John Nolan The release of ISO 14001:2015 in September 2015 saw some fundamental changes to the requirements given to the “top management” team within the EMS (Environmental Management System). Section 5 of the standard specifically relates to “Leadership and Commitment,” and indeed we explored this in some detail in the previous article How to demonstrate leadership according to ISO 14001:2015. While we will consider this section again, there are also other requirements tied into the standard’s specification that need consideration and action beyond those mentioned in this specific clause. So what are they, what do we have to do to make sure that the full benefit from ISO 14001:2015 can be accrued, and vitally, that your organization is seen to be complying with the standard when audited?
Management responsibility by ISO 14001 clause
Probably the best way to approach the summary of responsibility for top management in the 14001:2015 standard is to briefly examine what each clause now requires from the top team, given that we now have a firm understanding of the requirements of clause 5, which we have mentioned above. Obviously, the reader is recommended to purchase the standard and equate these requirements to his/her own organization, but let us look broadly at what the clauses can reasonably be translated to require from the top management team:
Clause 4, Context of the organization: One of the major changes outlined in our previous article How to determine the context of the organization in ISO 14001. Before the EMS is even established, the top team must determine its scope, external and internal factors, and stakeholders who may be affected by the system’s scope and resulting performance. This is a key task that cannot be completed satisfactorily by an organization without the input and strategic knowledge of the top team.
Clause 6, Planning: Another example of a clause that requires specific top team involvement. Planning of environmental aspects, actions, ensuring compliance obligations are considered and met, as well as the obvious planning of environmental objectives are all issues that require input and strategic guidance from a level only the top team can bring. Again, the identification and planning of risk and opportunities and the actions that ensue is one of the most critical components of the EMS, and this level of input can only come from the top team.
Clause 7, Support: This is a wide-ranging clause that needs constant top team input. Incorporating resources, competence, awareness, communication, and documented information, again there are many instances where only the top team can provide the strategic knowledge, guidance, and authorization within an organization to satisfy this clause.
Clause 8, Operation: Again, operational control aspects and emergency response planning should not be undertaken by any organization without knowledge, action, and guidance at a strategic level. Only the top management team can provide this.
Clause 9, Performance evaluation: From management review through internal audit to monitoring and measuring of results, these critical functions all clearly require top team input and action.
Clause 10, Improvement: The very component that underpins the ISO 14001 standard, clearly the top team must oversee the results and ensuing actions that drive the EMS and its objectives. Ultimately, the top team will be the only people in an organization with the authority and power to respond to ineffective results with a response that encapsulates all of the above: namely extra resources, training, finance, support, information, or communication – whatever is required to get performance and objectives realigned.
So, as we can see, section 5 outlining leadership and commitment is extremely critical to the EMS, but it is actually just the tip of the iceberg when it comes to responsibilities of the top management team. So, is there anything else we need to do?
Top team responsibility: The proof
In the previous article A new approach to documented information in ISO 14001:2015, we looked at the new requirements of the standard in terms of documentation. However, as you can see from above, there are multiple instances where proof of goal setting, action, review, guidance, and communication to stakeholders are required. Therefore, it stands to reason that it is wise to consider how to present proof of this in audit circumstances. Capturing all of the above in an appropriate format in regular management minutes may be the most seamless and sensible method of doing this, which will augment the proof that a complete set of management review minutes will also provide, whatever the frequency your organization performs that function. Therefore, it is clear that the top management team responsibilities don’t start and end with the specific leadership clause itself, but need to be ingrained throughout all aspects of your EMS as stated above. Achieve this, and your results will benefit accordingly.
To ensure that you meet the standard’s requirements, visit our ISO 14001:2015 Internal Auditor online course.
