Annex ARecommendations for the <strong>Revision</strong> <strong>of</strong> <strong>ISO</strong> <strong>14001</strong> from the EMS Future ChallengesReport"When considering new requirements in a revised version <strong>of</strong> <strong>ISO</strong> <strong>14001</strong>, it should be remembered that <strong>ISO</strong><strong>14001</strong> 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 <strong>of</strong> ‘maturity matrices’ should be considered to show how requirements can be applied in anincreasingly comprehensive manner.”Maturity matrices are already a part <strong>of</strong> BS 8900: 2006 Guidance for Managing Sustainable Development,which allows organisations to pr<strong>of</strong>ile the maturity <strong>of</strong> the management system and identify areas <strong>of</strong>weakness.An example <strong>of</strong> how a maturity matrix might apply within <strong>ISO</strong> <strong>14001</strong> is shown below although it wouldbe the responsibility <strong>of</strong> 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 <strong>of</strong> <strong>ISO</strong> <strong>14001</strong> are setout below with some further explanation <strong>of</strong> some recommendations in italics. <strong>IEMA</strong> has grouped theseinto related areas to aid discussionsContext <strong>of</strong> Sustainable Development1. Put environmental management more clearly in the perspective <strong>of</strong> contributing to sustainabledevelopment (the ‘planet pillar’ <strong>of</strong> SR). This does not mean incorporating requirements from other nonenvironmentalaspects <strong>of</strong> sustainable development (i.e. people and pr<strong>of</strong>it pillars) into the standard, but to recognisethat an EMS is a tool used to address the ‘planet pillar’, <strong>of</strong>ten taken as part <strong>of</strong> 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 <strong>of</strong> environmental aspects related to products and services. *this does not meanimposing LCA.3. Consider addressing other environmental principles from <strong>ISO</strong> 26000, clause 6.5. Some principlesfrom <strong>ISO</strong> 26000 are inherent to EMS implementation in line with <strong>ISO</strong> <strong>14001</strong> (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 <strong>ISO</strong> 26000 (Social Responsibility) and <strong>ISO</strong> <strong>14001</strong>.N.B. <strong>ISO</strong> 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 <strong>of</strong> 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 <strong>of</strong>ten an operationallevel only tool to one which has greater influence on the overall business management <strong>of</strong> the organisation.6. Use the JTCG identical text on ‘context <strong>of</strong> 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 <strong>of</strong> its XXX management system”.7. Consider the implications <strong>of</strong> new (strategic) business management models for application <strong>of</strong> <strong>ISO</strong><strong>14001</strong>8. Pay attention to strategic considerations <strong>of</strong> environmental management, the benefits andopportunities <strong>of</strong> it for organizations, not only in the introduction, but also in the requirementsStrengthen Requirements9. Strengthen performance evaluation as part <strong>of</strong> 4.5.1 in <strong>ISO</strong> <strong>14001</strong> (e.g. use <strong>of</strong> indicators);consider in this respect the ways in which performance evaluation is addressed in <strong>ISO</strong> 14031, in<strong>ISO</strong> 50001 and in non-<strong>ISO</strong> 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 <strong>of</strong> demonstrating knowledge and understanding <strong>of</strong> theorganization’s compliance status. This refers to the legal compliance status <strong>of</strong> the organisation.12. Address the concept <strong>of</strong> 'demonstration <strong>of</strong> 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 <strong>of</strong>, consultation and communication with stakeholders on environmental issues14. The future revision <strong>of</strong> <strong>ISO</strong> <strong>14001</strong> should address a requirement to establish an externalcommunication strategy, including communication objectives, identifying relevant interestedparties, description <strong>of</strong> what and when to communicate. This does not necessarily mean that externalcommunication will be a requirement <strong>of</strong> <strong>ISO</strong> <strong>14001</strong>, but that the current requirement to “decide whether to communicateexternally about its significant environmental aspects” could be enhanced to promote external communication.15. Clarification <strong>of</strong> the requirements <strong>of</strong> (improving) environmental performance in <strong>ISO</strong> <strong>14001</strong>.Accessibility16. An organization should retain the responsibility to align its <strong>ISO</strong> <strong>14001</strong> processes with itsenvironmental and business priorities.17. Maintain the applicability <strong>of</strong> <strong>ISO</strong> <strong>14001</strong> 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 <strong>ISO</strong> <strong>14001</strong>20. Clearly describe and communicate the approach/mechanism <strong>of</strong> achieving legal compliance in <strong>ISO</strong><strong>14001</strong> (e.g. in the Annex)21. Broaden/clarify the concept <strong>of</strong> Prevention <strong>of</strong> Pollution5