John Nolan The release of the ISO 14001:2015 standard saw multiple changes that organizations had to incorporate into their EMS (Environmental Management System), and activities to enable them to meet the terms of the standard. One of the changes that may not be so obvious in the first instance is how your organization manages outsourced services and suppliers, and ensuring that this is aligned with the terms of the ISO 14001:2015 standard. When the standard mentions “outsourced suppliers,” it means third parties who are contracted to perform critical parts of your process and service, normally but not always outside your own facility. So, what do we need to understand, and what actions do we need to take, to ensure that our EMS remains compliant?
What do the changes mean?
ISO 14001:2015 says that the organization shall “determine its environmental requirement(s) for the operational planning and control regarding products and services as appropriate.” While this statement does not seem radically different from the 14001:2004 standard, reading Annex A provides more details. Here we are told how the organization needs to decide the extent of control needed over its external suppliers, based on factors such as competence in terms of meeting compliance, technical competence, the importance and effect the product or service will have on the organization, and how capable the organization’s purchasing process is of delivering these elements during its normal function. Annex A goes on to explain that the amount of control exerted by the organization over the delivery of a service or product may vary according to certain circumstances, but one thing remains clear: your organization must assume ultimate and total responsibility for the environmental performance of any outsourced suppliers you engage in the delivery of your product or service. So, what is the best way of achieving this?
Getting the basics right
In the previous article Driving your supply chain to ISO 14001 compliance, we looked at how using ISO 14001-certified suppliers can make running your organization easier and also bring environmental benefits. This remains the case for the ISO 14001:2015 standard, but there are extra questions that would be beneficial to answer:
- Are your suppliers likely to deliver your key environmental performance indicators?
- If your supplier is not ISO 14001:2015 certified, do they have an environmental policy? If so, this is a positive, but do they follow the terms of your organization’s environmental policy?
- Does your supplier have an internal audit policy and results available?
- Does your supplier have a full understanding of legislation that applies to your product and its delivery?
- Does your supplier have evidence of risk-based thinking and identification of environmental aspects to mitigate environmental impact?
So, what steps can your organization take to ensure that your supplier is equipped to manage environmental performance in line with ISO 14001:2015 requirements? Let us consider the options:
- Insist on setting regular key performance indicators to be reported back from your outsourced supplier.
- Ensure your supplier purchases with environmental criteria at the forefront of their decision-making process.
- Ask to see evidence of risk assessment, environmental aspect identification, and actions that will yield improvement.
- Ask to see the supplier’s legislation log, and proof that relevant environmental legislation is both understood and complied with.
- Seek proof that any environmental incidents will be recorded and reported back to the organization within the parameters of an emergency preparedness policy, and that a process exists to deal with incidents in terms of reporting to authorities, containment, and corrective action. For elements such as this, it is recommended that the supplier be given input and guidance as to how this process should operate, given that your organization is responsible for the outcome. You can learn more about this topic in the blog How to satisfy emergency response requirements in ISO 14001:2015.
- Ensure that your organization agrees to a schedule for supplier audit and review, where the environmental performance of the outsourced supplier can be assessed and action taken, if required. This is the most common and effective method of ensuring that the outsourced supplier complies. These expectations would normally be outlined in the contract between the organization and the outsourced supplier.
Ensuring your organization takes responsibility
When managing your external suppliers, it is important to remember that your organization has the ultimate responsibility for environmental performance and all environmental impacts caused by the manufacture of your product or service, both internal and external. Given the more prescriptive guidelines in Annex A of ISO 14001:2015, the more control your organization has over its supplier, the better your overall environmental performance will be. In some businesses, such as electronics, where subcontracting is the industry standard, it is not unusual for an organization to have a representative onsite full time to ensure that the supplier works to the stated parameters. In cases where this is not practical, taking the steps outlined above will help you to ensure that your suppliers’ environmental performance is managed effectively, and the terms of ISO 14001:2015 are met, and exceeded.
Use our free online training ISO 14001:2015 Foundations course to improve your knowledge about supplier management in the EMS.
