YOUR HEADING HERE10.05.2011

ISO 14001 revision: what do the changes mean for business?A focus on strategic aspectsColleen Theron, director 14 July 2015

Introduction• Who am I ? • What do we do? • What will we cover this morning?

Some of our clients

Setting the scene • Societal expectations have evolved of increasingly

stringent legislation, restraint natural resources, supply chain challenges

• Increased international focus on companies and how they manage risk

• Greater focus on stakeholder engagement • Leadership key in attainment of resilient companies• ISO- normal review process

Basics of 14001 • Plan, Do, Check, Act approach• Demonstrates iterative process for

organisations to achieve continual improvement

• Benchmark environmental standard but previously more of a tick box exercise

ISO revision timeline • Proposed changes been on sale since 2 July

2014• Final DIS released in April 2015 • Final standard in Autumn of 2015

To whom does the standard apply? • Large and small business and industry• Service sectors • Government organisations • All types of organisations

Key changes • Greater expectation for top management to

understand the organisations environmental issues• Broader strategic consideration of organisations

environmental context, including the interests of stakeholders

• Specific commitments to sustainable development• Extending environmental influence in the supply chain • Demonstrating environmental compliance• Using KPIs to track improvement

New structure detail • Significant change• Context• Leadership• Processes rather than procedures• Compliance obligations• Need to view the requirements in a more

holistic manner

The new structure

Plan

CheckCorrect

Do6.

Planning5.

Leadership

10. Improvement

9.Performance evaluations

7/8 Support & operation

4.1 external

4.2 needs

3. Terms & definitions2. Normative references 1. Scope

4. Context of org.

Seven key changes 1. Greater expectation top management2. Broader strategic consideration of organisations

environmental context3. Specific commitments to sustainable development4. Extending environmental influence to the supply chain5. Embracing opportunities for using environmental

design as a tool for improvement6. Demonstrating environmental compliance 7. Using performance indicators to track performance

Context • Organisations to understand the internal and

external issues of an organisation• AND the needs and expectations of interested

parties

Leadership • Requirement strengthened - commitment and

active support / be accountable• Provide adequate resources• Expected to create a culture and environment

that encourages leadership roles • Integrate EMS into business processes

Processes rather than procedures • Multiple connections between different parts

of the new standard• Not written in a linear implementation way• Terminology- e/g ‘consider vs ‘take into

account’ ‘appropriate vs ‘applicable’ • Change management

Broad concept of risk • Organisation to understand the risk associated

with threats and opportunities • Also link risk to compliance

Interested parties • Standard requires the identification of

interested parties• Can include customers, regulators,

shareholders, investors and internal (e.g. marketing, finance, employees)

• Must understand their needs and expectations • Not prescriptive on how the needs or

expectations are evaluated

Tracking performance • Broadly align environmental objectives with

top management commitments• Aligned with environmental policy • Selection of indicators to achieve measureable

objectives• Indicators can be aligned with any regulatory

requirements

Extending environmental influence –procurement implications

• Specific requirement to address environmental issues in procurement: – evaluating the supply of goods, services and

outsourced processes, taking a lifecycle perspective

– specifying environmental requirements in procurement of goods (DO shorts book)

– communicating requirements to contractors

What does this mean in practice? • Holistic approach• Understand what internal and external

issues give rise to risk ( materiality? ) • Gain an understanding of internal and

external stakeholders • Not limited to solely environmental

factors

Challenges facing users• How to interpret the new requirements• How to get more business value out of the

system• Aligning the system with the business drivers • Competence and capability • Implementing the new standard from scratch

What should you be doing now? • Start planning for the transition • Consider training requirements

– Auditors/ management/ operational managers• Consider key changes to way business

operates – Stakeholder engagement, identifying material risk,

changes to procurement• Undertake a gap analysis

– Tool available: www.clt-envirolaw.com

Contact Details

Colleen TheronSustainability lawyer and consultantTel: +44 (0)7714979936 Email: colleen.theron@clt-envirolaw.com

ISO 14001 REVISION: WHAT DO THE CHANGES MEAN FOR BUSINESS?

A FOCUS ON COMPLIANCE OBLIGATIONS 14 JULY 2015

www.warburtons.co.za; www.imbewu.co.za; www.imbewuregisters.co.za

http://clt-envirolaw.com/

6. PLANNING

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Draft Standard:6.1.3 Compliance ObligationsThe organization shall:

a) identify and have access to the compliance obligations related to its environmental aspects;

b) determine how these compliance obligations apply to the organization.

The organization shall maintain documented information of its compliance obligations.

Existing Standard:4.3.2 Legal and other requirementsThe organization shall establish, implement and maintain a procedure(s)a) to identify and have access to the applicable legal requirements and other requirements to which theorganization subscribes related to its environmental aspects, andb) to determine how these requirements apply to its environmental aspects.The organization shall ensure that these applicable legal requirements and other requirements to which theorganization subscribes are taken into account in establishing, implementing and maintaining its environmentalmanagement system.

6. PLANNING

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• The compliance obligations section is now directly linked to risk associated with threats and opportunities in 6.1.4

• Risk required to be determined with associated threats and opportunities:

— Give assurance that the EMS can achieve outcomes— Prevent or reduce undesired effects— Achieve continual improvement

• Compliance obligations are also linked to documented information in 7.5

• Actions are required to address risks and compliance obligations (6.1.5 a)

— Actions must be integrated and implemented into the EMS processes and the effectiveness of the actions must be evaluated.

7.5 DOCUMENTED INFORMATION

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Definition (3.7)Information required to be controlled and maintained by an organisation (3.1) and the medium on which it is contained

-Necessary for the effectiveness of the EMS-Will vary in content and extent depending on organisation-Must be appropriate-Must be updated, reviewed & approved for suitability & adequacy-Must be available & protected & controlled-Necessary external documents must also be controlled in the system

E.g. Legal Registers, compliance audits, management plans to address compliance obligations etc ..

9. PERFORMANCE EVALUATION

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• Compliance obligations need to be monitored and measured.

• The methods for monitoring measurement analysis and evaluation must be specified to ensure valid results, including timing of such monitoring, measurement & evaluation. The results must be documented.

9.1.2. EVALUATION OF COMPLIANCE

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Draft Standard:9.1.2 Evaluation of Compliance The organization shall plan and implement a process to evaluate conformity with its compliance obligations.

The organization shall:•determine the frequency that compliance will be evaluated;•evaluate compliance and take action if needed;•maintain knowledge and understanding of its status of conforming with compliance obligations.

The organization shall retain documented information as evidence of the compliance evaluation result(s).

Existing Standard:4.5.2 Evaluation of compliance4.5.2.1 Consistent with its commitment to compliance, the organization shall establish, implement and maintain a procedure(s) for periodically evaluating compliance with applicable legal requirements.The organization shall keep records of the results of the periodic evaluations.4.5.2.2 The organization shall evaluate compliance with other requirements to which it subscribes. Theorganization may wish to combine this evaluation with the evaluation of legal compliance referred to in 4.5.2.1or to establish a separate procedure(s).The organization shall keep records of the results of the periodic evaluations.

9.2 INTERNAL AUDIT

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• Internal audit required to provide information on whether the EMS conforms to the standard, the co’s own requirements and is effectively implemented and maintained.

• The audits must take into account the risks associated with threats and opportunities as well as the results of previous audits (includes compliance audits).

• Audit programme and audit results to be retained as documented information and required to assist with management review.

• Therefore Compliance issues are integrated into the entire management process.

9.3 MANAGEMENT REVIEW

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• Management review must consider changes in compliance obligations and risks associated with threats and opportunities.

• All to contribute towards continual improvement (10.2) to enhance environmental performance.

CONTACT DETAILS

THANK YOU

CATHERINE WARBURTON

Warburton AttorneysIMBEWU Sustainability Legal Specialists (Pty) Ltd

53 Dudley Road, Cnr Bolton AvenueParkwood, Johannesburg.

Tel: 011 447 6848/0Fax: 011 447 6868

www.warburtons.co.za; www.imbewu.co.za; www.imbewuregisters.co.za

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