1. 1 Next Generation ISO 14001 Susan LK Briggs Presented to EFCOG/DOE EMS Implementation, Lessons Learned & Best Practices Training Workshop, 3/05

2. 2 Presentation Outline Objective: Provide an overview of the major changes to ISO 14001 and a brief synopsis of their implications. Topics: -Background -Key changes -Increased Emphasis on Compliance -ISO 9001 Compatibility -Next steps

3. 3 Background ISO Mission to develop consensus standards on topics of global interest –Standards are prepared by Technical Committees - TC 207 for Environmental Management Systems (EMS) –Membership available to any national standard body, or representative of gov’t, NGO, or int’l liaison organizations - ANSI is the US member body; US TAG to TC207 is mirror body –ISO 14001 & ISO 14004 revision initiated in parallel in 1999 - ‘Experts’ from mirror body appointed to the working groups - Role is to negotiate the revised, consensus standard

4. 4 Background Goals: –Increase compatibility with ISO 9001:2000 –Clarify requirements, to assist in user understanding, ease implementation, and enhance environmental protection …without resulting in additional or diminished requirements

5. 5 Challenges Clarification to some is interpreted as ‘new requirements’ by others Minor grammatical changes can result in significant change in meaning ISO 9001 concepts are not always applicable to environmental issues Independent stakeholder pressure to enhance emphasis on regulatory compliance and external communication

6. 6 General An organization now has to: Define and document the scope of the EMS Determine how it will fulfill requirements Implication: Enable the organization to customize its EMS to its size, culture & needs Reduces potential for external entity (i.e., registrar) to mandate how to implement a requirement.

7. 7 Scope and Applicability communicating policy training, competency and awareness Implication: Expand efforts to include contractors, suppliers, and temporary staff “all persons working for or on [the organization’s] behalf” Expand scope and applicability of EMS requirements beyond employees to “all persons working for or on [the organization’s] behalf”

8. 8 Aspects “identifying aspects of its activities, products or services” Instead of “identifying aspects of its activities, products or services” “activities, products and services” An organization now has to identify aspects of its “activities, products and services” Implication: Ensures comprehensive aspects analysis Avoids arbitrary exclusions (ie., aspects associated with product use and disposal) Maintain flexibility to define scope and thereby expand or limit aspects determination.

9. 9 Aspects “it can control and over which it can be expected to have an influence”… Instead of considering activities, products and services “it can control and over which it can be expected to have an influence”… - both control and influence “it can control and those which it can influence” …an organization now has to consider those “it can control and those which it can influence” - two independent considerations Implication: Expectation to influence management of aspects related throughout the life cycle –Supply chain; transport/distribution; product use/disposal

10. 10 Legal Requirements New requirement: “Determine how legal and other requirements apply to an organization’s environmental aspects” Implication: –Not sufficient to identify and have access to legal requirements –What will an organization be expected to do to demonstrate they conform? -Is regulatory understanding by environmental managers sufficient? -Will operations staff be expected to cite applicable regulations? -Will a detailed, documented analysis be expected?

11. 11 Increased Emphasis on Compliance New Clause, ‘Evaluation of Compliance’ –Applies to both regulatory and voluntary requirements Legal & other requirements no longer limited to ‘environmental’ requirements –DOT, OSHA, etc may be applicable Legal & other requirements must be taken into account when establishing, implementing and maintaining an EMS –For example, when setting Objectives Records of compliance evaluation results required Implications: Expansion of scope of compliance evaluations Ends dispute on validity of Compliance Goals Legal ramifications when documenting noncompliances

12. 12 Compatibility with ISO 9001 Where commonality exists, efforts made to use same terminology, format and structure –Records –Internal Audit –Management Review –Documentation –Document Control –Definitions –Nonconformity, Corrective & Preventive Action Implication: Documents of external origin need to be controlled (ie., permits) For organizations implementing both ISO 14001 and ISO 9001, eliminate potential for conflicting requirements

13. 13 Nonconformity, Corrective & Preventive Actions Causes of nonconformities must be determined, and actions taken to prevent recurrence Evaluate the need for actions to prevent nonconformities from occurring Review effectiveness of corrective & preventive actions Definition: ‘ Nonconformity is non-fulfillment of a requirement’ Implications: Potential double jeopardy wrt preventive actions Common understanding expanded to include non-compliances, non-achievement of goals, even natural disasters

14. 14 Next Steps IAF established 18 month transition period US Technical Advisory Group accepting questions for ‘Clarification of Intent’ Discussions at international level on how to further enhance alignment between 9001 and 14001 already starting

15. 15 Debate Continues Some argue proposed revisions do not increase the value and benefit to an organization or community in terms of improved performance or environmental protection. –Instead benefit only consultants and registrars, at expense of increased administrative burden for organizations Others argue new version is clear, explicit and compatible with ISO 9001 Users will be ultimate judge on whether working group achieved its goals.

16. 16 An Organization’s Next Steps Assess your organization’s EMS against ISO 14001:2004 Monitor US TAG Clarification of Intent Process –Submit questions for clarification –Review responses to submitted questions –http://standardsgroup.asq.org/groups/e/index.htmlhttp://standardsgroup.asq.org/groups/e/index.html Brief key managers/staff on significant changes to affirm commitment Identify gaps and develop targets and action plan to fill gaps Registrars will start assessing to new standard in May ’05; conformance required by May ‘06

17. 17 Questions, comments and feedback