of their customers’ efforts to influence the environmental performance of their suppliers?

Thanks to Dr. Lisa Greenwood, Lecturer in Environmental Sustainability, Health and Safety at Rochester Institute of Technology for leading the evaluation of the survey. Here are links to documents evaluating the survey responses:

ISO 14001 Survey 2013 – Final Report and Analysis

ISO 14001 Survey 2013  – Summary Report

ISO 14001Revision and ISO Annex SL – Elegant Simplicity or Redundant Complexity?

Being part of the ISO14001 revision process is fascinating. The technical advisory group (TAG) here in the USA of which I am an active member met in New Orleans late last month and I participated in the ISO 1400:201x revision process. There are likely to be significant changes to the ISO 14001 as it is aligned with something called the High Level Structure (HLS). ISO has decided that all new and revised standards will be organized in accordance with the HLS and ISO 14001 is the first major standard to go through the revision process under the HLS mandate. The revision to the standard is expected to be issued in final form in early 2015.

Under the HLS, ISO 14001 will go from 4 sections to 10. Even with six additional sections there is simplicity to the HLS that I find appealing. The HLS elegantly walks an organization through the steps needed to implement and operate any type of management system whether it’s environmental, health and safety, quality or even food safety.

Some participants in the revision process believe that a major obstacle  is that the International Organizations for Standardization (IOS) has imposed strict limitations prohibiting deletion of any of the HLS text. Text can only add where needed to make the HLS work for environmental management. There are two schools of thought on how to make the HLS work for an EMS. So far the group has used an approach where the old ISO 14001:2004 is dismantled and each section is inserted into a section of the HLS where it seems to be appropriate. The core HSL is only about 9 pages long. The approach currently being used by the TAG, to add text to the HLS from ISO 14001, has resulted in a document that is over double the length (19 pages not including the Annex).

Another emerging “less is more” approach to the ISO 14001 revision leaves the HLS mostly as it is with only subtle changes. EMS specific issues are addressed largely in Annex A. The only requirement imposed by the IOS regarding the content of the Annex is as that:

“The additional text given in this Annex is strictly informative and is intended to prevent misinterpretation of the requirements contained in this International Standard. While this information addresses and is consistent with the requirements, it is not intended to add to, subtract from, or in any way modify these requirements”.

Using this “less is more” approach solves some of the current problems with proposed revisions to the standard. It will reduce the potential problem of increased complexity and redundancy. The US TAG will continue to meet over the next few weeks to determine what the TAG experts will present as recommendations at the next international meeting of the ISO 14001 Technical Committee June 24-28, 2013 in Gaborone, Botswana. If you are interested in learning more Annex SL is where you can find the core HLS text. Look in Appendix A of Annex SL.


Future Challenges for ISO 14001: ISO Continual Improvement Survey (2013)

As you may already know, the ISO 14001 environmental management systems (EMS) standard is currently being revised, considering future challenges for EMS and continual improvementThe International Organization for Standardization (ISO) recently launched an ISO 14001 continual improvement survey to develop an understanding of the needs of current, past and potential users and other knowledgeable interested parties in relation to EMS standards.  The survey takes into account key topics from the ongoing discussions in the working group that is revising ISO 14001, and the results will be used to inform the ongoing revision.

Your views on these key topics and opportunities for improvement are extremely important, in order that the results truly represent the thinking of the users of the standard and other knowledgeable interested parties, including those in the US.  Please follow the link below to participate in the survey.

ISO 14001 continual improvement survey 2013

The survey will take approximately 20 minutes to complete.   All responses will be confidential, and individual respondents will not be identified.  Overall results will be made available to interested parties upon request, as indicated on the final page of the survey.

If you have questions concerning the distribution of the survey or participation in the standards revision process, please contact the American Society for Quality Standards Group at standards@asq.org.  General questions regarding survey participation or distribution of results may be directed to the ISO Central Secretariat at central@iso.org.

Thank you very much for your assistance.


Lisa Greenwood and Kevin Lehner

US Technical Advisory Group to ISO TC 207 – Environmental Management

ISO 14001:201X Revisions Underway

The ISO 14001 revision process is in full swing. It has been underway now for almost a year and the US Technical Advisory Group (TAG) is currently working on the third committee draft of this popular international standard. In August 2012 we traveled to Washington DC to attend the semiannual meeting of the US TAG where the US team discussed the new compressive reorganization of the ISO 14001 revision required by something called the High Level Structure or Annex SL.

Both ISO 14001 and ISO 9001 will follow the new outline during their revision process. For ISO 14001 wonks out there who really want to get into the weeds on the reorganization of ISO 14001 here is a link to the Annex SL. The text of the HLS is at the end of the document.

Since the August DC meeting a core group of the TAG members has been meeting weekly to prepare comments on the current revision working draft (N_073_ISO_14001_ (E) WD3). The massive reorganization of the standard is the most significant difference people will notice right away when the revised standard in finally issued within the next 12-18 months. Here is a peak at the new high level structure that will be the framework of the ISO 14001:201X revision

Clause 1 – Scope

Clause 2 – Normative references

Clause 3 – Terms and definitions

Clause 4 – Context of the organization

Clause 5 – Leadership

Clause 6 – Planning

Clause 7 – Support

Clause 8 – Operation

Clause 9 – Performance evaluation

Clause 10 – Improvement

Our initial focus was on trying to fit the existing content of ISO 14001:2004 into the new structure. There are areas that fit well and others that don’t. More recently much effort has been invested by the core group discussing revisions to important definitions like “requirement”, “conformity” and “non-conformity”.

One of the additions to the standard we recommended was to include a new definition of the term “Significant Environmental Aspects” (see related post).

Participation on the TAG is rewarding but not without expense. Trips to DC, New Orleans, Sweden, and Botswana to promote the US position are investments in helping make the standard better for everyone. If you or your organizations would like to help support this important work we would welcome your assistance in anyway. You can email us at: ecsi14001tag@envcompsys.com or call me (Kevin Lehner) directly at 920-648-4134.


Revision to ISO 14001:2004 – Defining Significant Environmental Aspects/Impacts – Sense and Semantics

Over the last two decades practicing as an ISO 14001 auditor, consultant, and teacher, I have found that many individuals and organizations misunderstand the intent and meaning of the terms “significant environmental aspect” and “significant environmental impact.”  With the revision to ISO 14001:2004 well under way, perhaps now is a good time to attempt introducing language or definitions into ISO 14001:201x that will help individuals and organizations better understand the term “significant”, and the distinction between the terms “aspect,” and “impact.”   Such clarity would enable individuals and organizations to better interpret  what exactly must be done according to the standard. This confusion in meaning is understandable because, at least in the English language, there are several definitions or “senses” or “subsenses (meanings in specific contexts) of the term “significant.”  The senses or subsenses that are applicable within the context of ISO 14001 can be found in the MerriamWebster Collegiate Dictionary (Tenth Addition) as follows:

2   a: having or likely to have influence or effect:  IMPORTANT  <a significant piece of legislation>;    also: of a noticeably or measurably large amount <a significant number of layoffs> <producing significant profits>

In order to fully comprehend this definition, you need to refer to the Explanatory Chart and Explanatory Notes at the beginning of the dictionary, which describe the meaning of the numbers (2), something called a “sense number”; the small letters (a), which are “sense letters”; the colon (:), which is used to separate two or more definitions of a single sense; and the italicized word “also,” which is called a “sense divider” and is used to introduce a meaning that is closely related to but may be considered less important than the preceding sense.  If a capitalized word is used to define a sense of the word, that capitalized word, in this case IMPORTANT, is defined as a synonym of the term being defined.

The sense number 2 definition of the term “significant” has several subsenses with different meanings.  One of these subsenses means “important.”  The other means “a noticeably or measurably large amount.”   What has happened over the years with the interpretation of ISO 14001 is that many individuals and organizations have applied only the second subsense of the term “a noticeably or measurably large amount,” when they are determining which environmental aspects they consider significant.  They ignore the other, and arguably more important, subsense of the term  “IMPORTANT.”

The effect on an organization’s Environmental Management System of only considering the part of the definition of “significant” that means “a noticeably or measurably large amount“ has been that an organization typically excludes from its list of significant environmental aspects those that are “important” to them for  reasons other than their being “a noticeably or measurably large amount”. This typically includes environmental aspects for which the organization has established operational controls (work instructions) to ensure that the environmental impact of the significant environmental aspect is controlled to the level desired by the organization.  

An example might be waste light bulbs, batteries, and other electronic waste.  Although most organizations have procedures for ensuring that these wastes are properly recycled (work instructions or procedures), many do not identify these wastes as significant environmental aspects because they believe the presence of the operational control has reduced the potential impact from these wastes to a point where they do not constitute a  “noticeably large amount.”   They do not apply the other subsense of the word “significant” with the meaning “important.”  Proper management of waste light bulbs is obviously important to the organizations because they have established a procedure (operational control) for ensuring that they are managed in a certain way. 

The unfortunate consequence of not including waste light bulbs as a significant environmental aspect is that this important environmental aspect  then becomes transparent to the management system.  The organization’s performance toward ensuring that waste light bulbs are managed correctly is not routinely measured or audited during internal or other system audits. 

To correct this problem the US TAG should consider adding the following definitions to ISO 14001:201x:

3.xx significant environmental aspect The cause of a significant environmental impact

3.xx significant environmental impact The potential or actual environmental effect or risk caused by a significant environmental aspect that an organization intends to manage or is managing through operational controls and/or environmental objectives, targets, and programs

The definition of significant environmental impact above includes reference to “risk,” which is meant to address the risk to the organization, including potential regulatory noncompliance.  The result of including the word “risk” in the definition is that organizations controlling  an environmental aspect to manage a potential risk of noncompliance will need to identify that environmental aspect as “significant.” Close attention should also be paid to the way in which the terms “significant environmental aspect” and “significant environmental impact” are used in the standard to avoid confusion between these terms.  The use of the term significant environmental impact” should be limited compared to the use of the term significant environmental aspect.  The term significant environmental impact should be used only in the section of ISO 14001:201x addressing identification of environmental aspects.

Kevin A. Lehner, EMS-LA, CHMM – January 11, 2013