John Nolan The ISO 14001:2015 standard was released on September 15, 2015, for general use. To understand more about the changes, you can read our previous article: Infographic: ISO 14001:2015 vs. 2004 revision – What has changed?, but right now many company employees around the world will be digesting these changes and planning the way ahead for their respective organizations, both in order to comply with the new standard and also to obtain maximum business benefit from the implementation of the changes. As with many changes to existing standards, the changes are not descriptive, and are open to a degree of interpretation. While this can be a positive thing in many ways, it also leads to the possibility of incorrect interpretation or implementation, creating non-conformity during the audit. So, what can be done to identify this before it happens?
Non-conformities: Best avoided!
We have looked at non-conformities in previous articles, and specifically the article Environmental Nonconformity Management: How is ISO 14001 different from ISO 9001 may be worth referring to when considering environmental non-conformities. As we can see from that article, non-conformities tend to be more about the outputs of methods that your Environmental Management System (EMS) utilizes than with non-conforming product in ISO 9001. So, let us briefly take a look at a sample of the main changes and examine one instance that could hypothetically lead to a non-conformance being raised by an auditor under the terms of the 14001:2015 standard:
- Reformatting to the Annex SL Standard: This is quite a wide topic of change, but let us imagine that your organization cannot provide documented proof that you understand and use the “plan-do-check-act” cycle correctly. Result: non-conformance against 14001:2015.
- The importance of risk: Let us imagine that we cannot demonstrate that we are using risk-based thinking at a strategic level, and our organization has not had input from our top team when discussing risk. Result: non-conformance against 14001:2015.
- Environmental aspects: Evidence of planning now needs to be shown to ensure that proper consideration of this facet exists. If this cannot be demonstrated, the result is non-conformance against 14001:2015.
- Leadership: In my opinion, this is one of the key changes to ISO 14001:2015. Let us say that no members of your top team were present at your EMS Management Review or periodic meetings. Result: lack of evidence of leadership involvement causes non-conformance against ISO 14001:2015.
So, as we can see from the explanations above, non-conformances could potentially be caused by the new strands of the ISO 14001:2015 standard unless your organization is well prepared, educated, and vigilant. So, we understand that it is preferable to avoid non-conformity, but what is it? And will understanding the implications of dealing with non-conformity strengthen the case to avoid it?
Understanding non-conformities in ISO 14001:2015 in order to prevent them
Action taken against a non-conformity will result in a formal corrective action more often in ISO 14001:2015 than it will in ISO 9001. Nobody wants a major or minor non-conformance against their EMS, so the ethos of the “plan-do-check-act” cycle should also be used if required to eliminate a non-conformance, as follows:
- Ensure that a root cause is established, with input from stakeholders wherever possible.
- Take action to mitigate and remove the root cause, and prevent reoccurrence.
- Establish a monitoring method and period to ensure that no reoccurrence takes place, and improvement can be measured.
- Document and communicate at all relevant stages and ensure that you use the vehicles that you have, whether EMS or combined Quality, Health & Safety & Environmental meetings to discuss, monitor, and constantly seek improvement. Raising a corrective action should be expected.
- If your EMS utilizes a “Lessons Learned” log, use it. What is important today soon becomes forgotten tomorrow, so you should take every opportunity to record and learn from any non-conformity that may be found. After all, that is all part of continual improvement.
Ensuring you understand these important points should help your organization prevent further non-conformance during the transition to 14001:2015. After all, understanding the cause is central to being able to prevent non-conformity in the first place.
Benefit of avoidance versus cure
As understanding the root cause of a non-conformity can help your organization to prevent it, the benefits of avoiding a non-conformity during your transition to the 2015 standard are many:
- Immediate benefit of the positive aspects of the 2015 standard: the adoption of risk-based thinking will create the removal of risk and identification of opportunity immediately to your organization.
- Time and money saved: dealing with non-conformities takes resources, and costs money. Avoiding a non-conformity is financially advantageous to your business.
- Increased leadership involvement: the increased strategic involvement of the top team will provide a tangible benefit to the business in terms of planning and execution of strategy, if implemented and executed correctly.
- Reputational benefit: this will be accrued in the eyes of your stakeholders, partners, and customers if you can implement a 14001:2015-compliant system free of non-conformity.
Therefore, it is easy to see that when we understand the actions and resources required to deal with non-conformity during the transition to ISO 14001:2015, that prevention is vastly preferential to cure. Embrace the changes, implement and monitor them, and see the benefits of avoiding non-conformity on your journey towards ISO 14001:2015 compliance.
To learn more about the new version of the standard, use this free white paper: Twelve-step transition process from ISO 14001:2004 to the 2015 revision.
