ISO 14001:2015 and Life Cycle Assessment

[Dr. L. Ramakrishnan]

Section 4.3.1 of ISO 14001: 2004 requires that impacts of PRODUCTS have to be identified and assessed. Obviously products have impacts throughout their life-cycle. Most of the impacts during the manufacturing of the product are covered under impacts arising out of the manufacturing activity. Aspects during use, for example "use of electrical energy" in an electrical / electronic product, or "emission of propellant" in a body spray etc., need to be addressed in the aspect -impact analysis. Similarly, when the product is disposed off, for example an electronic product, in case of incineration, an aspect like "emission of dioxin" (from flame retardant component) needs to be addressed. Generally these aspects are identified and are addressed in the design of the product through Eco-Design (Design for Environment) to reduce the impact of the product throughout the life cycle, through use and disposal (end-of-life) phase. Some aspects of Eco-Design, like Design for Disassembly, actually aim at the disposal stage, making the product disassembly for recycling easy. Unless the end-of-life impacts are identified and evaluated such eco-design are not possible. Hence a good ISO-14001 system should identify the product life cycle impacts, evaluate impacts and take actions to reduce/eliminate these impacts at the design stage.

My understanding is that IPR differs from EPR in this aspect of designing products keeping in mind the end-of-life issues.

MY experience with many organizations implementing ISO-14001 for the last 20 years is that most of them concentrate on the manufacturing aspects and service aspect and rarely on the product aspect. If one addresses product related impacts too in the ISO-14001 EMS, then one cannot but include life cycle aspects of the product. I worked in an electronics company; based on the product life cycle aspect, we had eliminated toxic substances like Cd, Pb, Cr (VI), PBBE, PBB in our products more than ten years before ROHS came into existence, the energy consumption of our products was reduced year on year, the mass of our products was reduced year on year, the products were made more recyclable, we also addressed packaging mass reduction, eliminated PVC in packing etc. All these are because the company had taken into consideration the total life cycle impact of the products while designing the products. I was involved in the ISO-14001 EMS (both 1996 and 2004 versions) establishment and maintenance in more than 20 factories of our organization and I can say that the product aspect was one of the main aspects of our system and each of the factories worked keeping in focus the total life cycle impact of the product. i.e. our aspects-impacts analysis included the total life cycle aspect of the product. This requirement has now been made explicit in ISO 14001: 2015.

 

[RyanFleser]

I'm wondering what folks are coming up with to demonstrate that they are taking a life cycle perspective? Has anyone had discussions or audits from their registrars around this matter?

 

[madwalker]

Hello, this is one of my first posts here

When I completed my auditor transition course it didn't come across to clear how to best address this requirement.

What I did take from the course is there is no requirement for a formal life cycle assessment however an organisaition should demonstrate they have at least considered life cycle. For a manufacturing company this could be something like what materials have been used for a product, how it's made and how a customer can recycle a product at end of life.

For our transition, I am working on this by adding a life cycle consideration comments box within our aspects and impacts register. It seems to me the most logical place to record or demonstrate our thoughts.

 

[Randy]

Life cycle also includes where does it come from, how was it made...Think "Cradle to grave"

 

[Jen Kirley]

But....what about "life-cycle assessment for a service"? How to address this?

What is your service? Do you use supplies? Transport? Utilities?

In general, I would like to point people to the lower half of page 24 in the Annex: A.6.1.2. It talks about "consideration" with acknowledgment that we cannot influence everything. But we can work to gain a better understanding of it and try to address factors of our choosing once we identify them and decide it's worth pursuing.

 

[Ian_Morris]

Hi there,

First time post on a subject that is interesting for our company as we are currently debating if lifecycle can be a permissible exclusion.
We provide professional advice to the building industry and as such provide advice on contracts, buying and selling properties, leases and so on. Any thoughts would be really appreciated.

 

[MRWardell]

I can tell you as an assessor for a CB, that there is a lot of disagreement amongst assessors regarding what needs to be included and how comprehensive it needs to be. 6.1.2 on aspects says "considering a life cycle perspective". The Annex says '“consider” means it is necessary to think about the topic but it can be excluded'. Our guidance has been that an organization can chose not to include aspects/impacts that might be a part of the life cycle of the product that are outside the scope or boundaries of the management system. There is less clarity as to what to expect an organization to do in order to conform to 8.1 if they do design. The organization needs to use a life cycle perspective, but it is not clear what that might mean or what outputs an assessor should expect. I would be interested to hear from organizations that have gone through transition regarding what their CB felt constituted conformance to 6.1.2 and 8.1

 

[charanjit singh]

Very interesting discussion. My clients will be due for up-gradation to ISO 14001:2015 only early next year. In the meantime here are some of my thoughts on the subject.

Life cycle consideration needs to focus on
a) the extent of adverse environmental impact the organisations's products or service can have over the processes and products of their customers.
b) the extent to which the organisation can use environment-friendly inputs
c) the extent to which the organisation can influence their suppliers to use environment-friendly materials and processes.

The products made for OEMs of professional equipment may have minimal influence on operations at their customers' ends, or on their suppliers processes. The life cycle perspective in such cases is therefore limited, more or less to the organisations own processes. Under the circumstances the best a CB auditor can do is to go into greater depth on the subject when auditing manufacturers of consumer products.

While life cycle perspective is an important consideration, it is worth mentioning that major contribution to environmental degradation comes from consumer items-particularly the plastic packaging and e-waste (electronic junk). Millions of tons of plastic waste and discarded electronic devices can be seen in any society. But unfortunately the language of the standard does not make it mandatory to ensure such items utilize bio-degradable material, as far as possible, to protect the environment before their manufacturers can be considered for certification.

 

[charanjit singh]

Under the circumstances, the best a CB auditor can do is to go into depth to verify whether the auditee organisation- particularly the manufacturer - has given sufficient thought to environmental impact of the product during it use and also when it is discarded.