ISO 14001: 2004 Revisions - By Brandon Kerkstra
As most of you are probably already aware, there is a new revision to ISO 14001 and companies must upgrade before May 15, 2006. (For cost effectiveness the upgrade audit with your registrar should be scheduled at a normal surveillance audit between now and May 2006) This article is part 1 of a 2-part series to assist you with making changes to your system to comply with the new revision.

The good news for those of you who have worked with Management Solutions Group for implementation or Internal audits is that we have interpreted the intent of the standard to be more inclusive and it therefore should meet the intent of the new standard as well. (You may remember may “Recommendations” on internal audits that look familiar when you read clarified requirements below)

In general, my recommendation is to revise the documentation to include the new language of ISO 14001: 2004 which will also be more inline with ISO 9001: 2000 and TS 16949: 2002. This should not be an overwhelming task and will not effect many people in your organization. It will make your system easier to upgrade in the future, easier to audit and more clear.

The following is a summary of the changes by section:

Definitions: The new revision contains revised and new definitions to be more inline with ISO 9001

4.1 General Requirements:

More specific requirements for a clearly defined scope of the EMS and a requirement to continually improve

4.2 Environmental Policy

Again here are requirement that the EMS policy is consistent with the Scope of the EMS

Requirement that the Policy be communicated to “any persons working for or on its behalf”

4.3.1 Environmental Aspects

More clear wording that the company identifies all “Activities, Products, and Services” that it can control and influence

More emphasis on keeping this information up-to-date and considering Significant Aspects in the whole EMS

The information must be documented. (Meaning the initial baseline assessment of Aspects)

4.3.2 Legal & Other Requirements

More general requirement that all legal and other requirements that apply to the companies Environmental Aspects and to determine how these requirements apply

Again here as in 4.3.1 there is more emphasis on considering Legal and other requirements in the whole EMS

4.3.3 Objectives and Targets

More explicit requirements that Objectives and Targets be measurable and include Legal and Other requirements, Significant Aspects, & Continual Improvement.

4.4.1 Resources, roles, responsibility and authority

Additional language in this section covers “Improving the EMS” and includes “Organizational Infrastructure”.

4.4.2 Competence, Training and awareness

Revised wording here states “Any person(s) performing tasks for it or on its behalf” is expanded to include temporary and contract workers

4.4.3 Communication

No significant changes

4.4.4 Documentation

The required documents are more clearly defined and more in line with the ISO 9001 requirements. Most companies should meet these requirements, especially those with integrated systems (With ISO 9001: 2000)

4.4.5 Document Control

Again here as in 4.4.4 the wording has been changed to align with ISO 9001: 2000. There is a specific reference here for external documents.

4.4.6 Operational Control

No significant changes

4.4.7 Emergency preparedness and response

No significant changes

4.5.1 Monitoring and measurement

More emphasis on monitoring performance

4.5.2 Evaluation of compliance

Legal requirements and Other requirements have separate clauses which places more emphasis on evaluating compliance to each.

Explicit requirement that records of the compliance evaluation must be kept.

4.5.3 Nonconformity corrective and preventive action

Corrective action process is more clearly documented with increase requirements. Most companies with established corrective action procedures and (ISO 9001) integrated systems should already meet this requirements

Nonconformity is defined in a broader sense that would require corrective action process to be used more often.

4.5.4 Control of records

Shortened language states “Records necessary to demonstrate conformity” and does not list specific records.

4.5.5 Internal audit

Brought inline with ISO 9001 and specifically requires internal auditors be objective and impartial. This may make assigning internal auditors more confining.

4.6 Management Review

Again here the standard is aligned with ISO 9001.
Specific Inputs and Outputs are required

Here are the most common items that need to be addresses due to the new revision:

1. Legal Requirements should be linked to the associated aspect

2. Contractors need to be informed of Policy, Requirements, & Responsibilities

3. Documenting the competence of contractors

4. Documented Verification that Objectives and Targets are consistent with the Environmental Policy

5. Make sure External Documents are included in Document Control

6. Document & Demonstrate that Internal Auditors are Objective and Impartial

7. Review Management Review agenda's to ensure they cover the required items.

This should assist you with upgrading your Management System. Please contact us if you have any questions.