Changes to ISO 14001 2015 in Plain Language

Paul MacLean, M.SC., EP(CEA), EP(EMSLA), PBAS

President and Founder

• In business since 1993• More than 100 active clients• 12 bilingual consultants• Headquartered in Montreal• Work mainly in Quebec and Canada, with projects in the U.S., Africa, Asia,

Europe, and Latin America • Sectors:

- Mining & Metals- Aboriginal / First Nations- Aerospace- Energy

- Infrastructure & Construction

- Manufacturing- Media- Waste management- Government

- Pharmaceuticals- Printing- Tourism & Events- Non-profit Organizations- Education

OUR SERVICES

CSR STRATEGY COMMUNITIES ENVIRONMENT

• Assessment and Planning of the Approach

• Embedding

• Performance Evaluation

• Communication and Reporting

• Social Impact Assessment

• Community Relations

• Participatory Planning and Development

• Socio-economic Studies

• Management System for Environment, Health and Safety (EHS)

• Regulatory Support

• Outsourcing of Resources

• Evaluation and Miscellaneous Analyses of Environmental Impacts

CHANGES TO ISO 14001

A review and explanation of changes to the ISO 14001

standard, based on the July 2015 FDIS, and how it may

affect EMS based on ISO 14001:2004.

New document structure of ISO standards Broader definition of the environment

• Stronger commitment and leadership from top management• Improved understanding of organizational context and

stakeholders• Management of both risks and opportunities• More emphasis on objectives and performance indicators • Lifecycle thinking in determining what to manage, including

externalised processes

KEY CHANGES IN THE REVISED ISO 14001 STANDARD

• Integration of the management system into core business processes

• Risk management approach• Actions based on lifecycle thinking• Improved sustainability performance from a

comprehensive understanding of the business context and stakeholder expectations

HIGH LEVEL STRUCTURE FOR ALL ISO MANAGEMENT SYSTEM STANDARDS

OBJECTIVE

• A common framework of 10 clauses with core text unchanged

• Additional sub-clauses and domain-specifictext


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

4. Context of the organization

5. Leadership

6. Planning

7. Support8. Operation

9. Performance evaluation

10. Improvement

10.2 Nonconformity and corrective action

10.3 Continual improvement

4.1 Understanding the organization and its context

4.2 Understanding the needs and expectations of interested parties

4.3 Determining the scope of the environmental management system

4.4 Environmental management system

5.1 Leadership and commitment5.2 Environmental policy5.3 Organizational roles,

responsibilities and authorities

6.1 Actions to address risks and opportunities

6.2 Environmental objectives and planning to achieve them

7.1 Resources7.2 Competence7.3 Awareness7.4 Communication7.5 Documented information

8.1 Operational planning and control

8.2 Emergency preparedness and response

9.1 Monitoring, measurement, analysis and evaluation

9.2 Internal audit9.3 Management review


COMPARATIVE TABLE OF CLAUSES AND SUB-CLAUSES

4. Context of the organization4.1 Understanding the organization and its context4.2 Understanding the needs and expectations of interested

parties

6.1 Actions to address risks and opportunities6.1.1 General

4. Environmental management system requirements (title only)

4.1 General requirements4.3 Determining the scope of the environmental

management system4.4 Environmental management system

5. Leadership (title only)

5.1 Leadership and commitment

4.2 Environmental policy 5.2 Environmental policy

6. Planning (title only)4.3 Planning (title only)

4.3.1 Environmental aspects 6.1.2 Environmental aspects

4.3.2 Legal and other requirements 6.1.3 Compliance obligations

6.1.4 Planning action

ISO 14001:2004 ISO/DIS 14001:2015

KeyGREEN = equivalent 2015 sectionsBLUE = new 2015 sections

ISO 14001:2004 ISO/DIS 14001:2015 6.2 Environmental objectives and planning to achieve them

(title only)6.2.1 Environmental objectives6.2.2 Planning actions to achieve environmental objectives

4.4 Implementation and operation (title only)7. Support (title only)8. Operation (title only)

4.4.1 Resources, roles, responsibility and authority7.1 Resources5.3 Organizational roles, responsibilities and authorities

4.4.2 Competence, training and awareness7.2 Competence7.3 Awareness

4.4.3 Communication

7.4 Communication (title only)7.4.1 General7.4.2 Internal communication7.4.3 External communication

4.3.3 Objectives, targets and programme(s)

4.4.4 Documentation7.5 Documented information (title only)7.5.1 General

4.4.5 Document control7.5.2 Creating and updating7.5.3 Control of documented information

4.4.6 Operational control 8.1 Operational planning and control

COMPARATIVE TABLE OF CHAPTERS AND SUB-CHAPTERS

4.4.7 Emergency preparedness and response 8.2 Emergency preparedness and response

4.5 Control (title only) 9. Performance evaluation (title only)

4.5.1 Monitoring and measurement9.1 Monitoring, measurement, analysis and evaluation (title

only)9.1.1 General

4.5.2 Evaluation of compliance 9.1.2 Evaluation of compliance

4.5.3 Non-conformity, corrective and preventive action 10.2 Non-conformity and corrective action

4.5.4 Control of records7.5.2 Creating and updating7.5.3 Control of documented information

4.5.5 Internal audit 9.2 Internal audit

4.6 Management review 9.3 Management review

10 Improvement (title only)

10.3 Continual improvement

ISO 14001:2004 ISO/DIS 14001:2015

COMPARATIVE TABLE OF CHAPTERS AND SUB-CHAPTERS

KeyGREEN = equivalent 2015 sectionsBLUE = new 2015 sections

“In order to meet the needs of the present without compromising the ability of future generations to meet their own needs, it is essential to achieve a balance in a global system taking into account the three pillars of sustainability: environmental, social and economic sub-systems. Organizations implement environmental management systems with the aim to contribute to the environmental pillar of sustainability.”

The environmental policy refers to organizational context, implying that the policy should focus the EMS, not just on key environmental risks, but also threats and opportunities for the organisation. This is a big difference from the narrower focus on pollution prevention in the 2004 version.

The DIS also emphasises the benefits of determining where in the value chain the organisation can control or influence performance. The objective is to encourage the consideration of external opportunities for improvement, which may result in lower costs from the supply chain or greater marketing opportunities, as a consequence of addressing environmental issues.

SCOPE OF ISO 14001: 2015

A BROADER DEFINITION

CLAUSE 4.1 - NEEDS AND EXPECTATIONS OF INTERESTED PARTIES

Organization

Employees

Competitors

Supply Chain

Government

Non-governmental organisations Communities

Customers

Owners and Financial Community

Company Decision MakersRecruitment

and retention

Access to capital

Changing markets

Informed decisions

Social license to operate

Reputational Risk

Regulatory Constraints

Input Costs

Competitive advantage

What are the internal and external issues that affect the ability of the organization to1) Control and2) Improve its

performance?

What are the stakeholder’s needs and expectations? Which ones become obligations?

Compliance Obligations

Ex: climatic conditions, resource availability, social conditions, economic conditions, organizational culture, etc.

Ex: exigences corporatives, permis et règlements, entente de collaboration, conditions d’adhésion des associations sectorielles, attentes en communications transparentes avec les ONG, etc.

Confirmation of obligations and authority to act

Activities to control and actions to plan

4. Context of the organization

4.1 Understanding the organization and its context

4.2 Understanding the needs and expectations of interested parties

4.3 Determining the scope of the environmental management system

5. Leadership

5.1 Leadership and commitment

5.2 Environmental policy

5.3 Organizational roles, responsibilities and authorities

6. Planning

6.1 Actions to address risks and opportunities

6.2 Environmental objectives and planning to achieve them

The organization’s commitments with respect to the targeted performance and goal framework

The organization’s commitments with respect to resources and integration into business processes

What aspects / issues could have significant impacts (positive or negative)? What are the associated risks? What actions are planned to reduce them?

Ex: dust during high winds, aging population over labour availability, climate change on site access, price of metal over production.

Objectives aligned with the commitment of the policy

CLAUSE 4.2 AND 6.1.3. COMPLIANCE OBLIGATIONSLEGAL REQUIREMENTS

What are the operational requirements in terms of permits?

Example:Monitoring programs

Example: • Training and Employment• Business Opportunities• Education Awards and

Scholarships• Social and Cultural• Environmental Matters and

Closure• Financial Matters

What are the operational requirements in terms of applicable rules?

What are the operational requirements in terms of collaborative agreements?

Example:NPRI report

Example:Air emissions criteria

Example:Incident follow-up

Example:Expiration date on TDG training

1

CLAUSE 4.2 AND 6.1.3. COMPLIANCE OBLIGATIONSCORPORATE REQUIREMENTS

What are the corporate operational requirements?

Operational RequirementsSS 1 Security/Theft ManagementSS 2 Product Security/Theft

Operational RequirementsSH 1 Safety Golden RulesSH 2 Industrial HygieneSH 3 Golden Eye ReviewSH 4 Field MonitoringSH 5 Preventive SafetySH 6 Continuous Improvement Plan

Operational RequirementsCR 1 Social Baseline StudiesCR 2 Stakeholder ManagementCR 3 Community Response

System (Grievance Mechanism)

CR 4 Community AgreementsCR 5 Human Rights CR 6 Land Acquisition and

CompensationCR 7 Local Employment and

ProcurementCR 8 Community InvestmentsCR9 Reclamation and Social

Closure Planning

Operational RequirementsEP 1 CyanideEP2 Chemicals and Petroleum

ManagementEP 3 Mercury Management EP 4Solid and Hazardous WasteEP 5 Waste RockEP 6 Tailings EP 7 Water Stewardship and

ManagementEP 8 Energy StrategyEP 9 Air Emissions ControlEP 10 Land UseEP 11 Environmental

MonitoringEP 12 Exploration EP 13 Reclamation

and Closure Planning

2

CLAUSE 4.2 AND 6.1.3. COMPLIANCE OBLIGATIONSEXTERNAL REQUIREMENTS

What are the operational requirements in terms of voluntary standards the organization commits to?

Example:Cyanide Code

Example:Towards Sustainable Mining• Aboriginal and Community Outreach• Energy and GHG Emissions Management• Tailings Management• Biodiversity Conservation Management• Safety and Health• Crisis Management• Mine Closure

3

Extractive Industries

Transparency Initiative (financial

transactions)

Global Reporting Initiative – Sustainability

Reporting Guidelines

International Council on Mining and Metals (incl

GRI) United Nations Global

Compact

Universal Declaration of Human

Rights

Voluntary Principles on Human Rights

and Security

International Finance Corporation’s

Environmental and Social Performance Standards

Activities to control and

actions to plan

Significant Aspects

Evaluation P

rocess

Identified Aspects

Objectives

Compliance Requirements

ELEMENT 6 - PLANNING

Commitment confirmation and authority to act

Planning P

rocess

Informed by

ELEMENT 8 - OPERATIONS

Controlled Activities

8.1 Operational planning and control

8.2 Emergency preparedness and response.

Emergency measures plan A in

case of fire

Weekly inspection of department X

Emergency measures plan B in

case of spillage

Emergency measures plan C in

case of crisis

List of the department’s activities with

significant aspects/risks.

Inspection form

Inspection schedule

Work procedures for activities x, y

and z

Work instructions for activities a, b

and c

Planning of meetings with communities

Community Action Plans

Preventive maintenance

Proof of preventive maintenance

Meeting agendas and minutes

System Document

System Procedure

Key

Establish, implement control and maintain the processes… to implement the actions determined in 6.1 and 6.2.

Establish, implement and maintain the processes needed to prepare for and respond to potential emergency situations.

Principal Activities Examples of documentation

EvaluatedPerformance

9. Performance evaluation

9.1 Monitoring, measurement, analysis and evaluation

Calibration program for equipment

Data from equipment

Proof of calibration

CLAUSE 9.1 - MONITORING, MEASUREMENT, ANALYSIS AND EVALUATION

Monitoring of community engagement (in collaborative agreement)

Monitoring of pollution control equipment

Determine what needs to be monitored and measured and how to do it.

Evaluate conformance to compliance obligations.

Analyze the results and evaluate the performance.

Calibration procedure

Surveillance of working environment (SS)

Performance recording

(ex: SO2 emissions)

Monitoring contractor work

Inspection forms

Données relevées par le département

des achats

Monitoring of supplier’s products/services

Wastewater monitoring program

Principal Activities

System document

Systems procedure

Examples of documentation

Key

Activities to control and

actions to plan

Significant Aspects

Objectives

Compliance obligations

CLAUSE 9.1.1 - MONITORING, MEASUREMENT, ANALYSIS AND EVALUATION


Planning P

rocess

Informed by

Operational control

Emergency preparedness

plans

Global performance

indicators

Performance indicators

specific to an activity or piece

of equipment

Controlled activities

Determine required

monitoring

Compliance obligations


Informed by

Global performance

indicators

Performance indicators

specific to an activity or piece

of equipment

Determine monitoring required

Results analysis and performance evaluation

Conformity evaluation to operational

requirements

Objectives

Evaluated performance

Non-conformity management

Required improvement

Required improvement

CLAUSE 9.1.2 - EVALUATION OF COMPLIANCE

• Identical for ISO 14001 and ISO 9001• 3 years for the transition of the certificates to the new standard• ISO 45001 (replaces OHSAS 18001) at the Committee Draft

stage, expected for final publication in 2016

2014 2015 2016-18

November– Draft International Standard (DIS) available for public comment

July – Final Draft International Standard (FDIS) published

September – International Standard expected

Planned transition period is 3 years, according to the IAF.

REVIEW AND TRANSITION SCHEDULE

• The “auditable” part of the draft standard is 12 pages (vs 6 pages in 2004)

• There are now 10 main clauses and 21 sub-clauses (vs 4 and 16 in 2004)

14001: 2015 TOO MUCH?

ISO 14001: 2015 – TOO MUCH?

• Without a management system representative, responsibility for the EMS will be distributed at the top level of organizations (e.g., CSR/Environment, Finance, Operations, Procurement, Public Relations)

• Given the importance of external stakeholders to the EMS, system audits may extend to include them.

• The definition of “appropriate”, “adequate” or “deemed necessary” level of system documentation leaves much for interpretation. This may be a contentious point during system audits.

• Operational controls associated with significant aspects are not necessarily documented procedures anymore. Organizations will need to define how control is achieved.

ISO 14001: 2015

IMPORTANT POINTS