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ISO 14001:2015 AND THE INTERPRETATION

ISO 14001:2015 INTERPRETATION REVIEW

ISO/TC 207/SC 1


The objective of this blog post is to create a clear understanding of the requirements within ISO 14001:2015 by means of answering recently asked questions.



Content

Who are ISO/TC 207/SC 1

Interpretations?

Review of updated interpretations ISO/TC 207/SC 1

Understand the ISO committee structure

Review process

Interpretations to date –22 covered today

Full list to be found at: ttps://committee.iso.org/sites/tc207sc1/home/projects/published/iso-14001--environmental-manage/iso-14001-interpretation.html

The ISO sub-committee with responsibility for ISO 14001 -and other supporting standards;

Work Programme focus is on its core standard ISO 14001 and four key components;

Overall understanding and implementation (ISO14004);

Evaluating consequences of environmental aspects (ISO14002-1);

Policy and organisational elements (ISO14006 & ISO14009 -WIP);

Evaluating strategic & monetary (financial) consequences (ISO14007 & ISO 14008.


Interpretation Process Anyone can request an interpretation -via BSI Standards. May be answered at that stage -but forwarded to TC207/SC1. All requests received & formal responses given by ISO member bodies will be included in

an annual compilation of interpretations. SC1 will be asked to consider all information received & if any interpretation is at variance

with the formulated position of SC1, then an explanation of the variance will be provided to the member body. SC1 will make the annual compilation of interpretations after its review publicly available on their website free of charge. Herewith the responses received.

General Q

Where to draw the border line between legal requirements on the protection of the natural environment and those protecting occupational health and safety issues. Had been raised by CB as a non-conformance for not including H&S legislation.


A All organisation's are obliged to comply with all applicable legislation. The standard says that the organisation shall “determine and have access to the compliance obligations related to its environmental aspects..”. If there are no environmental aspects that can be linked to legal requirements concerning occupational health and safety issues, then they do not have to be included. Obviously acceptable to include other obligations – not a requirement!

General

Q In some places in the Standard, the organisation is directed to take certain items into account, while in other places in the Standard, the organisation is directed to “consider” certain items. Is there a difference?


A ISO 14001 uses the word “consider” and the phrase “take into account” with a specific intent. The word “consider” means it is necessary to think about the topic but it can be excluded; whereas “take into account” means it is necessary to think about the topic but it cannot be excluded.

General Q

Is Section 3, Terms and Definitions, binding and, if so, may an auditor determine whether "appropriate" environmental objectives have been set to meet the requirements of definitions 3.2.6?

A

The only sections of ISO 14001 against which an organisation’s conformance is audited are Sections 4 to 10 -EMS Requirements, the terms of which are clarified by the definitions in Section 3. If the environmental objectives are consistent with the environmental policy, and their development has taken into account the organisation’s significant environmental aspects and associated compliance obligations and considered its risks and opportunities then the objectives are consistent with the standard.

Clauses 4 & 6 Q

Does ISO 14001 require an organisation to demonstrate that it has addressed requirements related to environmental aspects, significant environmental aspects, policy commitments, context issues and concerns, risk/opportunities & compliance obligations individually for each sub-clause in ISO 14001, or can an organisation demonstrate that it has addressed these collectively, through the significant environmental aspects determination process?

A

ISO 14001 does not mandate separate processes or procedures to be used for “addressing” its requirements -provided the requirements are addressed! An organisation might have a single “environmental planning” process that addresses a number of requirements set out in Clauses 4 and 6. The organisation simply needs to provide evidence that each of the separate requirements are addressed.

Clauses 6.1.1, 6.1.2 Q

Does ISO 14001:2015 allow an organisation to consider environmental risks and opportunities as environmental aspects, and those aspects that it intends to address, as its significant environment aspects?

A

There is a relationship between an organisation’s significant environmental aspects and the risks and opportunities related to its environmental aspects, but they should not be necessarily treated as identical. The definition of “risks and opportunities” is not the same as “significant environmental aspects.” Environmental aspects can result in risks and opportunities, which can be determined as part of the significance evaluation, or determined separately. There may be other risks and opportunities that need to be addressed in the environmental management system –issues raised in context

Clause 5.2

Q What is meant by the “commitment to fulfill its compliance obligations” in Section 5.2(d) –Policy in ISO 14001?