Category Archives: ISO 14001

ISO 14001 Topics

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

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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:

Perspective

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”:

3.3.3
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

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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.

Revision to ISO 14001:201x Moving Forward

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As a member of the US Technical Advisory Group to ISO 14001 I traveled to Washington DC recently to attend meetings of the US TAG (TC 207).  Although TAG members are sworn to secrecy to help protect the US negotiating position on key issues I can say that the next version of the standard is likely to be unrecognizable in its form.  This is due to a big change at ISO headquarters compelling all standards revisions to conform to a new format called the “High Level Structure” or HLS.  What this means is that the ISO 14001 standard will be dramatically rearranged to fit neatly into a format that ISO believes will facilitate better understanding of the intent of each standards requirements.

ISO believes that all standards should have a uniform format so the current work of TC 207 is to disassemble the existing ISO 14001:2004 standard and reassemble it within this new structure.  If you are interested you can see what the HLS looks like here.

The other changes to the standard are not expected to include new requirements.  There are however areas where the US TAG is working to clarify the intent of the standard.  These areas include revised language on how organizations decide what their EMS will manage (significant environmental aspects) and the need to continue to include preventive action as a separate activity in the EMS.

The international ISO 14001 group is meeting in Rochester NY later this month when the US TAG will present its ISO 14001 revision proposal.  It will be interesting to see what comes out of Rochester and what the rest of the international community is thinking about how to align the current version of ISO 14001 with the MLS.

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 …..

Tips For Environmental Aspect Identifcation

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Most organizations embarking on the EMS implementation process greatly underestimate the level of competence needed to do a good job in identifying environmental aspects, impacts and deciding which are significant. It’s sort of like landing an airplane. If you have never done it before the outcome can be a disaster.

The result of inept aspect identification will inevitably be an ineffective EMS. Do yourself and your organizations a favor and get professional help from someone who has done it many times. There are a zillion mediocre EMS consultants that will charge much and deliver little. Do your home work and check their references before you invest in their assistance.

Also, there are serious drawbacks to using a risk based approach to determining which environmental aspects are significant. A better outcome and more effective EMS will be achieved by establishing significance criteria (filters) for aspects such as:

1. Is the aspect regulated?

2. Is there potential for a significant impact from an unplanned release?

3. Are their other interested parties that care about the aspect like neighbors?

4. Is it costing lots of money to manage the aspect?

5. Is the scale or duration of the impact such that we should manage the aspect?

If an aspect is found to meet one of the criteria (gets caught on one of the filters) it should be considered significant or important to the organization and managed by the EMS (controlled, improved or both). If it passes all of the filters it should be considered insignificant or irrelevant to the organizations and ignored by the EMS.