12 steps to make the transition from ISO 14001:2004 to 2015 revision
The new version of ISO 14001 is finally published, and you are probably asking yourself whether you need to implement the whole standard all over again.
Well, this is not quite necessary – although the 2015 revision did bring some changes, they are not so drastic. For an overview of the changes, see this infographic: New ISO 14001 2015 revision – What has changed?.
According to ISO, the transition period will last three years, meaning that you can become certified or have surveillance audits according to the old version until September 15, 2018. Of course, this is only in theory. Some of the biggest certification bodies announced that they will stop issuing new certificates according to the old version by September 2016.
If you became certified before September 15, 2015, you will have your surveillance audits according to the 2004 revision, but your recertification audit will be conducted according to the 2015 revision.
If you get your certificate according to the 2004 revision after September 15, 2015, you will have three years to transition to the new version.
This is my proposition on what steps should be taken, and their order, for a successful transition to the 2015 version of the standard:
1) Define context of the organization. This is a new requirement, and it should be thoroughly considered because it represents the foundation of your new EMS (Environmental Management System). For more information, see: Determining the context of the organization in ISO 14001.
2) List all interested parties. You should list all your stakeholders (the persons and companies that can influence your EMS or can be influenced by it), and their requirements. If you already listed all the statutory, regulatory, and contractual requirements according to the old clause 4.3.2, then you have already done half of your job.
3) Review the scope of the EMS. The credibility of your EMS depends on the choice of organizational boundaries. The transition is a great opportunity to reconsider the scope of your system and to define its boundaries more precisely.
4) Review the Environmental Policy. The requirements regarding the policy are pretty much the same, although there is now a greater emphasis on incorporation of the EMS into the strategic direction of the company, so that should be noticeable in the policy also.
5) Align EMS objectives with the company’s strategy. 2015 requires you to determine whether the environmental objectives are compatible with the strategic direction of the company.
6) Assess risks and opportunities. This is a completely new requirement, and it refers to the risks and opportunities related to the EMS. It concerns not only environmental aspects, but also other parts of the system such as context of the organization and compliance obligations. After the assessment of risks and opportunities, there should also be some plans for addressing them. For more information, see: Risk Management in ISO 14001:2015 – What, why and how?.
7) Identify and evaluate environmental aspects. The transition is a great chance to reevaluate your environmental aspects. The new version also requires you to consider foreseeable emergency situations and a lifecycle perspective of your products and services during the identification and evaluation of environmental aspects. For more information, see: 4 steps in identification and evaluation of environmental aspects.
8) Determine the compliance obligations. A requirement for complying with statutory and regulatory requirements existed in the previous version, but now there are also interested parties and their needs and expectations to be observed as compliance obligations.
9) Control documented information. Documented information is the new term, and it refers to both procedures and records. Besides aligning your old procedures with the new clause numbers, you should also consider improving your existing documentation. The requirements for preventive actions do not exist anymore (preventive actions basically became a part of the risk assessment process), so you can decide whether to delete that procedure or not.
10) Operational control. The new version requires better control of the processes, including operating criteria and implementing controls of processes according to the criteria.
11) Environmental performance. There is now a lot of emphasis on establishing environmental performance measuring and monitoring. If done properly, this will give you an overall picture of your system and tell you what needs to be improved. For more information, see: Environmental performance evaluation.
12) Measurement and reporting. Requirements became much stricter in the 2015 revision, especially regarding the above-mentioned environmental performance, but also the internal audit and the management review need to be aligned with the new version of the standard. The changes are not related to the techniques for conducting them, but rather to changes in the input elements of the management review and requirements to be audited during the internal audit.
And, this is it – it might seem like a lot, but my guess is that within the one-year period this won’t take more than a couple of hours per month to achieve. This is especially true because I think these changes really do make sense – they will not only bring your EMS closer to the needs of your business, but you will also have a system in place to show the usefulness of your environmental management.
To learn how to perform each of these 12 steps, download the free white paper Twelve-step transition process from ISO 14001 2004 revision to 2015 revision.