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.


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About Kevin Lehner

Kevin has been president of ECSI for over 25 years. His practice focuses on environmental and health and safety management systems training, consulting and auditing. He is an active member of the US Technical Advisory Committees to ISO 14001 and ISO 45001. He represents that USA at international meetings of these committees. He is also the lead developer of the CorrectTrack corrective action tracking app.