14001: 2015 – lessons from the early adopters
- Business & Industry ,
- Management ,
- Auditing ,
- Certification ,
- Corporate governance
Marek Bidwell talks to four organisations that were among the first to achieve the revised standard
More than 250,000 organisations worldwide will have made the transition to ISO 14001: 2015 by September 2018, yet for most this challenge still lies ahead. There is plenty of advice available about the changes, but organisations that have already been through the process may provide the most practical insights. These include precision metal fabricator Hydram Engineering, project development and construction firm Skanska UK, train operating company Northern (formerly Northern Rail) and Manchester Metropolitan University.
Common to the four was the advanced state of their environmental management systems (EMS). Northern, which was the first organisation anywhere to be certified to the new standard, had carried out a context analysis in 2012 as it developed an environmental strategy for a two-year franchise extension, implemented an energy management system and reviewed its procurement process according to the requirements of BS 8903 (principles and framework for procuring sustainably).
Meanwhile, Manchester Metropolitan University has been active in sustainability for at least five years and in 2013 topped the People and Planet Green League, the independent table of UK universities ranked by environmental and ethical performance. It is now working to embed sustainability into its teaching curriculum. Skanska UK has developed a tool to embed sustainability into the lifecycle of all major projects, and has introduced an internal and external communications plan. The firm’s chief executive, Mike Putman, chairs the Green Construction Board.
The organisations found that the work they had done in these areas eased the transition to 14001: 2015. This makes sense because one objective of ISO’s Future Challenges Study Group, whose work fed directly into the drafting of the revised EMS standard, was to consider new approaches and methods for management systems. The overriding message was to adopt best practice.
Practitioners should be encouraged that their advances in areas such as lifecycle thinking and sustainable procurement need not be rewritten for 14001: 2015. Rather they will provide objective evidence towards meeting the new requirements.
To give themselves a head start, all four organisations obtained copies of the early drafts of 14001: 2015. They tracked subsequent changes and consulted other sources of information and support. One source was the ISO 14001: 2015 Road Test Group (reported in the August 2014 issue of the environmentalist, pp23–25), a cross-sector band of environment practitioners who had reviewed the planned changes and the implications for their organisations. Andrew Robertson, HSE manager at Hydram Engineering, hosted the first meeting of the group. He says: ‘It was interesting to find out about how the other companies were dealing with the likely changes, because they were from all sorts of backgrounds.’
Helena Tinker, environment and energy systems manager at Manchester Metropolitan University, worked on achieving the final stage of EcoCampus, the framework to help higher and further education institutions manage their sustainability performance, and the transition to 14001: 2015 at the same time. She says: ‘I attended a number of consultation workshops run by Martin Baxter [IEMA chief policy advisor and UK representative on the group that developed the revised standard], which were useful as they gave an early insight to the changes that were being proposed. EcoCampus was also helpful; we worked together to understand the impact of the changes on our system.’
All of the early adopters carried out a gap analysis of the systems they had in place against the new requirements, but they were keen to ascertain more than a mechanistic understanding of the changes. Nigel Sagar, senior environmental compliance manager for Skanska UK, says: ‘I was attempting to identify not only the new aspects of the standards, but also the way in which they would be interpreted. That was the hardest element.’
Despite the strengths of their existing EMS, all four organisations had to develop their systems to meet the new requirements. ‘Our main concern was purchasing in clause 8.1,’ says Robertson. ‘In metal fabrication, most raw materials are specified by the customer, and the purchasing team was initially uncomfortable with the whole idea.’ On investigation, Robertson found that, when pricing a job, the commercial and design team could advise customers on other methods of manufacture that might use less steel. These design changes ultimately reduced upstream impacts, benefiting both the customer and the environment.
There has been a shift in emphasis in the new standard from training to competency. Skanska UK now requires staff to have specified professional membership levels for particular tasks. ‘Anyone can write an environmental aspect and impact assessment, but it now has to be ratified by an associate member of IEMA or equivalent,’ says Sagar. ‘Similarly, anyone can write a project environmental management plan, but they have to be reviewed and approved by a full member of IEMA or equivalent.’
A further new requirement in 14001: 2015 is the need to ‘maintain knowledge and understanding of compliance status’. This includes status with compliance obligations that are non-regulatory, and Northern took these into account when amending its system. Kyle MacNeill, environmental assurance manager, says: ‘We were measuring certain contractual requirements, but we started including other non-statutory compliance obligations, such as noise complaints associated with public address systems. This has been a huge advantage to us because sometimes local managers made commitments and then left the company, the complaints would start again and the residents would have more information about previous problems than us. But now we do know about them and the process is more resilient.’
Tinker took a devolved approach to the new requirements for context analysis at Manchester Metropolitan University. She held workshops on each policy area that involved a PESTLE (political, economic, social, technological legal, environmental) analysis. She then presented the key risks and opportunities to the university’s environmental strategy board for review.
Comparing the process of identifying risks and opportunities to environmental aspects, she says: ‘I found it more useful than the aspects assessment exercise, especially for the travel and waste policy areas; it helped teams think about how their activities are influenced by internal and external factors. It encouraged them to think more holistically and plan for the future.’
Although the university already has an objective to embed environmental and social sustainability into the curriculum, the changes to 14001: 2015 have helped with its business case to garner resources.
Many practitioners will be wondering how the certification bodies will interpret the new requirements and whether nonconformities will be more common in some areas than others.
Robertson says the team at Hydram Engineering was not overly stretched during its transition audit process. ‘It was just like other audits we have had in the past,’ he says. Hydram Engineering was audited by certification body SGS. Sagar says of Skanska UK’s audit: ‘It was a learning process, both for our certification body and for ourselves. On this occasion, the auditor spent more time interviewing senior managers from our central enabling functions, such as procurement, HR, design and fleet. Employees from the procurement department were asked about our sustainable procurement policy and designers were questioned about taking a lifecycle approach.’
Between them, the transition audits for the four early adopters lasted 12 days, and covered more than 14,000 staff. Seven audit findings were raised associated with the new requirements of 14001: 2015 (see panel, below).
None of the four organisations were required to take corrective actions associated with the new requirements for top management commitment, despite polling consistently showing that this was the change of greatest concern to system managers. The extent to which assessors interviewed top management varied between the four organisations. Robertson says: ‘The assessor had the opportunity to speak to the chair of the company, but he did not interview him in detail. I think he was satisfied by the detailed management review minutes I had written, as well as everything he picked up from the team.’
Only one observation raised during the audits was associated with the important new requirements for lifecycle thinking. This was a suggestion for Hydram to provide information to customers regarding the carbon emissions associated with its products, as well as disposal and recycling arrangements.
Words of advice
The interviewees thought that the changes to 14001 would help to democratise environmental management. ‘It can only bring benefits in encouraging more people to become involved in environmental management, not only in Skanska UK but also in our supply chain,’ says Sagar.
Robertson adds: ‘The main benefit for our company has been the expansion of the group of people who consider the environment, from one environmental manager to all the key decision makers. This has been cascaded down to everyone who can have an impact or influence, however small. This can only help to have a positive impact on the environment.’
Tinker offers the following advice for others transitioning to 14001: 2015: ‘Make sure that you have good leadership and commitment; embed the EMS into your organisation – people and processes; and ensure that people are clear about their roles and responsibilities.’
Robertson says: ‘I think the external auditors are slightly unsure, so the best idea is to do it now, before they become more familiar with the new standard. Start at the top by discussing the environmental aspects of the business plan with the directors and creating a SWOT/context analysis. Give yourselves plenty of time and use the opportunity to promote the environment, especially to people who influence environmental performance, such as those in purchasing and tendering.’
None of the early adopters saw achieving the revised standard as the end point for their EMS. ‘There are still lots of things that we want to do,’ says MacNeill. ‘After we achieved 14001: 2015, we developed a forecasting system for environmental objectives, which uses environmental information gathered from hundreds of locations in the business, such as stations and depots. Next, we will be integrating our system with health and safety. We are also hoping to do a lot of work towards improving biodiversity.’
Skanska UK is looking to further improvements by making its management system, called ‘Our way of working’, more user friendly. ‘We will be making changes to it on the intranet, by subdividing it into the different phases of the project, with the relevant processes and procedures assembled under each stage,’ says Sagar. ‘Another priority is to digitise more forms and documents for use on iPads and link them into BIM [building information modelling]. Skanska UK is also now advising other parts of the Swedish-owned company on their transition to 14001: 2015.’
Tinker says: ‘We would like to improve our programme on climate change adaptation and business continuity, working with the head of business continuity. We will continually review our energy, carbon and travel performance and continue to deliver on our challenging action plans to meet our targets. We would also like to expand our work on embedding sustainability into the curriculum as this contributes to students’ employability.’
The interviews with the early adopters reveal some common themes in the transition to 14001: 2015. All did research into the new requirements and carried out a gap analysis. This found they had either intentionally, or unintentionally, already made progress on one or more of the new requirements before making the necessary changes to their systems; and agreed that the changes brought benefits to their organisation by integrating environmental considerations into a wider-range of business processes than previously and drawing on the expertise of more individuals.
Differences were also apparent. For example, the new lifecycle thinking requirements were paramount for those with a high degree of control over the design of their products or services.
Every organisation’s 14001: 2015 journey will be different, but hopefully they will all lead to benefits for both organisations and the environment.
Audit findings: a summary
Length of audit
Number of staff
Audit findings associated with the new requirements of ISO 14001: 2015
- A suggestion to provide information to customers regarding the carbon emissions associated with products, as well as their disposal/recycling arrangements.
Two corrective actions:
- When visiting a particular project, the assessor found that the risk and opportunity assessments were not in the same format as the business risk and opportunity assessment.
- Environmental objectives were not fully documented for a specific project (covering what, by whom, and when).
Two corrective actions:
- A requirement to add a commitment to ‘protection of the environment’ to the policy. The previous wording was ‘enhancement of the environment’.
- The audit programme did not include all new elements of the standard so had to be extended.
Manchester Metropolitan University
Two corrective actions:
- The ‘root cause analysis’ carried out for nonconformities was not documented.
- The internal audit compliance findings did not link back to the register of legislation (associated with the new requirements for ‘maintaining knowledge of compliance status’ under ‘evaluation of compliance’).
Marek Bidwell, CEnv, is director of Bidwell Management Systems and a visiting lecturer in environmental management at Newcastle University. He is author of Making the Transition to ISO 14001: 2015 – from Compliance to Opportunity. Throughout the rest of the year, he will be interviewing representatives from organisations that have successfully made the transition. If you would like to contribute, email email@example.com. The results of his research will be published online at bit.ly/2a4pt4D.
‘Making the transition to ISO 14001’, the IEMA-approved one-day course, aims to help individuals with responsibility for implementing or maintaining an environmental management system based on 14001 to adapt to the revised standard. Participants receive insights from IEMA on the new standard and the IEMA EMS gap analysis tool, and learn how to identify and plan actions so that their organisation can conform to the new requirements. A list of providers running the course can be found in the June issue of the environmentalist.
In Elliott-Smith v Secretary of State for Business, Energy and Industrial Strategy, the claimant applied for judicial review of the legality of the defendants’ joint decision to create the UK Emissions Trading Scheme (UK ETS) as a substitute for UK participation in the EU Emissions Trading Scheme (EU ETS).
None of England’s water and sewerage companies achieved all environmental expectations for the period 2015 to 2020, the Environment Agency has revealed. These targets included the reduction of total pollution incidents by at least one-third compared with 2012, and for incident self-reporting to be at least 75%.
Global greenhouse gas emissions from agriculture are projected to increase by 4% over the next 10 years, despite the carbon intensity of production declining. That is according to a new report from the UN food agency and the Organisation for Economic Co-operation and Development (OECD), which forecasts that 80% of the increase will come from livestock.
Half of consumers worldwide now consider the sustainability of food and drink itself, not just its packaging, when buying, a survey of 14,000 shoppers across 18 countries has discovered. This suggests that their understanding of sustainability is evolving to include wellbeing and nutrition, with sustainable packaging now considered standard.
Billions of people worldwide have been unable to access safe drinking water and sanitation in their homes during the COVID-19 pandemic, according to a progress report from the World Health Organisation focusing on the UN’s sixth Sustainable Development Goal (SDG 6) – to “ensure availability and sustainable management of water and sanitation for all by 2030”.
New jobs that help drive the UK towards net-zero emissions are set to offer salaries that are almost one-third higher than those in carbon-intensive industries, research suggests.
IEMA has today urged the UK government to focus on developing green skills and expertise across business, industry and civil society following the publication of an alarming report from the Climate Change Committee (CCC).