A survey carried out by Zutshi and Sohal (2004) gives a general picture as to the per- ceptions and experiences of the organizations with respect to EMS implementation.
The findings can be briefly summarized in the following points:
1 Employees play a significant role in the successful adoption of an EMS. They need to be made aware and trained in the basics and significance of EMS both for the organizations and the employees themselves. The communication and training pro- vided by the organization (especially during the initial stages of the EMS adoption process) both increases employee knowledge and understanding of the EMS process itself and would also assist in reducing their resistance towards the EMS implementation and the changes being made.
2 The contributions made by suppliers to an organization’s EMS process are still reserved and restricted. Organizations thus need to build trust and long-term rela- tionships with their suppliers to obtain full benefits from their suppliers’ involve- ment during the implementation process.
3 Organizations, when calculating the payback period from the EMS implementa- tion, need to understand that not all the benefits from EMS implementation are quantifiable in dollar terms. Moreover, many benefits to be realized are long rather than short term.
4 Ambiguity, duplication and wastage reduction of resources are feasible only through integration of their existing management systems and audits with EMS.
5 EMS implementation costs would also be reduced if organizations learn from their past experiences of implementing other systems ISO 9000, OHS and from the experiences of other industries in the same field.
The considerable difference reported between the registration rate of ISO 14001 environ- mental management system (EMS) and the implementation rate of environmental impact assessment (EIA) in the construction industry in Mainland China clearly indicated that
ISO 14000: A Promising New System for Environmental Management or Just Another Illusion?73
(Euros)
Definitions New terms and definitions to ● The definition of auditorhas been aligned Document only Nil High alignment
increase compatibility with ISO with the definition in ISO 9000:2000. with ISO 9001
9001 regarding: Organizations will need to demonstrate that
● auditor their (internal) auditors are competent and
● continual improvement auditor competence must be defined in the
● corrective action organization’s EMS
● document ● The definition of continual improvementhas
● internal audit been amended with an additional emphasis
● non-conformity that the process must be a recurringone.
● preventive action The organization must be able to demonstrate
● procedure that the continual improvement process is
● record recurring and is not a one-off event
Revised standard removes ● Internal audithas replaced the term definition of EMS Audit Environmental Management System Audit,
partly to avoid confusion by users of the standard with external (certification) audits.
The wording of the definition has been amended to emphasize that internal audits must be independent. The focus of the internal audit has changed from one of determining conformance of the EMS to determination of conformance with the EMS audit criteria
● The definition of environmental performance has changed in focus from the
management system to the organization’s management of its environmental aspects.
Organizations will need to ensure that the evidence they use to demonstrate environmental performance improvement is in accordance with the revised definition
● The definition of prevention of pollution has been clarified to reflect methods and options for the prevention of pollution.
An organization will need to examine how it defines prevention of pollution (and its scope) to ensure that it covers new concepts of
‘creation, emission or discharge of any type of pollutant or waste’
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4.1 General More specific requirements for the ● The addition of ‘determine how it will fulfill Document only Nil High alignment requirements organization to clearly define and these requirements’ to clause 4.1 requires the with ISO 9001 and scope document the scope of its EMS, organization to state how the EMS fulfills the
continually improve the EMS requirements of ISO 14001. The process will and to determine how it need to be traceable. It will be insufficient to will fulfill the requirements claim that the internal audit cycle covers all
clauses of the standard and therefore you are able to demonstrate that the EMS fulfills the requirements of ISO 14001
● Ensure that the scope of the EMS is clearly defined and documented, including what activities, operations, services and products are included within the scope. For
organizations seeking accredited certification, the EMS scope must agree with the
requirements laid down by accreditation rules.
These preclude organizations from ‘ring fencing’ their EMS scope to exclude difficult areas or areas that are part of their site
4.2 The policy is consistent with the ● To comply with the requirement for the The policy shall not € Low alignment Environmental scope of the EMS (i.e. that environmental policy to be consistent with the go beyond the with ISO 9001 policy it covers all activities, products scope of the EMS, the environmental policy scope. On the
and services within must not cover issues that are wider, narrower legislation side it now scope). In addition, the or different from that of the EMS scope goes beyond pure standard requires ● To demonstrate compliance with the new environmental that the policy requirements the environmental policy must: legislation. It can be communicated to – Be developed by top management include health and
‘all persons working for or – Cover the scope of the EMS safety regulations, on its behalf’ and not just – Cover all activities, products and for instance,
‘employees’ services within the scope of the EMS if applicable to
– Reflect the amended terminology environmental aspects.
with regard to applicable legal and This change also
other requirements applies to clauses
– Be communicated to everyone working 4.3.2 Legal and for or on behalf of the organization. other requirements This includes contractors, subcontractors, and 4.5.2 Evaluation temporary staff and remote workers of compliance
ISO 14000: A Promising New System for Environmental Management or Just Another Illusion?75
control and those it can ● The requirement has been changed to those environmental influence. Clarifications to ensure activities, products and services that it can aspects were not no activities, products or services are influence. This means there is now a clear previously included, excluded from aspects assessment. requirement to determine those aspects that an this change may cause This provides organizations with organization can influence in addition to those a more in-depth flexibility to define scope but they it can control. The procedure for identifying review of the system cannot include only activities aspects and impacts needs to be revised
and exclude services and products. to ensure that it incorporates activities, It is also implies that the products and services that can be organization will need to consider influenced within the scope of its EMS those it can influence (i.e. aspects ● The aspect identification procedure needs to relating to goods provided cover planned or new developments, or new through the supply chain) or modified activities, products and services
● identify aspects for new ● Organizations are required to document developments, or new or modified the whole process of identifying their activities, products and services. environmental aspects and This is to ensure changes in determining which are significant operations are evaluated
appropriately and aspects identified
● consider significant aspects in establishing, implementing and maintaining its EMS. This extends the previous standard requirement which required significant environmental aspects to be considered in developing objectives and targets. Document the information from the identification and evaluation process. Clarifies existing requirement
● clear requirement for the information from the process is documented.
Changes clarifies that the intent of an EMS is for identifying and managing significant aspects
4.3.2 Legal and More specific to: ● The change in the wording of the The final output is €–€€€ Low alignment other ● determine the legal and other requirement (in this clause and in more complex than a with ISO 9001 environmental requirements relevant to the Environmental Policy) means that simple list, as is
requirements organization’s environmental organizations will have to take into account the (hitherto) aspect, and how these apply all legal requirements that relate to their current practice. As
environmental aspects. This means that not
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● ensure that the environmental only the directly applicable environmental per the legal and other requirements legislation but also other environmental commitment are considered in developing, aspects related legislation e.g. COMAH made in the policy implementing and maintaining (Control of Major Hazards and Accidents). (4.2), ‘non- its EMS Organizations will need to determine howthe environmental’
The changes are to clarify that legal and other requirements apply to legal and other the organization needs to establish their environmental aspects, ensuring that requirements may and understand the applicable these are reflected in the EMS overall have to be included requirements and not just have
access to them. The revised standard eliminates the direct reference to environmental requirements. The purpose of this is to remove the potential for misinterpretation that only those requirements from environmental agencies/bodies are relevant (i.e. requirements from OHandS requirements may contain relevant requirements).
The changes also increase the emphasis on compliance by stating that the requirements are taken into account in establishing, implementing and maintaining the EMS
4.3.3 The requirements of the 1996 ● Organizations need to demonstrate through Document only Nil Medium alignment
Objectives, Standard Clause 4.3.3 (Objectives the EMS that the objectives are consistent with ISO 9001
targets and and Targets) and 4.3.4 with the above
program(s) (Environmental Management Program(s)) are now incorporated in Clause 4.3.3 of revised Standard.
The structure change is to improve the links between the goal setting and program/planning processes to achieve these goals.
The revised standard now requires that objectives and targets are to be
ISO 14000: A Promising New System for Environmental Management or Just Another Illusion?77
environmental requirements and continual improvement and not just those related to the prevention of pollution.
The changes also require that significant aspects and legal and other requirements must be taken into account rather than just considered in developing objectives and targets
4.4 Implementation and operation
4.4.1 Revised standard requires that ● The revised clause incorporates resources, No significant Nil Medium alignment
Resources, resources (provided by roles and authority, in addition to impacts, but with ISO 9001
roles, management) be provided for responsibility, which need to be potentially more responsibility establishing, implementing, reflected in the EMS and documented responsibilities to
and authority maintaining and improving the procedures the management
EMS ● Organizations are now required to ‘ensure representative
The revised standard includes the the availability’ of resources rather than when reporting to phrase ‘improving the EMS’ in ‘provide’. This will mean, for example, that the top management order to strengthen and facilitate the organizations will need to demonstrate that (see 4.6), including intent of continual improvement. It there are contingency plans in place to ensure recommendations also includes ‘organizational that competent people are able to fulfill for improvement infrastructure’ as a resource along specific EMS roles
with human resources
4.4.2 Any person(s) performing tasks on ● The requirement for competence, training May imply training €–€€ Medium alignment Competence, its behalf that have the potential and awareness has been extended to of subcontractors, with ISO 9001 training and to cause significant environmental incorporate all persons performing tasks salespeople, home-
awareness impacts shall be competent. for or on behalf of the organization. The based employees, if Persons now specifically includes organization will need to review all people not done already.
contractors, temporary staff etc. working for or on behalf of it to ensure they The same change (Note – 1996 Standard refers to are competent to fulfill their role in the EMS. applies to the policy.
‘Personnel’) Records must be retained by the organization Competence records The inclusion of ‘competence’ as that demonstrate competence (on the basis were kept in most the first word in the title increases of education, training or experience) of people of the EMS anyway the emphasis on competence. performing tasks that have the potential to
Other changes are terminology and cause a significant environmental impact structure of the clause ● The organization will need to ensure that all
people performing tasks for or on behalf of the organization, which includes contractors, subcontractors, temporary staff and remote
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assessment for their potential to cause a significant environmental impact and the associated competence required
● The revised wording in paragraph two allows flexibility for the organization to develop the skills and competence to fulfill EMS functions, rather than simply requiring training
4.4.3 The revised standard requires ● If the organization decides to communicate Document only – Nil–€€ Medium alignment Communication that if the organization decides its environmental aspects it needs to most organizations with ISO 9001
to communicate externally about establish methods of communication in its will prefer to its significant environmental EMS. The decision regarding this matter must communicate aspects, it shall document the be documented by the organization. Most externally than to decision and establish method(s) organizations do communicate their issue a documented for the external communication environmental aspects: sometimes actively to decision not to
all the public, e.g. through an environmental communicate report or by the use of an environmental
mark/logo on their product; sometimes selectively to people who ask about their performance; sometimes as part of legal requirements, e.g. monitoring returns to environmental regulators. In all these cases the organization will need to establish its methods for communicating. It is probable that only very few organizations do not communicate in some way and hence do not need a method of communication
4.4.4 The title of clause in the revised ● The organization will be required to Potential Nil–€ Medium alignment Documentation standard has been amended to demonstrate that the above documents simplification, but with ISO 9001
documentation. This is to reflect are in place to ensure the effective planning, most organizations alignment with ISO 9001:2000. operation and control of processes which will need to use The revised standard more relate to significant environmental aspects. documented specifically identifies the The extended requirements are in accordance procedures. However, documentation required to be with the requirements of ISO 9000:2000 new documents are
included in the EMS as: required: scope,
● Environmental policy, environmental aspects,
objective and targets decision on external
communication,
ISO 14000: A Promising New System for Environmental Management or Just Another Illusion?79
to related documents applicable
● All documents/ operational controls
records required and conformity
by the standard with the
● All documents/records organization’s
needed to demonstrate environmental
the effective planning, objectives and
operation and control targets. The overall
of processes that related to EMS, policy,
significant aspects objectives and
targets, responsibilities, and external communication still need to be documented
4.4.5 Control of The title and clause text of the ● Title and wording has been changed No need to revise Nil High alignment
documents revised standard have been to align with ISO 9000:2000 documents with ISO 9001
changed to reflect alignment ● The organization will need to demonstrate, periodically any more, with ISO 9001:2000 in addition to the existing requirements, how except for emergencies
The revised standard includes documents are approved for adequacy prior to (see 4.4.7) more specific requirements to issue and how documents of external origin,
control documents from external such as licences, are identified and their origin/sources which are distribution is controlled
relevant to the EMS
Note: reference to ‘documented procedure’ in 1996 standard has been replaced with ‘procedure’
4.4.6 The text of the revised standard ● No additional requirements No significant Nil Medium alignment
Operational has been changed for clarification, impacts with ISO 9001
control however, the intent remains the same. The clause now includes the term ‘implementation’ with respect to procedures to strengthen the intent (for controlling significant aspects and continual improvement)
4.4.7 The revised standard contains an ● Organizations should check that their No significant Nil Low alignment Emergency additional specific requirement existing procedure covers the ‘identification impacts with ISO 9001 preparedness for the organizations to of potential emergency situations and
and response
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mitigate or prevent adverse an impact on the environment and environmental impacts. The 1996 how it will respond to them’
standard contained requirements ● Procedures must also cover actual for establishing and maintaining, emergency situations
and reviewing and revising ● Organizations will also be required procedures, but was not explicit to demonstrate that the procedures regarding the need to respond have been periodically reviewed 4.5 Checking
4.5.1 The revised standard requires ● Applicable has replaced relevant when No significant Nil High alignment
Monitoring and ‘documenting of information to referring to operational controls. impacts with ISO 9001
measurements monitor performance…’. The 1996 Organizations will need to update their standard requirement was procedures to reflect this change.
‘recording’ this information. The revised standard also now requires a procedure to document information required to monitor performance, applicable operation controls and conformity with objectives and targets
The intent is to strengthen the monitoring element which is essential for facilitating improvement
Note: The 1996 standard to evaluate compliance with applicable environmental legislation and other requirements is separated into its own clause (Clause 4.5.2) – refer below
4.5.2 Evaluation New clause and most obvious ● Organizations will be required to retain Can imply a €–€€€€ Low alignment of compliance change to revised standard. This records of the periodic evaluation of legal broader exercise with ISO 9001
clause has been prepared from the compliance undertaken. Note should be made to include other last paragraph of 4.5.1 in the 1996 that this clause requires organizations to requirements.
standard version. It requires a undertake an evaluation of compliance against Consequently, if procedure for periodically all legal and other requirements and that this non-compliance is evaluating compliance for both will be a pre-requisite of accredited certification. found, financial legal environmental requirements This means that compliance against each investment for
ISO 14000: A Promising New System for Environmental Management or Just Another Illusion?81
covering ‘other requirements’ ISO 14001:2004; it will not be acceptable it emphasizes the increase in scope for organizations to claim that the from purely ‘environmental periodic evaluation will be covered requirements’ to all ‘other by their internal EMS audit
requirements’ programme at some future date
4.5.3 Non- The revised standard clarifies the ● Organizations need to review and update New requirements €–€€ High alignment conformity, requirement to have a their procedures as appropriate and ensure for identification with ISO 9001 corrective and procedure to: that they incorporate, in particular, the and investigation
preventive ● investigate and determine causes prevention of recurrence of non-conformities of causes of non- actions of actual non-conformity and and the prevention of potential non- conformities.
to take action to prevent recurrence conformities Effective and
● investigate potential non- ● The organization’s processes must also be preventive actions conformities and assess the need reviewed to ensure that it evaluates the need are also required for implementing preventive actions for action to prevent non-conformities and
● review effectiveness of corrective implement appropriate actions to avoid and preventative actions their occurrence
The definition of ‘non-conformity’
as ‘non-fulfillment of requirement’
increases the scope of what a conformity covers, as this now implies non-compliance is a non- conformity, in addition to failing to meet an EMS requirement
4.5.4 Control The text of revised standard has ● Organizations need to ensure that all No significant Nil High alignment
of records been rearranged in which the records used to support the EMS and the impacts with ISO 9001
specific records required are no standard demonstrate compliance with longer listed. Instead the clause the EMS, procedures and results contains a requirement to have: ● Record retention times are no longer
‘Records as necessary to required by the standard, although record demonstrate conformity to the retention is still required
requirements of its EMS and the Standard’ Records which are required specifically are identified under the relevant clause (including evaluation of compliance, monitoring and measurement)
4.5.5 Internal The title of the revised standard has ● The organization will need to demonstrate No significant Nil Medium alignment audit been amended to reflect alignment that audits have been planned and an audit impacts, except with ISO 9001
with ISO 9001:2000 program is in place – this may be done when new auditors
(Continued)