Category Archives: ISO 14001

ISO 14001 Topics

ISO 14001:2026 – An Opportunity for Change

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Introduction

ISO 14001 is the most popular environmental management system standard in the world. There are over 1.2 million facilities certified to this globally recognized standard. Many other organizations are using ISO 14001 as a model for their EMS but have not yet sought certification. The revision of ISO 14001 in April of 2026 offers an opportunity for organizations. Older legacy EMS should be to reviewed and updated periodically to better manage risk.

The ISO 14001:2026 update made no material changes to the basic requirements of the standard. The revision did, however, clarify some important requirements, especially in Clause 6 on Planning. The restructuring of this section helps organizations improve processes for environmental risk management. The restructuring also helps certification body and other auditors better understand what ISO intends for this clause of the standard.

Clause 6 is important because it determines what the environmental management system is going to manage (environmental aspects). Results of planning help everyone using the EMS understand what environmental risks are important to the organization. Planning also helps users of the EMS understand what actions the organization is taking to control environmental aspects and impacts.

Better Understanding of Environmental Aspect and Risk

Environmental aspects cause risk or environmental impact. Reducing risk of environmental impact is the primary outcome that an ISO 14001 EMS should achieve. Clause 6 on planning has been ambiguous about the relationship between risk(s), opportunities, aspects, impacts. This leavins it up to the organizations to interpret the requirements when planning the EMS.

This ambiguity has led to a wide variety of approaches to identifying environmental aspects and determining which are significant. Although these approaches technically meet the requirements of ISO 14001 they are marginally effective in controlling risk from aspects. The ISO 14001:2026 revision helps users gain a better understanding of environmental aspects, impacts, risks and opportunities.

ISO 14001 requires that organizations identify significant environmental aspects and to address risk and opportunity associated with these environmental aspects. However, the standard provides little guidance on why organizations need to identify some environmental aspects as significant. The standard is also unclear about what to do differently with significant aspects than with those that are not significant. This approach allows organizations flexibility to meet the requirement of this part of the ISO 14001 standard. However, this flexibility has led to a wide range of approaches to identifying significant environmental aspects, impacts, risks, and opportunities.

Clause 6 From an Auditors Perspective

Some conformant legacy EMS process identify only a few environmental aspects and only 1 that is significant. Others are complex Failure Mode Effects Analysis (FMEA) type methods. Some with 7 or more factors used to calculate a Risk Priority Number (RPN). Often the FMEA has an arbitrary RPN cutoff value that limits the number of significant aspects.

Although these approaches met the basic requirements of ISO 14001, they often did not help organizations identify what was important. If the planning part of the EMS is weak the rest of the management system suffers. This is because the rest of the EMS relies heavily on the output of clause 6 planning.

ISO 14001:2026 revisions in clause 6 used a three bucket concept. The standard reordered the sequent of clauses to focuses on environmental aspects as a priority (Bucket-1). Bucket 2 are compliance obligations and Bucket 3 are risk and opportunities. See Figure 1.

Figure 1 – Three Bucket Concept

The following example of cheese making illustrates one approach to identify environmental aspects, impacts, determine which are significant. The case study describes how organizations can determine actions needed to address environmental risk and opportunities. It also provides information on how the ISO 14001:2026 EMS planning supports other parts of the EMS including auditing.

Process Flow Diagrams Aid Aspect Identification

Most organizations have systematic processes that add value and help organizations generate revenue. Often these processes have environmental aspects and impacts. Mapping the process flow is the first step in identifying environmental aspects. In manufacturing, businesses use inputs, like raw materials and energy in a sequence of processes that change these raw materials into something with more value that the organization can sell to customers.

Developing a process flow diagram of the manufacturing process is a critical step in aspect identification. Figure 2 is an example of a cheese making process flow diagram.   Raw milk is one of the inputs into the process. The cheese making process changes milk into cheese through a sequence of steps. The result of the process in cheese ready for sale to customers.

Figure 2 – Cheese Manufacturing – Whey Environmental Aspect

Waste whey is an output of the curdling and molding processes. If mismanaged it can have a significant water pollution environmental impact. To avoid fines and damage to the company’s brand risk of noncompliance from mismanagement of waste whey should be addressed by the company

The cheese making process has many other environmental aspects that may be significant like the use of cleaning chemicals and potential emissions of pollutants into the air. The first step in the Clause 6 planning process is to create an inventory of environmental aspects.

Use a process flow diagram like the one in figure 1 to identify environmental aspects.   Include someone with knowledge of environmental impacts are for the cheese making process. Once you have an inventory you can begin to evaluate them for importance using risk assessment techniques.

Deciding What Is Important

ISO 14001 requires organization’s determine what environmental aspects are important (significant) and thereby need to be addressed.

“The organization shall determine those aspects that have or can have a significant environmental impact (i.e. significant environmental aspects) by using established criteria.”

Risk assessment should be used to determine which environmental aspects are important and need to be controlled or improved. However, risk assessment can be subjective and imprecise. There are many approaches to performing risk assessment. The key is to not make it overly complicated. Keep it simple.

Figure 3 is an example of a simple risk matrix you can use to estimate relative risk based on likelihood and severity.

Figure 3 – 5×5 Risk Analysis Matrix – CorrectTrack.com

Across the top of the matrix are values for the likelihood that an aspect will have an impact on the environment.  The likelihood values in the top row increase from left to right, not likely (Value of 1) to Very likely with a (value of 5).  The Severity values along the left side of the matrix are similar with Low (1) at the bottom and Very High (5) at the top.

Use the matrix to estimate risk. Start by assuming that there are no existing controls to manage the risk of environmental impact even if you do have exiting controls in place. Pick a value along the Severity axis that you think is reasonable (1-5). Then pick a value along the Likelihood axis that you think is reasonable using the 1-5 scale. Multiply these 2 values together to give the estimated risk value. A group is often better at estimating these values than one individual alone. Also include an environmental professional with some risk assessment experience to guide the risk assessment process.

Significant Environmental Aspects

When making cheese, enzymes are added to the milk to help the milk coagulate into cheeses curds.  The enzymes come in returnable containers, and the likelihood is low and severity of an impact from adding enzyme is low. The risk score is calculated by multiplying the likelihood times the severity which gives a risk value of 1 which is low and represented by the color green on the matrix.

The generation of waste whey from the milk curdling process is highly likely (5) on the matrix because it happens every day that cheese is being made. The impact of improper disposal of waste whey is either high (4) or very high also (5). The combined estimated risk is calculated to be either 15 or 25 (high or very high) color red. This uncontrolled risk score helps in prioritizing environmental aspects for risk control   Figure 4 is an example of a prioritized aspect list.

Figure 4 – Prioritized Aspect List for Cheese Making

Good Planning Equals Good Audits

Skillful planning helps ensure good audits. Good audits provide critical information to leadership and others about the performance of the EMS and its ability to control risk to the organization. A well-planned EMS links environmental risk to the controls established to address the risk. This linkage is like a breadcrumb auditors can follow to check that the environmental risk is being addressed and the control is effective.

Breadcrumbs for Audits

A good example is Used Oil Management. Some of the equipment in the cheese factory is lubricated with petroleum oil. This oil needs to be changed by the maintenance department from time to time to protect the equipment moving parts from excessive wear. Without adequate controls used oil can be mismanaged and dumped on the ground, in sewers and storm drains causing significant environmental impact.

The likelihood and severity of environmental impact is high if used oil is mismanaged. Used oil is also regulated by government agencies and organizations and its leadership risk fines and even criminal penalties if waste oil is mismanaged.

To ensure that risk from the aspect of used oil is minimized organizations can establish several controls including Spill Prevention Control and Countermeasures Plans, secondary containment of used oil drums and tanks, and documented work instructions. By connecting the environmental aspect of used oil to these controls the auditor can quickly confirm what controls need to be in place and if those controls are effective. Audits would check that the SPCC Plan and the used oil work instructions are being followed.

Hierarchy of Control (HOC)

EMS Planning includes consideration of what actions can control environmental risk. Risk controls take several different forms, and not all are equally effective.  One method for determining the effectiveness of risk control is the Hierarchy of Controls (HOC).  HOC is based on the concept that some types of control are more effective at reducing risk than others. In the HOC “Elimination” is one of the methods to control risk.

If a cheese factory is able to eliminate the process that generates the whey waste the risk of that aspect is also eliminated and the risk score goes from 25 to 0. Figure 5 is a version of the HOC used to calculate the effectiveness of a particular type of operational control Engineering controls reduce risk by 60% and administrative controls by 40% and so on.

Figure 5 – Hierarchy of Risk Control – CorrectTrack

Layers of Protection (LOP)

Another important concept of risk control is Layers of Protection. If we apply several different controls to the aspect of Waste Whey we can reduce risk from this aspect significantly.The calculated uncontrolled risk score for waste whey at 25 (Very High). We can use an engineering control (treat the wastewater before discharge). This will reduce that risk score by 60% down from 20 to 8 (20 x .4=8). This reduced value is the residual or remaining risk before any additional control.

A risk value of 8 for the aspect is still high (orange). Another layer of protection is desirable to reduce the risk further. The organization needs to be maintain the wastewater treatment process. Leadership should confirm that treatment plant operators are competent to ensure the treatment is done properly. Training and competence are a form of administrative operational control in the Hierarchy of Control (See Figure 3).

Appetite for Risk

This additional layer of protection reduces the risidual risk to 4.8. Depending on the organization’s appetites for risk, this value may be low enough. Leadership should review and confirm risk to the organization is managed adequately. Repeating this process for all other environmental aspects ensures that risk is assessed and addressed to an acceptable level.

Tying It Altogether

The ISO 14001:2026 revision emphasized the importance of clause 6 and good planning. The intent is to encourage organizations to review their planning process. Organizations with a legacy EMS will benefit from reviewing the planning parts of their EMS. Important questions to ask during this review are:

  • Was a process flow diagram or something similar consulted during the aspect identification process?
  • Are risk assessment processes used based on likelihood and severity of impact?
  • Were aspects with higher risk values prioritized for action?
  • Does the risk assessment process consider the hierarchy of controls when deciding if risk had been adequately addressed?
  • Has linkage between the environmental aspects and the actions taken to control risk been documented?

Answering yes means the planning part meets the requirements of ISO 14001:2026 and is addressing environmental risk. If not maybe now is a good time to make some changes to the planning process.

About the Author:

Kevin Lehner is a senior member of the ANSI US technical Advisory Groups for ISO 14001, 45001 and ANSI Z10.  He is leading the international group establishing a new guidance standard in the ISO 14002 series on using ISO 14001 to address environmental topic areas.  He is a certified ISO management systems lead auditor performing frequent ISO audits for ECSI audit clients.  He also is a frequent instructor for ISO 14001, 9001 and 45001, auditor and lead auditor Exemplar Global certified courses.

Big 3 Standards Now Under Revision – What You Need to Know

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The 3 big ISO standards are now under revision. ISO 14001, 45001 and 9001 are being reviewed and revised simultaneously.  Recently, ECSI attended meetings of the US Technical Advisory Groups (TAG) for both ISO 14001, and 9001 in Washington DC where the upcoming revisions were discussed. We have also been participating in the US TAG to ISO 45001 and in meetings discussing revisions to that standard.

The revised standards will be released in a few years when organizations will be need to conform with the revisions. The following is a brief discussion of what to expect for revisions to each standard.

ISO 14001

ISO 14001 was first published in 1996.  Since then, it has been revised twice. Once in 2004 and again in 2015.  The 2015 revision incorporated a major change. This change involved converting the entire standard to the ISO High Level Structure (HLS).  Although the revision will not introduce new requirements, it may make changes to clarify some of the key requirements such as the relationship between risk and opportunity and significant environmental aspects.

The revision will integrate changes to the HLS and address concerns raised by users of the standard over the past 9 years.   Initially the ISO 14001 revision committee considered issuing an amendment with the few HLS changes.  The committee thought that this would be easier and take less time than a full revision.  The committee was also concerned about opening the standard up to a broader revision that could result in additional requirements.

Recently however, the committee discovered that the amendment option has significant drawbacks making it an unlikely choice.  The amendment route would have resulted in issuance of a separate 28 plus page document to be used with the current 2015 version of the standard.  Users would have to reference 2 different documents when using the new amended standard.  The committee is looking at other amendment options, but it appears the only way to avoid the 2 document problem is to do a full revision and then issue a single revision document.

If a full revision does occur, it provides more opportunity to address sections of the standard that have caused confusion for users.  Additionally, it creates an opportunity to take advantage of changes in the HLS that offer flexibility when using the term “risk and opportunity” in the planning section of the standard.

ISO 45001

The committee revising ISO 45001 has decided to do a full revision instead of just a limited amendment.  This option avoids the 2 document problem created by the amendment route and gives the committee greater flexibility in what can be changed. This includes clarifying and streamlining parts of the standard that users have found confusing and redundant.

Clause 6 (Planning) is one of the parts that has potential for improvement to make it more user friendly for small and medium sized organizations.  Clause 6 of the standard in the current version was over 1100 words and three pages in length.  One proposal being circulated for the revision by the committee would dramatically reduce the text by two thirds to only 318 words and 1 page.

There is also a proposal to refer to “OHS Hazard Risk” when describing what the OHSMS is supposed to be managing. It is thought that this may help reduce misuse of the terms “Risk” and “Hazard” interchangeably.

ISO 9001

The ISO 9001 committee has also chosen the full revision route.  However, the committee is taking a more aggressive posture when deviating from the HLS.  For over a decade ISO headquarters has insisted that it will not allow deviations from the HLS text for any of the standards.  The ISO 9001 revision committee wants to exclude certain new requirements introduced by the updated HLS.

The committee believes the new HLS requirement about climate change is not applicable to a quality management system. Although the committee believes that climate change consideration is important, they believe including it as a requirement in 9001 is inappropriate.

Conclusion

The revision of the three big ISO standards is not expected to result in new significant or reorganization of the standards.  The revisions are more likely to improve the standards by reducing unnecessary text and eliminating redundant requirements.  Organizations who meet the requirements of the current ISO standards should not need to make big changes to their Environmental, Occupational Health and Safety (OHS) and Quality management systems.  The revisions will also make these standards more accessible to small and medium sized businesses around the globe.

URGENT ALERT – ISO Climate Change Amendments!

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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.

ISO 14001 Continual Improvement Survey 2013 Results

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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?

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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)

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As you may already know, the ISO 14001 environmental management systems (EMS) standard is currently being revised, considering future challenges for EMS and continual improvement.  The 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.

Sincerely,

Lisa Greenwood and Kevin Lehner

US Technical Advisory Group to ISO TC 207 – Environmental Management

ISO 14001:201X Revisions Underway

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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

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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

A True Story – Why ISO 14001 Works

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Background

It has been over seven years since we first began helping a medium sized automotive equipment manufacturer in the midwest implement a company wide ISO 14001 EMS. They were getting pressure from their customers to prove they were good environmental performers and an ISO 14001 certificate was the best solution. We helped them with environmental aspects, setting up the EMS and identifying regulatory compliance requirements. As we were completing the project we performed a round of internal audits to check that each facility was complying with the applicable  legal requirements.

The Audit Finding

One of the findings of our compliance audit was that at one location, the company was operating unpermitted production painting equipment. The audit team could find no records of correspondence with the State permitting authority about this new equipment. It had been commissioned sometime after an initial Title V permit application had been prepared for the facility. The paint operation was an important part of the manufacturing process and it was not possible to simply shut the process down. Doing so would have resulted in delayed shipment of product and dissatisfied customers.

The Response

Although the discovery of this potential noncompliance was uncomfortable news for the organization, at least they now had a better picture of the potential risks they were facing. They examined the process closely and decided that it was time to upgrade. They worked it out with the state permitting authority to replace the old system with a new more efficient paint system.

Fast Forward

Over the last several years we have continued to perform periodic EH&S compliance, ISO 14001, and OHSAS 18001 internal audits to support their continued certification to these standards.. During a recent compliance audit at one of the facilities we were delighted to see a new process being installed. It means the company continues to grow but, from an auditors perspective, the stack ducting through the roof becomes a great opportunity to check the EMS effectiveness to control noncompliance risk. As we walked by the new process I could see the auditee cracking a half smile as I asked a few questions about the new equipment and construction underway. He knew where this audit was going.

The audit was actually a combined one-day environmental and OSHA compliance audit so we had a lot of ground to cover in 8 hours. When the audit schedule called for review of compliance with state air emission permits, I asked what they knew about the potential emission from the new process. The audtee said “the process had the potential to emit a hazardous air pollutant at levels requiring permitting before installation of the equipment”.  The auditee then produced the construction permit they had been issued by the state?  The EMS had worked to help the organization identify the need to obtain a permit, well in advance of beginning construction on the new process.

Results Matter

Discovery of unpermitted emission sources during internal and compliance audits is not uncommon for us even today. Helping organizations identify and manage risks of noncompliance in the short term provides some satisfaction in our work. But having the opportunity to see the results of an effective EMS that we helped implement and, how that EMS has helped manage risks long term, is particularly gratifying.

Skepticism of the benefits of ISO 14001 will continue to linger especially with the uniformed. However, organizations interested in managing environmental risk and becoming more sustainable need to understand how the audit processes, embedded in ISO 14001, can be used to support an organizations sustainability efforts, promote successful outcomes and provide confidence by other stakeholder that environmentally, things are as they should be.

ISO 14001 and Shared Operational Permits.

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Sometimes organizations share environmental permits with other organizations.  

This is a common situation with many large industrial operations where several plants are contiguous, use a common wastewater treatment facility or obtain energy from other parts of the organization where it is generated. The key is to carefully define the Scope of the EMS to only include those activities that are under the direct control of the organization implementing the EMS.

One of our clients in the paper industry has a similar situation. They are leasing a portion of a large paper making complex to make something called paperboard. Portions of the leased property are covered under the landlords Tier 1 NPDES Storm Water Discharge Permit and addressed in the SWPPP. The landlord has stipulated in the lease agreement that our client needs to comply with the terms of the SWPPP and we incorporated the conditions of the SWPPP that apply into the EMS as an “other requirement”.

The organizations is certified by an ANAB accredited Certification Body which has accepted our interpretation of the SWPPP as an “other legal requirement”. Again the real key here is to carefully define the Scope of the EMS (4.1) to limit it to the physical areas and process that the organization can control.

Also see – 4.3.1 a) to identify the environmental aspects of its activities, products and services within the defined scope of the environmental management system that it can control and those that it can influence …..