Road testing 14001:2015
the environmentalist reports on how one group of practitioners views the planned changes to 14001
The public consultation on the revised version of the international standard for environment management systems (EMS) is now open. First published in 1996, ISO 14001 was revised in 2004. The current revision is part of the ISO review cycle for standards and will lead to the publication of the third edition in 2015.
Since the start of the year, a cross-sector group of environment practitioners have been meeting to review the planned changes and the implications for their organisations. “By discussing and refining their understanding of the issues well ahead of the deadline [for comments], those involved hope to maximise the benefits for their organisations and the environment. Learning from the group may also help to shape best practice from a practitioner point of view,” says Marek Bidwell, director at Bidwell Management Systems, who has been facilitating the group.
Although the views expressed by members of the group relate largely to the proposals set out in committee draft 2 (CD2) rather than the draft international standard (DIS) recently issued for consultation, they provide an insight into the implications of the changes. Participants are generally enthusiastic about several of the planned changes, particularly the increased visible role of top management and links to business planning. “This will not only enhance the support for those with environmental roles, but also help their organisations to make the link with more strategic environmental issues,” says Bidwell.
Nonetheless, the precise meaning and implications of some changes, such as the extent of the value-chain requirements, have been hotly debated. Although some participants are confident that their organisations already exceed certain new requirements due to existing processes and initiatives, others believe they face a lot of work to embed the changes in their organisations.
To digest the implications of the likely changes, participants looked at each requirement set out in CD2 to prioritise the importance of each for their organisation.
These were grouped into 12 areas (see box below). Each organisation ranked the changes on a scale from one to 10 by considering the relevance and how much was required. A high-relevance score means that this issue is particularly important to the organisation, perhaps because it is linked to a significant environmental aspect or because of the business’s structure or market sector. A high-change score means that more time and effort will be required to meet the requirement. It is possible that a topic might be highly relevant, but attracts a low-change score because the organisation is already advanced in that area.
The group scores for change were aggregated, and the top-ranking issues in descending order were: value chain downstream; structure of the standard; value chain upstream; and risks and opportunities. Topics thought to require the least change were compliance status and achieving objectives.
For alterations to the structure of the standard, most participants scored highly for change, but lower for relevance, indicating that amendments to the paperwork would take time but were not seen as business critical. Of particular note is that the smaller organisations gave higher overall scores for how much change would be required compared with the larger ones. This probably reflects the fact that the latter tend to have well developed systems already in certain key areas, such as external reporting and business resilience planning.
The group scores for relevance were also aggregated. The top-ranking issues were: risks and opportunities; compliance status; and context of the organisation. Topics thought to be least relevant were value chain upstream and structure of the standard.
Having gained an insight into the key issues for each organisation, the group turned its attention to the implications of each change – which existing processes can be used (or amended) to provide evidence, and where something new is required. Insights from the group’s discussions on four key topics follow.
Leadership and strategy
Members of the group broadly welcome the increased emphasis on leadership and strategy in the revised standard. However, the mechanisms for delivering this will vary, in part, due to the size of the organisation.
Andrew Robertson, safety, health and environment manager for Hydram Engineering, an SME and family-owned business, believes that implementing these requirements will be reasonably straightforward because he is part of the senior management team. He explains that, since implementing 14001, the business has directly benefited from savings in areas such as waste, packaging and energy.
He says: “The owners saw the benefits, and resource-efficiency measures were integrated into the design of a large extension to the factory in 2013. In the future, an environmental element could be added directly into our business plan.”
In larger organisations, those with responsibility for the EMS are often further from the decision-makers who formulate business strategy. The challenge is, therefore, to ensure that directors see the benefits of embedding environment considerations into their decision-making processes, such as for acquisitions, new products or sourcing.
Kirsten McLaughlin, environmental manager (UK) at Parsons Brinckerhoff, is keen for top management to be more involved in the running of the EMS and thinks the new standard will encourage this. “Its greater emphasis on the role of leaders will make it easier for me to obtain the resources and commitment needed to improve our EMS and environmental performance,” she says.
Risks and opportunities
The requirement to determine an organisation’s risks – or “threats” in the DIS – and opportunities was seen as an important change by the group. While aspects are related to the impact the organisation has on the environment, risks and opportunities relate to the impact the external environment has on the organisation, and are informed by clause 4.1 – understanding the organisation and its context.
A standard aspect register may not fully address this, though in some organisations this analysis may have been done, at least in part, for other reasons.
Several participants provide examples of how their organisations address risk. Gordon Walker, environment manager at Northern Powergrid, which operates the major electricity distribution network in the North East, Yorkshire and northern Lincolnshire, reports that his company has a well-developed business resilience plan that includes environment risks, such as those related to climate change. “It covers not only an increased risk of flooding, but also issues like the implication of higher air temperatures on the network and the increased growth rate of vegetation around overhead lines,” he says.
Stewart Vale, environment, health and safety manager at Imerys Minerals, meanwhile, says external environmental factors are changing the market for the production and processing of industrial minerals, and therefore his business. “Changes in the economy and market demand have placed an increased importance on research and development to identify and promote new products and the associated environmental considerations that are associated with these.”
Participants also provide evidence of the sort of opportunities that can emerge if an organisation better manages its environmental impacts. Imerys, for example, has installed a solar farm to generate electricity, and has now received planning permission for a second one, while Northern Powergrid is looking at how the increasing use of renewables will affect the operation of the power network. “Switching to renewables creates risks, but the use of smart grid techniques to address things like intermittency of supply presents opportunities for customers and for companies providing new services and technologies,” says Walker.
The value chain
The group discusses the extent to which the new value chain requirements will require an assessment of the environmental impact of the products and services in addition to assessing the environmental performance of the supplier. Several members believe that their organisation’s existing environment procurement processes will suffice, while others think their processes will need to improve.
Robertson expresses concern that Hydram Engineering might be penalised for not having control over the materials it uses because its customers mainly determine selection. However, there is recognition that the new value-chain requirements apply only where they are related to an organisation’s significant aspects, risks or opportunities. The definition of significance retains the phrase “that [the organisation] can control and those that it can influence”, which is in the current version of 14001.
One example from the group of how environmental considerations are integrated into downstream processes is the product stewardship audits conducted by a chemical manufacturer of its customer’s handling and use of chemicals supplied. Nicola Martin, sustainability and environment manager for power transmission and distribution at Balfour Beatty, offers a further example. She says that environmental considerations are integrated into the project design process by the contractor even when a client has not asked for a specific environmental quality standard.
Bidwell comments that when environmental design tools, such as BREEAM or CEQAUL, are required on a project they are sometimes used as a tick-box exercise as a means to gain planning permission. Therefore, for sustainable design to add value it must be fully embedded in the ethos of the organisations rather than be seen as a bolt-on. He says there are many examples of organisations that are doing this for good business reasons, such as reducing costs by light-weighting products or reducing dependence on virgin resources by designing for re-manufacture. “Organisations should see the new design requirements as a business opportunity rather than a burden,” argues Bidwell.
14001: 2015 – 12 main changes
Structure of standard – changes to the structure of the standard in accordance with ISO’s new high-level structure (annex SL).
Understand the organisation and its context – a requirement to determine the environmental context of your organisation (clause 4.1); and a requirement to determine the needs and expectations of interested parties (4.2).
Leadership and strategy – increased focus on the role of top management, and ensuring compatibility between environmental policy and the organisation’s strategic direction (5.1).
Environmental policy – make additional commitments in the environmental policy to “protection of the environment” specific to the organisation (5.2).
Threats and opportunities – determine the risk to the organisation of environment threats and opportunities arising from external conditions; in addition to aspects and impacts (6.1.4).
Planning to achieve objectives – more detailed and specific environment management programmes (6.2.2).
Competence – a requirement to evaluate the effectiveness of actions taken to acquire competence (7.2).
Communication – requirement to plan communications, taking into account interested parties (7.4), which may involve additional external reporting; plus need to ensure the reliability of external communications (7.4), which may require increased data verification.
Value chain procurement – consider a lifecycle perspective when identifying environmental aspects (6.1.2), and develop more specific environmental procurement requirements (8.2)
Value chain: design and downstream – consider a lifecycle perspective when identifying environmental aspects (6.1.2), and consider environmental requirements at each stage of a product’s lifecycle – that is, design, development, delivery, use, and end-of-life (8.1).
Performance evaluation – an enhanced level of monitoring, measurement, analysis and evaluation as well as a requirement to determine methods to ensure valid results (9.1.1).
- Compliance status – maintain knowledge of compliance status (9.1.2).
Based on key changes in the published draft international standard (DIS). Comments can be made on the individual clauses of the DIS through the draft review site. The consultation is open until 31 October 2014. IEMA is encouraging all members to comment on the DIS.
Interested parties and communication
The group is interested in the nuances of the new communication requirements. Unlike the EU eco-management and assessment scheme, there is no explicit requirement in 14001 for an external report. Nonetheless, it requires communications to be planned, taking into account the requirements of relevant interested parties (or compliance obligations in the DIS), and assurance provided on the quality of the information (changed to “reliable” in the DIS).
Organisations with well-developed external communication systems will be able to apply them to help meet the new requirements.
Northern Powergrid has implemented and been assured against the AA1000 stakeholder engagement standard, for example. “AA1000 will be a good foundation for meeting the new requirements for understanding the needs and expectations of interested parties,” says Walker. “However, an additional focus on environment may be welcomed by stakeholders in some communication forums.”
Most of the organisations represented at the meetings place some environmental information in the public domain, and much of it is verified internally or externally due to existing regulatory schemes, such as the carbon reduction commitment scheme. Martin explains that Balfour Beatty, for example, has created an online dashboard for sustainability that includes details of its greenhouse-gas emissions, and both its waste and water intensity. It has also establsihed an expert stakeholder panel that reviews operations across Balfour Beatty.
“Although these requirements have been diluted in the DIS, there is still a requirement to ensure that information communicated is reliable, and it may be wise for some organisations to increase the level of assurance they have of their reported environmental information,” advises Bidwell.
The group is continuing to meet to discuss how existing processes in their organisations can be integrated with their EMS, or enhanced to meet the new requirements, ideally without creating more paperwork. Changes in the DIS will also be discussed at the next gathering. The meetings have produced some interesting findings on the extension of environment management systems into other areas, such as the value chain and strategic decision-making.
Marek Bidwell and Kirsten McLaughlin, in association with Dr Phil Longhurst at Cranfield University, would like to invite readers of the environmentalist to take part in a short survey looking at the implications of the changes to 14001 for their organisations. The questionnaire is available at bms-services.com/iso-140012015-survey.
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