Paul Suff asks assessors how the new 14001 standard will change EMS audits
Whether the new international standard for environmental management systems, ISO 14001: 2015, strengthens the links between the EMS and organisational strategy, more effectively engages leaders and ensures environmental aspects are related to business risks and opportunities will largely depend on the quality of the internal and external audits.
Due to be published in September, 14001: 2015 is different from the previous version (2004) in several ways and these will challenge the competence of many auditors. The new section on organisational context will require assessors to develop a broader knowledge of the organisation they are auditing and the industry or sector in which they operate. Likewise, assessing how the environment can affect the ability of the organisation to create long-term value will demand a greater understanding about how climate change and resource scarcity, for example, will affect operations. Meanwhile, the new leadership clauses will necessitate more contact between auditors and top management teams, a dynamic that is likely to test assessors' communication skills and business acumen.
A roundtable discussion hosted by the environmentalist in 2012 on the future of 14001 found mixed opinions among practitioners on auditing competence.
Several participants questioned whether auditors would have the skills to effectively conduct a more strategic assessment. "The skills set is completely different for compliance-type compared with more strategy-based audits," said Viki Bell, global portfolio manager for sustainability at standards body BSI. Ben Vivian, co-founder of consultancy Vivian Partnership, said: "The concern I would raise about moving to a more strategic standard management system is that you end up asking who is going to audit it and who's competent enough to audit. So, if you end up with a system that no one can actually audit, you've got a big problem."
Certification bodies and assessors acknowledge that the competence of many auditors will have to improve. Warren Percival, director at consultancy RSK Environmental, describes 14001: 2015 as a huge change for the auditing profession. "There are some massive changes for auditors in the new standard," he warns. Certification bodies will have to "up their game" to ensure the process effectively assesses organisations against the requirements of the new standard. "In my experience, too many third-party auditors do not apply enough rigour during the audit," he says.
Nigel Leehane, managing director at environmental engineering consultancy CRA Europe, says auditing was always a weakness of 14001 and the flaws could be exacerbated by the additional demands on assessors on the revised version. "The quality of some internal and external audits has been questionable. Some auditors do not have the right skills to make an effective assessment and that competence gap is likely to grow with 14001: 2015," says Leehane, a technical expert on the groups that revised the auditing standard ISO 19011 in 2011 and now a member of the group revising 14001.
Martin Hockaday, environmental sector manager at certification body NQA, agrees that the clauses in the revised standard will require assessors to have a broader range of knowledge than that demanded by the 2004 version. "Assessing how organisations could be affected by the environment is very different from looking at how its operations affect the environment and will require assessors to have a deeper understanding about the organisation, its products and services, supply chains etc," he says. "How will increasing water scarcity due to climate change affect a textile manufacturer, for example, as sourcing its raw materials may get more difficult?"
Steve Williams, system and governance manager at business assurance company LRQA, believes that the proposed changes to 14001 are positive and will lead to greater integration of environmental management and organisations' business operating systems. But he also concedes that auditors will need more understanding of the business risks that face an organisation and how these will affect their ability to meet the required outcomes in relation to their EMS. "They will also have to be able to understand the context in which the organisation operates so as to better understand the potential impact of these risks," he says.
Most practitioners and assessors accept that the success of the revised standard in raising commitment to the EMS at the highest levels in an organisation will depend largely on the effectiveness of auditors. The leadership clauses require senior management to demonstrate commitment to the EMS. Auditing conformity will involve assessors speaking with top managers about what they have been doing to actively support the management system.
The frequency of meetings between assessors and senior managers will rise and auditors will have to be skilled in communicating what might sometimes be difficult messages. This was highlighted by Clare Dann, global technical manager for environmental management systems at BSI, in the environmentalist in February 2015. She said that 14001: 2015 would require assessors to discuss the EMS more often with senior management, which, on occasion, might lead to difficult conversations between clients and auditors.
Williams agrees: "The greater emphasis on leadership in 14001: 2015 will mean that auditors will need to be prepared to challenge the top management of the organisation on their commitments."
Hockaday outlines a possible scenario to illustrate how assessors might encounter problems when addressing senior managers. "What if the business strategy is geared towards growing sales of a product, but the EMS identifies that the material in it, perhaps a rare earth metal, is scarce?" he asks. "It would mean the EMS is telling the company to go in a different direction to the strategy. That might not go down too well in some businesses, particularly if they have invested heavily in the product."
Percival describes tenacity as a key attribute for an auditor. "They need to follow the right line of questioning to discover suitable evidence. Will they get long enough face-to-face time with senior managers to elicit the necessary information?" he asks.
Leehane wonders whether internal auditors will have the confidence and ability to deal with their top management teams and whether external auditors will have enough time to question senior managers. He advises organisations to prepare their senior management team.
He also counsels that the interaction is likely to be more productive if assessors can talk the "right language" in terms of what drives business performance.
Hockaday alludes to some of the practical difficulties that might arise when assessing performance against the leadership clauses. "Auditors need to recognise that senior managers are busy people, so they will have to be flexible when speaking with them," he says. "A meeting might be arranged 12 months in advance as part of the auditing cycle, but the chief executive might be called away at the last moment. Or senior management might be based in another facility or another country." In such circumstances, Hockaday advises assessors to find another way to provide senior management commitment. He suggests that this could involve speaking to others in the business to find evidence of top-level involvement in the EMS.
"For a new client, we'd initially expect to speak to top management during stage two of the audit process and then at least once during a three-year cycle. It might, however, be appropriate to interview management at every audit. The frequency will probably depend on the size and complexity of the organisation," says Hockaday.
Putting the organisation into context
Dealing with the clauses on organisational context may take many assessors out of their comfort zone and require them to have a general awareness of a much broader range of issues. Equally the requirements on risks, opportunities and threats will demand industry knowledge and an understanding of downstream issues.
The draft international standard (DIS) published last year states that an organisation should determine "external and internal issues that are relevant to its purpose and that affect its ability to achieve the intended outcome(s) of its EMS". The DIS offers an insight into the range of knowledge that auditors will need in terms of the context of the organisation. As well as the environmental conditions related to climate, air quality, water quality, land use, natural resource availability and biodiversity, assessors will also be expected to know about the external cultural, social, political and economic landscape in which the organisation operates. Crucially, auditors will also need to be capable of assessing not only the organisation's impact on the environment, but the effect the environment has on the organisation.
Certification bodies and assessors generally accept that this is a significant change and will require many auditors to update their skills and knowledge. "At LRQA, we have been anticipating the move towards the requirements defined in the new management systems high-level structure for a number of years and have been training all our assessors," says Williams. "The assessors are looking at the bigger picture in relation to the risks that certified organisations need to address, the context in which they operate and the interested parties' requirements that need to be addressed."
Percival is concerned that some auditors will have insufficient environmental or sector experience. "Although all management standards will follow the same high-level structure, I don't think you can expect assessors to effectively audit environment, quality and health and safety systems with some of the changes that are coming up. There will be a need for additional technical competency and knowledge that you may find only in a specialist." He says that it is often the case that an "environmental specialist" is assigned to undertake a legal review during the triennial audit cycle, for example.
Percival also asks whether all auditors will have the knowledge and skills to work across sectors. "Assessing an EMS at a manufacturing facility can be very different from auditing one on a construction site, especially when dealing with issues like ‘context', which is required under the new standard." He believes some auditors will lack knowledge in an important facet of the revised standard. "Do they understand the concept of lifecycle assessment or have the ability to effectively assess risk, opportunities and threats?" he asks. Leehane makes a similar point: "Considering lifecycle perspectives will be particularly challenging for auditors. They will have to push organisations to look at this across their supply chains and to consider significant aspects that may be outside their direct control. That is something many will not be used to doing."
Percival also points out that auditing for the new standard will not be an entirely lateral process, but will require assessors to examine how the clauses link together. "Clause 5.2 relates to establishing, implementing and maintaining an environmental policy. But auditors will have to find out how it links with, say, 4.1 and the requirement to understand the organisation and its context."
Hockaday describes 14001: 2015, with its reference to social, political, legal, regulatory, financial, and economic frameworks, as more closely aligned to the wider remit of sustainability than the previous version. This expansion to consider broader sustainability issues may be a new concept for some auditors, Leehane believes. He says: "Many will not understand that the failure to develop strategic approaches to environmental sustainability will result in an inability to build a more sustainable and successful business model – for example, by ignoring the potential benefits of efficient natural resource use. They will need to think outside their traditional pollution prevention and spill control boxes."
Ready and waiting?
Williams reports that LRQA has been preparing assessors for 14001: 2015 for several years. The training has focused not only on the requirements of the high-level structure, so that all management systems, including 9001 (quality), will follow the same template, but also the fact that a lot of detail is now supported by the annex to the standard. Percival reports that RSK too has already started providing its assessors and clients with training and consultancy on applying it.
Hockaday at NQA advises that training should not focus just on understanding the new clauses, but on establishing a common auditing approach to them. "We don't want auditors interpreting the clauses differently," he says, explaining that NQA and other certification bodies already adhere to ISO/IEC 17021: 2011, the conformity assessment standard.
17021 sets out the principles and requirements for the competence, consistency and impartiality of the audit and certification of management systems of all types. Hockaday hopes that consistency will be achieved by effective planning by the certification bodies and oversight by accreditation organisations. He says that NQA has been preparing for the changes to 14001 for some time, and started training its assessors last year in the new requirements. "We plan to audit against the new standard from day one, so we need to be ready," he says.
Ultimately, Leehane believes "switched-on auditors" will see the changes to 14001 as an opportunity, empowering them to support organisations to improve their performance. "Others will find the changes challenging," he says. "Many auditors have a lot of work to prepare themselves for the revised standard, but the enlightened ones will see it a chance to make their mark."
Percival recalls some of the advice he received early in his career: "We were told always to look for objective evidence that an organisation is meeting the standard and to not treat the assessment as a tick-box process, ensuring we audited and understood how all areas of the standard interact. I think that counsel still holds true."
Whether the duration of audits will rise to accommodate the new requirements in 14001: 2015 is open to question. Martin Hockaday, environmental sector manager at certification body NQA, is noncommittal on whether the revised standard is likely to lead to longer assessments. "Audit time is generally linked to the number of processes that require checking, so if there are more to examine it might take longer. As yet, we don't know if audits will take longer. But I think it's safe to say they will not take any less time."
Although 14001: 2015 requires auditors to address additional requirements, Nigel Leehane, managing director at environmental engineering consultancy CRA Europe, says external auditing against the new standard may not necessarily require more time: "Clients will not want to pay more and I think certification bodies will address this by adopting a more efficient auditing process, and by focusing on areas of greatest organisational risk."
Steve Williams, system and governance manager at business assurance company LRQA, believes the length of the audit will depend on the organisation: "If they have a mature system that is already embedded in their business system, where they are addressing risks at an organisational level, they will already be familiar with how their system will need to change to meet the new requirements. As a result, they should be prepared for the assessment against the new standard. If, however, we are looking at an organisation that is not well prepared, the time necessary to undertake the audit will be longer because the assessor will need to ensure that it understands what is required and to verify that it is compliant."