Mark Hammar Among the changes in the upcoming release of ISO 14001 are the requirements for documented information, but what does this mean for your company and the way they deal with documents and records? Are your documented procedures now obsolete? Do the new requirements demand that you to get rid of them? What about your records and the controls you have in place to keep them secure and legible? The good news is that the changes are not being made just for the sake of change, and they are not intended to cause more work to update your system to be able to comply with new rules. The new requirements give you some more leeway in what needs to be documented in your Environmental Management System (EMS), but first – what is the definition of documented information?
What does ISO 14001:2015 mean by documented information?
In the ISO 14001:2015 drafts, the term “documented information” is meant to describe any meaningful data that is required to be controlled and maintained by the organization, and the medium on which it is contained. Documented information can refer to the Environmental Management System and its processes, documentation, and records. So, in brief, it includes anything that you require to be recorded to make sure your EMS functions properly and that you can demonstrate that this is the case.
In section 7.5 of the draft standard, the requirements for documented information are captured, and they are fairly basic. Your EMS needs to document the information that is required by the ISO 14001 standard, and the information that your organization has determined is necessary for the effectiveness of your EMS. This information is expected to be tailored to your company, because it is noted that the extent of the documented information can differ due to the size of the organization, the complexity of the organization, and the competence of the people.
Lastly, there are requirements for the control of documented information, particularly how:
- it is available and suitable for use,
- it is adequately protected,
- it is distributed applicably, and
- access, retrieval, use, storage, and preservation are controlled.
Finally, there needs to be a control of changes, retention of documented information, and disposition when these documents are removed from use. If you look closely, you will see that these requirements are very much the same as those already in place for documented procedures and records, only merged into one set of requirements.
So, what do you need to change to comply with the new requirements?
Many people make the mistake of changing the definitions that they use in their management system to match those in the standard, when this is not a requirement. The standard is not there to dictate what you will call something, or even how you will number any documents that are in your system (matching the document numbers in the EMS to the ISO 14001 standard is also something people sometimes do unnecessarily). If you want to continue to use the terms “procedure” and “record” because this is what the people in your company understand, then go ahead. The requirements of the ISO 14001 standard are there to give you a framework to build an Environmental Management System that works the best for your company in your effort to meet legal requirements and improve your environmental performance.
So, if you see a benefit in replacing some of your current procedures, or merging your two procedures for documents and records, because it is simpler – then do so. However, if the procedures you have in place are working for you, then don’t change them just for the sake of change. While the purpose of an EMS is to create improvements in your company, and all improvement requires change – not all changes are improvements. Make the changes that help you improve, and leave the things that are already working well. In this way, you get the benefits that you want from your Environmental Management System.
Download this free Checklist of Mandatory Documentation Required by ISO 14001:2015 to learn which documents are required.
