Revision of ISO 14001 IEMA Briefing Note

IEMA Survey on Revision to ISO 14001 – 1,651 completed questionnairesStronglyDisagreeDisagreeAgreeStronglyAgreeTotalAgreeThe revision to ISO 14001 should require the EMS to be linked / integrated to the strategic decisionmaking processes of the organisation.The revision to ISO 14001 should require organisations to consider impacts from a changingenvironment that are relevant to their organisation, in addition to organisational impacts on theenvironment.The revision to ISO 14001 should place greater emphasis on the management of impacts across the lifecycle of products / services provided and used.The revision to ISO 14001 should seek to position environmental management in the context ofsustainable development.The revision to ISO 14001 should strengthen and clarify how organisations demonstrate their‘commitment to legal compliance’.The revision to ISO 14001 should require organisations to periodically demonstrate their knowledgeand understanding of their compliance status.The revision to ISO 14001 should require organisations to demonstrate continual improvement oftheir EMS and the environmental outcomes that they achieve.The revision to ISO 14001 should require organisations to evaluate their environmental performancethrough the use of defined indicators which the organisation would be free to determine.ISO 14001 should support the provision of information on environmental performance which anorganisation is required, or may decide, to report or disclose.Guidance in ISO 14001 should refer to other relevant standards which can help with the achievementof the aims of the EMS (e.g. ISO 14031 – Environmental Performance Evaluation).The principal aim of ISO 14001 is to provide a framework through which organisations can deliverimprovements in their environmental performance.Maturity matrices should be included in the annex of ISO 14001 (as guidance) to help organisationstrack and plan the development of the EMS, in order to continually deliver improvements inperformance.1.2% 4.1% 51.5% 43.2% 94.7%2.0% 9.6% 56.6% 31.9% 88.5%2.0% 13.7% 52.6% 31.7% 84.3%1.9% 7.5% 52.8% 37.8% 90.6%1.1% 6.8% 47.5% 44.6% 92.1%1.1% 9.0% 53.4% 36.4% 89.8%0.5% 7.1% 55.6% 36.8% 92.4%0.9% 9.3% 60.5% 29.3% 89.8%1.0% 9.1% 63.3% 26.6% 89.9%1.6% 7.6% 58.0% 32.7% 90.8%0.4% 6.3% 55.3% 38.0% 93.3%1.7% 9.9% 64.4% 23.9% 88.3%3

Annex ARecommendations for the Revision of ISO 14001 from the EMS Future ChallengesReport"When considering new requirements in a revised version of ISO 14001, it should be remembered that ISO14001 is a tool to improve environmental management; new requirements should not be set in such way thatthey only reflect 'best in class' levels that will dissuade or exclude entry level organizations from adopting thisstandard. The use of ‘maturity matrices’ should be considered to show how requirements can be applied in anincreasingly comprehensive manner.”Maturity matrices are already a part of BS 8900: 2006 Guidance for Managing Sustainable Development,which allows organisations to profile the maturity of the management system and identify areas ofweakness.An example of how a maturity matrix might apply within ISO 14001 is shown below although it wouldbe the responsibility of individual organisations to prepare their own maturity matrix to ensure it isrelevant to them:ManagementSystem CriteriaSystem MaturityNewly EstablishedFully EmbeddedTraining andAwareness RaisingBasic environmentalawareness provided;further training providedas required.Frequent awarenessraising programmes run;specific training needsevaluated periodically.Continual awarenessraising programmes andstaff engagement; stafftraining needscontinually assessed andmet, including planningfor future needs andcapacity.The 24 specific recommendations which will be considered in the revision process of ISO 14001 are setout below with some further explanation of some recommendations in italics. IEMA has grouped theseinto related areas to aid discussionsContext of Sustainable Development1. Put environmental management more clearly in the perspective of contributing to sustainabledevelopment (the ‘planet pillar’ of SR). This does not mean incorporating requirements from other nonenvironmentalaspects of sustainable development (i.e. people and profit pillars) into the standard, but to recognisethat an EMS is a tool used to address the ‘planet pillar’, often taken as part of wider action on sustainabledevelopment and social responsibility in organisations.2. Address life cycle thinking* and the value chain perspective more clearly in the identification &evaluation of environmental aspects related to products and services. *this does not meanimposing LCA.3. Consider addressing other environmental principles from ISO 26000, clause 6.5. Some principlesfrom ISO 26000 are inherent to EMS implementation in line with ISO 14001 (e.g. environmental risk management) but others,(e.g. the precautionary approach and polluter pays) are not and could be addressed in the revision.4. Consider aligning language between ISO 26000 (Social Responsibility) and ISO 14001.N.B. ISO 26000 (Guidance on social responsibility) is a guidance standard (i.e. not a management system standard whichcan be audited against) which provides overarching guidance on what is meant by social responsibility, including definitions,principles and covering the core subjects that should be addressed. The standard addresses social responsibility through4

seven core subjects, namely: organisational governance, human rights, labour practices, the environment, fair operatingpractices, consumer issues and community involvement and development.Strategic Application5. Strengthen (on a strategic level) the relationship between environmental management and thecore business of organizations, i.e. its products and services and the interaction withstakeholders (including clients and suppliers). This would aim to move the EMS from what is often an operationallevel only tool to one which has greater influence on the overall business management of the organisation.6. Use the JTCG identical text on ‘context of the organization’ to strengthen link betweenenvironmental management and the organization's overall strategic considerations. This refers toSection 4 in the proposed High Level Structure with identical text for Management System Standards, which reads, “Theorganization shall determine external and internal issues that are relevant to its purpose and that affect its ability to achieve theintended outcomes of its XXX management system”.7. Consider the implications of new (strategic) business management models for application of ISO140018. Pay attention to strategic considerations of environmental management, the benefits andopportunities of it for organizations, not only in the introduction, but also in the requirementsStrengthen Requirements9. Strengthen performance evaluation as part of 4.5.1 in ISO 14001 (e.g. use of indicators);consider in this respect the ways in which performance evaluation is addressed in ISO 14031, inISO 50001 and in non-ISO sources such as EMAS III and GRI.10. Strengthen attention for subjects such as:a. Transparency/accountability with respect to environmental management/issues/performanceb. Value chain influence/responsibility11. Consider to include the concept of demonstrating knowledge and understanding of theorganization’s compliance status. This refers to the legal compliance status of the organisation.12. Address the concept of 'demonstration of the commitment to legal compliance'. There are currentlydifferent views on what the requirement for ‘commitment to compliance’ should deliver in practice in certified EMS’s- thisvariance could be addressed in the revision.13. Building upon the (draft) JTCG identical text introduce a more systematic approach foridentification of, consultation and communication with stakeholders on environmental issues14. The future revision of ISO 14001 should address a requirement to establish an externalcommunication strategy, including communication objectives, identifying relevant interestedparties, description of what and when to communicate. This does not necessarily mean that externalcommunication will be a requirement of ISO 14001, but that the current requirement to “decide whether to communicateexternally about its significant environmental aspects” could be enhanced to promote external communication.15. Clarification of the requirements of (improving) environmental performance in ISO 14001.Accessibility16. An organization should retain the responsibility to align its ISO 14001 processes with itsenvironmental and business priorities.17. Maintain the applicability of ISO 14001 to SMEs, e.g. by drafting/maintaining simple andunderstandable requirements.18. Consider the guidance given in CEN Guide 17 “Guidance for writing standards taking intoaccount micro, small and medium-sized enterprises (SMEs) needs”Language and Clarity19. Draft clear and unambiguous requirements in ISO 1400120. Clearly describe and communicate the approach/mechanism of achieving legal compliance in ISO14001 (e.g. in the Annex)21. Broaden/clarify the concept of Prevention of Pollution5

Guidance22. Provide where necessary clearer guidance in Annex A (according to its current aim: to preventmisinterpretation of the requirements)23. Provide guidance in the Annex on information related to environmental aspects of products andservices to external interested parties.24. Include clear requirements/guidance related to strategic environmental considerations, design &development, purchasing, market & sales activities in alignment with organizational prioritiesFurther Information:ISO 14001 - http://www.iso.org/iso/home.htmlEMS web-portal: www.iema.net/emsIEMA’s activities and evidence base used to develop this position statement can be found atwww.iema.net/iso14001Contact IEMA about ISO14001:Martin BaxterExecutive Director – Policym.baxter@iema.netJosh FothergillPolicy & Practice Lead – EMSj.fothergill@iema.netPost: St Nicholas House, 70 Newport,Lincoln, LN1 3DP, UKTelephone: +44 (0)1522 540 069Further information about IEMA:For further information about IEMA and our activities on environmental skills, knowledge and thoughtleadership, visit:Web: www.iema.netLinkedIn: www.iema.net/linkedin6