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by Roderick A. Munro, Ph.D., and William M. Harral

As you first read ISO 14001:2004, you may very well start to think: “Why was all the time and energy spent on a new standard? I’m already doing all this!” Depending on how your organization first approached its environmental management system (EMS) under ISO 14001:1996, you may be correct. Changes to ISO 14001:1996 requirements found in the 2004 revision appear relatively minor. However, the 2004 requirements exist within an enhanced systemic context. This means that no requirement can be evaluated without considering the effects arising from interfacing requirements and the context in which they’re considered. Effects of changes within systemic paradigms should be considered as multiplicative, not additive.

Connie Glover Ritzert, a leader of the US TAG to ISO Technical Committee 207 for EMS, has stated, “How aggressively an organization established its EMS in the beginning will dictate how much change it actually sees in the new standard.” The international community had two goals in mind for the revision: first, clarify what the intentions of overall EMS requirements were meant to be in 1996 and second, more closely align ISO 14001 with ISO 9001.

General perspective of changes
The dual goals of clarification and alignment required revisions and additions to the existing formal definitions. Sixteen of the resultant 20 definitions are new or changed.

Alignment with ISO 9001 created a more formalized structure and operation with additional documentation, linkages between parts of the EMS, performance measurement and detailed reporting to top management. Also, alignment provided greater emphasis on the Deming plan-do-check-act cycle for ongoing continual improvement of aspect-level performance. Greater consideration of legal and other requirements follows the ISO 9001 model. Recorded compliance review ensures adherence to intents for compliance, even during changes. Competency, by itself, is becoming a higher-profile topic, with the emergence of ISO 17024:2003 for competency-based personnel certification. These changes may seem innocuous by themselves, but they imply a larger story.

Transition challenges
Whether an organization is developing a brand-new EMS, or just transitioning from ISO 14001:1996, certain challenges will exist. Space limitations preclude notation of all possible challenges, but some of the most commonly encountered can be addressed. Because most people view life with a task-based orientation, rather than a subclause focus we’ve collected various subclauses into potential task-based challenges. Most changes pose few technical challenges for individual EMS. The potentially larger challenges lie in the EMS support functions, e.g., human resources, information systems and corporate counsel.

Sources of EMS challenges
ISO 14001:1996 was exceptionally vague in some descriptions. (i.e.: “The organization shall establish and maintain an environmental management system.”) If you read it verbatim, an organization could claim that a requirement was satisfied with plans and that it was performing well, with very little evidence. There was nothing about a written system, little or no EMS training required, and little or no effectiveness review (either against what the organization claimed or against applicable laws). Typically, registrars provided enough detailed understanding and augmented requirements for registration to prevent many abuses under ISO 14001:1996 requirements.

In its current form, the standard states: “The organization shall establish, document, implement, maintain and continually improve an environmental management system in accordance with the requirements of this international standard and determine how it will fulfill these requirements.” Thus, there is a lot less “wiggle room” in ISO 14001:2004. Organizations will be required to know and to follow environmental laws, not only in their particular geographical area but also anywhere that their employees (including contract, agency personnel or even, potentially, suppliers) perform activities, or wherever their product may be shipped or used.

Additionally, while clause 4.1 is based on the specific stated requirements of ISO 14001:2004, many other clauses and sub-clauses also note “required by the environmental management system AND by this international standard.” This shows that the organization’s plans and the particulars of its EMS may affect overall or total requirements. In other words, the results of an organization’s environmental policy, scope, objectives and targets, plus its particular activities, products, services, customer base, location, structure and operational strategies can magnify the literal differences between ISO 14001:1996 and ISO 14001:2004. This directly affects the challenges of developing, implementing and maintaining the EMS. A simplistic comparison may fail to expose the most challenging requirements because they are not found in the standard. They arise from the resultant EMS.

Probable task challenges
There are five major interpretive paradigm differences in the new standard, in the following areas:

Communications. With 16 of the final 20 formal definitions changing to various degrees, a normal “learning curve” challenge exists for organizations familiar with ISO 14001:1996 or newcomers to EMS development. Early attempted actions may be compromised unless extra efforts are expended to ensure that everyone operates with common understanding. Other communication challenges arise from expansion of EMS communication to “all persons working for, or on behalf of, the organization.” Deciding whether to communicate EMS aspects externally may be required by existing statutes and regulations, if you know where these items exist. Perhaps the greatest communication challenge is the increased detail that must be communicated to top management during management review and its follow-up responses.

Documentation. The definition and documentation of EMS scope are critical, as they form the basis for ensuing plans and actions. However, local consensus on appropriate scope may be elusive. The scope parameters provide the boundaries for further documentation of EMS policy, objectives and targets. Documented aspects with linkages to legal and other requirements may prove frustrating, even overwhelming. The inclusion of records as documents and the need for records to evaluate an expanded focus on performance will increase workloads for most organizations. Control and maintenance of relevant, externally generated documents should be approached in a well-defined way that is agreed upon by all affected parties. Agreement is key because policing the activity is difficult at best in organizations with large scopes.

Competence. Agreement on the meaning of this term may be the first obstacle, as various definitions exist, including legal ones, and no definition is provided by the standard. Definition may affect labor or business agreements and have both legal implications and ramifications. Competency is a dynamic condition that may vary under different situations or challenges.

This is unlike static training requirements, which can be evidenced by observation or testing. In fact, competent people may lose their status for short or extended periods due to various circumstances. This consideration may clash with the organization’s new requirement that competence extends to “any person(s) performing tasks for it or on its behalf.” For some organizations, simply identifying these people, figuring out what they are supposed to be doing and how their competency should be determined may be an initial challenge.

Performance focus and evidencing. An emphasis on EMS performance is found in many new or revised requirements. Environmental objectives and targets must be measurable and foster continual improvement. Resources must be available when needed, not just “provided.” Procedures must be clearly implemented, in addition to previous directions to establish and maintain procedures.

Corrective and preventive actions are better defined and aligned with ISO 9001 approaches, which require effectiveness evaluation and maintenance, e.g., root cause analysis and elimination. Internal audits have expanded demands for auditor objectivity, impartiality and competence. These changes culminate in an expanded management review of performance indicators, with quantified measures against objectives and targets.

Legal and other requirements. The new mandate for determining how these requirements apply to the organization’s environmental management plan may require a new level of awareness, and possibly new or additional resources. Many organizations previously considered only the most obvious (or enforced) statutes and regulations. Few recognized that grandiose statements of policy, objectives or targets might introduce additional requirements.

Likewise, not all organizations fully explored the content of purchase orders or other business documents to ferret out unnecessary requirements. The exploration of legal and/or other requirements locally or in distant markets was seldom self-initiated, except for risk management. This paradigm has changed with the introduction of ISO 14001:2004, as evaluation of compliance has been elevated to a separate subclause (4.5.2) to ensure proper attention. Our advice is to ensure that management is aware of this situation, that adequate legal resources are available and that actions are documented. This task should not be taken lightly.

Intertwined system requirements
Challenges to efficient development and implementation of an ISO 14001:2004-compliant EMS arise from subtle changes with interface effects as well as major changes. Let’s examine a short trail of legal requirements as an example.

The significance of compliance is highlighted by its elevation to a separate subclause (4.5.2) with need for separate consideration. In the previous version of the standard, compliance was considered collectively with operations and key characteristics of activities that could have significant environmental effects, performance recording, relevant operational controls, organization objectives and targets conformance, plus recorded calibration and maintenance of monitoring equipment. Thus, it was one of many concerns in sub-clause 4.5.1 (monitoring and measurement) and had a tendency to receive little separate attention. The requirement previously demanded a documented procedure for periodically evaluating compliance with relevant environmental legislation and regulation. Little or no emphasis was placed on evidencing compliance. The augmented requirement is titled “Evaluation of compliance” (4.5.2), and that is what it demands—specific evaluation. Compliance evaluation is different from an internal EMS audit, as stated in note 1 of A.5.5, found in Appendix A.

The applicable statutes and regulations must be identified under subclause 4.3.2 before they can be evaluated. This may seem overwhelming because statutes, regulations, directives, etc., are created within numerous jurisdictions. Conflicts or inconsistencies may exist between legal requirements on the same subject at different levels, and may be conditional. Identifying and understanding requirements can be a substantial task by itself. Few EMS-focused individuals seriously consider the minor “hydrogen pollution” from charging batteries on electric forklifts, but safety and OSHA-focused workers are sensitive to this type of “pollution-” generating activity to the point of regulating it.

Also, subclause 4.3.2 requires that organizations examine how laws apply to their EMS. The environmental aspect clause (3.6) has been clarified to ensure that organizations fully consider all activities, products and services when identifying aspects. New wording and punctuation improves understanding that the term “or” is used to extend consideration to all aspects associated with products or services. It does not allow an organization to choose between either products or services before identifying aspects, e.g., a retailer must consider the solid waste produced by packaging and discarded inventory, even though its activities are primarily service-oriented in nature. This clarifying “nonchange” might nearly double workloads. This trail of escalating, intertwined requirements balloons with “minor” changes found in clause 4.2 (EMS policy) and subclause 4.4.2 (competence, training and awareness). These changes extend application of various requirements to “all persons working for or on behalf of the organization” and to “any person(s) performing tasks for it or on its behalf.” Now, compliant companies must ensure the compliance of various contractors, suppliers, etc. Part of this educational effort is dually covered by “Right to Know” legislation. Does everyone working for a contracted janitorial service understand a client’s EMS or the ramifications of discarding burned-out fluorescent lamps, broken computers or electronic circuit boards in your particular state? Do you?

Outcome of the changes
Depending on your registrar (there is still a lot of variation in the way registrars interpret the standard), most registered organizations will probably not find many dramatic changes in the way ISO 14001:2004 will affect them. We must re-evaluate how our organizations interpret environmental aspects and effects. However, given the legal system and the sheer number of environmental laws that we face, some will be traveling uncharted waters.

About the authors
Roderick A. Munro, Ph.D., is an ASQ Fellow, CQE, CQA, CQMgr, FIQA and IRCA lead auditor. Munro is a business improvement coach with RAM Q Universe Inc., which provides coaching, training and consulting services to manufacturing and service industries. He retired from Ford Motor Co. in 2001 and has more than 20 years of supplier development experience.

William M. Harral, MBA, is an ASQ Fellow, CQE, CRE, CQA, CQMgr, PEIT-Ohio and QSLA (RAB lead auditor). Harral is CEO of Arch Associates LLC, a Northville, Michigan, organization systems, standards compliance, and TQM consulting and training firm that he founded in 1983 after 20 years of various management positions at Ford Motor Co.