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ISO 14001 Clarification of Intent

Questions and Answers


Compliments of U.S. SubTAG 1 TC 207

The following is the official US interpretations of the intent of ISO 14001 for environmental management systems.  The following procedure is used to submit questions for official interpretation (if your company is within the United States).

The procedure to be used by the U.S. SubTAG 1 to respond to these questions and provide responses is defined below.

Questions should be posed in a question format, be specific as possible, and preferably in a style to facilitate a concise answer. Question that are not clear will be returned to the submitter.  All questions must be submitted in written or electronic form to the American Society for Quality ("ASQ"), Attention: Administrator, U.S. ISO 14000 SubTAG 1, 611 East Wisconsin Avenue, P.O. Box 3005, Milwaukee, Wisconsin 53201-3005; or faxed to 414-273-1734, Attention: Administrator, U.S. ISO 14000 SubTAG 1.  The submitter name, affiliation, address and phone/fax number must be included. 

97-05.A1.R99-06

Question

Must objectives and targets be set which are explicitly related to the organization's commitment to pollution prevention or are the scope and content of objectives and targets solely at the discretion of the organization?

Answer

This question refers specifically to the setting of objectives and targets, which is covered by Section 4.3.3 of the standard.

This question, responded to below, also raises the issue that one cannot read a particular sentence or section of the ISO 14001 standard in isolation from the other sections of the standard. There is an interrelationship between the requirements in some sections with the requirements in other sections. This question deals with one of those interrelationships.

Section 4.3.3 does not by itself require that the documented objectives and targets explicitly mention prevention of pollution. However, Section 4.3.3 does require the organization to take legal requirements into consideration when setting its objectives and targets. It also clearly states that the objectives and targets "shall be consistent" with the organization’s environmental policy. The environmental policy, which is set by top management in writing and must be implemented and be made available to the public, must include commitments to the prevention of pollution. Therefore, while organizations have the discretion to set their own objectives and targets, they must do so within these parameters.

In addition, Section 4.3.3 is not the only section of ISO 14001 where the concept of prevention of pollution is addressed. The following sections of ISO 14001 are also relevant:

Section 4.2 Environmental Policy As noted earlier, the top management is required to define the organization’s environmental policy which, among other requirements, must include commitments to prevention of pollution, and this policy must be implemented and maintained. Section 4.2 states: "Top management shall define the organization’s environmental policy and ensure that it... includes a commitment to...prevention of pollution; …is documented, implemented and maintained and communicated to all employees..."

Section 4.3.2 Legal and other requirements An organization must have a procedure for identifying and having access to legal requirements applicable to its environmental aspects. Section 4.3.2 states: "The organization shall establish and maintain a procedure to identify and have access to legal...requirements...that applicable to the environmental aspects of its activities, products and services."

Section 4.4.6 Operational Control Documented operational controls must be established and maintained where their absence could lead to deviations from the environmental policy and the objectives and targets. Therefore, documented operational controls are necessary where their absence could lead to a deviation from the commitment to prevention of pollution. Section 4.4.6 states: "The organization shall identify those operations and activities that are associated with the identified significant environmental aspects in line with its policy, objectives and targets. The organization shall plan these activities, including maintenance, in order to ensure that they are carried out under specified conditions by a) establishing and maintaining documented procedures to cover situations where their absence could lead to deviations from the environmental policy and the objectives and targets;...".

Section 4.5.2 Nonconformance and corrective and preventive action Procedures need to be established and maintained to correct nonconformance's.

Please note that the above Q&A originally related to both compliance with regulatory requirements as well as prevention of pollution . The discussion on compliance with regulatory requirements has been moved to the subsequent Q&A 99-03.A1.

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97-05.A2

Question

Is Section 3, Definitions, binding and, if so, may an auditor determine whether "appropriate" objectives and targets have been set to meet the requirements of definitions 3.7 and 3.10?

Answer

The Introduction to Section 3 Definitions states: "For purposes of this International Standard, the following definitions apply." The only section of ISO 14001 against which an organization’s conformance is audited is Section 4, EMS Requirements, the terms of which are clarified by the Definitions in Section 3. With regard to objectives and targets, an auditor is limited to assessing whether the organization conforms to the requirements specified in Section 4.3.3. If documented objectives and targets are consistent with the environmental policy, including the commitment to prevention of pollution, and their development has considered the issues listed in paragraph two of Section 4.3.3, objectives and targets are consistent with the standard.

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 97-05.A3

Question

Does the standard's requirement for awareness training of employees pertains to all employees or only those whose jobs bear some relationship to environmental aspects and impacts?

Answer

ISO 14001, Section 4.4.2, does not specify that "all" employees must receive "awareness training". Rather, it states that "employees at each relevant function and level" must be made aware of the items listed in paragraphs a) through d) of Section 4.4.2. This can be accomplished by various means such as by training or some other means identified in the organization’s established procedures. However, the first paragraph of Section 4.4.2 also states that "(the organization) shall require that all personnel whose work may create a significant impact upon the environment, have received appropriate training.". This allows the organization to determine for itself which employees are in "relevant" areas. It is likely that such employees will have jobs with the potential for environmental impact. However, "awareness" and "training" does not have to be limited to such employees.

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97-05.A4

Question

Does the requirement that the EMS "`be implemented" imply that, in addition to organizational responsibility, there must be individual job assignments and actual performance of assigned jobs?

Answer

Responsibilities for implementing an organization's EMS are addressed in ISO 14001, particularly in Sections 4.3.4 a (responsibility for achieving objectives and targets - this section uses the term "relevant functions and levels" but does not address individual responsibilities), 4.4.1 (definition of responsibility and authorities to facilitate effective environmental management and responsibilities of the designated management representative), 4.4.2 (responsibility for addressing EMS nonconformance's - this section does not address individual responsibilities), and 4.6 (top management EMS review responsibility).

The phrase used throughout the standard, "`establish and maintain," indicates that establishing a procedure, program, or other activity is not sufficient. It also must be implemented. Therefore, an EMS that conforms to ISO 14001 requirements will (a) assign responsibilities in conformance with the above-referenced Sections and (b) ensure that such jobs are performed. If assigned jobs are not performed (i.e., implemented), the EMS will not be in conformance with stated requirements.

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97-05.A5

Question

In determining whether the environmental policy is "appropriate to the nature, scale and environmental impacts of the organization's activities, products or services," is it relevant for an auditor to determine whether the scope of the policy covers all of the management units within the organization being audited?

Answer

The auditor must determine whether the policy is appropriate for all of those management units that are within the scope of the EMS. The sum of those units must be consistent with the Section 3.12 definition of an "organization."

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97-05.A6

Question

Does ISO 14001 imply some consideration by the organization of legal requirements for training of employees in establishing competence and training?

Answer

ISO 14001 in Section 4.4.2 requires the identification of training needs. If an organization is legally required to provide certain kinds of training, such training should be identified as a "need."

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97-05.A7

Question

Does the requirement for management review of the EMS imply that the actual review "process" must be documented?

Answer

There is no stated requirement to document the "process".

This question also raises the issue that one cannot read a particular sentence or section of the ISO 14001 standard in isolation from the other sections of the standard. There is an interrelationship between the requirements in some sections with the requirements in other sections. This question deals with one of those interrelationships. Section 4.6 Management review states: "This review shall be documented." Section 4.5.3 Records states: "Records shall be maintained, as appropriate to the system and to the organization, to demonstrate conformance to the requirements of this International Standard."

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97-05.A8

Question

The phrase "shall establish and maintain a procedure" is used throughout ISO 14001. Does it require that all prescribed procedures be documented?

Answer

No. The ISO 14001 EMS Standard requires a number of procedures to be established and maintained. An additional requirement to document these procedures appears in three sections of the standard: 4.4.6 Operational Control, 4.5.1 Monitoring and Measurement (general) and 4.5.1 for compliance reviews.

It should also be noted that there are other documentation requirements in the standard that do not relate to procedures. It is left to the discretion of the implementing organization to determine whether to document procedures that are only required to be established and maintained. With regard to those procedures, the term "documented procedure" was expressly omitted to allow implementation flexibility.

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98-03.A1

Question

Does Section 4.3.2 "Legal and other requirements" require that the "facility" (the relevant organization) must have its own direct knowledge of the environmental legal requirements that are applicable to its products in all countries into which they may be exported and not be able to rely on either a related corporate entity which sells the product in a foreign country or an independent importer customer to which it ships the product to have and apply such information?

Answer

This question refers specifically to Section 4.3.2 which requires that "The organization shall establish and maintain a procedure to identify and have access to legal…requirements…that are applicable to the environmental aspects of its …products…".

Section 4.3.2 does require the organization to establish and maintain a procedure to identify and have access to legal requirements that are applicable to the environmental aspects of its activities, products or services. Specifically, with regard to products, the Standard does not specify geographic boundaries, nor how the identification and access requirement part of the Standard can be accomplished. It is up to the organization to establish its procedure as to how it will identify and have access to such legal requirements. This may depend largely on the scope of the EMS and the level of control an organization can exercise over its products as stated in Section 4.3.1. If the organization defines its procedure as depending on outside organizations to assist it in meeting that requirement, then that is the choice of the organization. The Standard provides flexibility to the organization to define how such legal requirements will be identified and who will do it.

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Question:

What is meant by the "commitment to comply" in Section 4.2(c) in ISO 14001?

Answer

To understand what is meant by the "commitment to comply," the standard has to be read as a whole and the relationship between the relevant provisions of the standard understood. The relationship between ISO 14001 and regulatory compliance is addressed in a number of places in ISO 14001.

Section 4.2(c) requires that top management define a policy that includes a commitment to compliance with relevant environmental legislation and regulations. This commitment must be reflected in the planning process (Section 4.3), implemented (Section 4.4) and maintained through the EMS. The organization must:

Establish and maintain a procedure to identify and have access to the legal requirements that are applicable to it. (Section 4.3.2)

Establish and maintain documented objectives and targets that take its legal requirements into account and are consistent with the policy commitment to comply. (Section 4.3.3) Compliance must be taken into account when setting objectives and targets, though objectives and targets do not need to include all compliance requirements.

Establish and maintain programs to achieve objectives and targets, including those relating to compliance with legal requirements. (Section 4.3.4) Programs must describe who is responsible for achieving the objectives/targets and how and when they will be achieved.

Establish and maintain documented procedures necessary to achieve the policy commitment to comply and compliance-related objectives and targets. (Section 4.4.6). Procedures may be necessary to meet compliance requirements that have not been explicitly identified in the objectives and targets.

Make employees aware of the procedures that apply to them, which would include those procedures related to compliance developed pursuant to Section 4.4.6. (Section 4.4.2). Employees’ whose work can cause significant environmental impacts must have received appropriate training and be competent based on training, qualifications, education and/or experience. To the extent that such work also involves legal requirements, such employees’ training and competence must also cover the capability to meet those requirements.

Establish and maintain a documented procedure to periodically evaluate compliance with legal requirements. (Section 4.5.1). These are the legal requirements identified pursuant to Section 4.3.3.

Establish and maintain a procedure for periodically conducting EMS audits, which necessarily include those elements of the EMS that are compliance-related. (Section 4.5.4).

Establish and maintain a procedure to correct nonconformance's. (Section 4.5.2). Detected non-compliance with legal requirements must be corrected.

Taken together, these provisions mean that an organization implementing ISO 14001 must systematically identify and manage its compliance obligations in line with the commitment to comply. This system must include the components listed above and be properly supported with adequate resources and defined responsibilities (Section 4.4.1), be documented (Sections 4.4.4 and 4.4.5), measured/monitored and audited (Sections 4.5.1 and 4.5.4) and have records created and maintained sufficient to demonstrate conformance to these requirements (Section 4.5.3). The top management commitment to comply is buttressed by the requirement that top management periodically review the adequacy and effectiveness of the EMS (Section 4.6).

Question

Must a regulated environmental aspect automatically be considered a significant environmental aspect?

Answer

No. Section 3.3 states that "[a] significant environmental aspect is an environmental aspect that has or can have a significant environmental impact." ISO 14001 does not establish the criteria for determining significance.

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99-03.A3

Question

When an organization is identifying its environmental aspects pursuant to Section 4.3.1, must it identify the environmental aspects of other organizations?

Answer

No. Section 4.3.1 requires that the organization "establish and maintain (a) procedure's) to identify the environmental aspects of its activities, products or services that it can control and over which it can be expected to have an influence, in order to determine those which have or can have significant impacts on the environment." This requirement applies to the environmental aspects of the organization implementing the EMS, not the environmental aspects of other organizations. Further, the requirement applies to those of its activities, products and services over which it has influence and control: both elements must be present.

99-03.A4

Question

Must each objective have a measurable target? Or can an organization have an objective without a measurable target?

Answer

Yes, each environmental objective must have at least one measurable environmental target. The definition of environmental target (Section 3.10) states "Detailed performance requirement … that arises from the environmental objectives and that needs to be set and met in order to achieve those objectives." Furthermore, Section 4.5.1 relating to Monitoring and Measurement states that the organization must "establish and maintain documented procedures to monitor and measure…. This shall include the recording of information to track ... conformance with the organization's environmental objectives and targets." Consequently targets must also be measurable.

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99-03.A5

Question

The definition of environmental targets says quantified "where practicable". What constitutes "practicable"?

Answer

Since the term "practicable" is not defined by the Standard, its meaning should be derived from its ordinary dictionary definition.

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99-03.A6

Question

The Standard only mentions the word "documented" or "documentation" eight times: Environmental Policy; Objectives and Targets; Roles, Responsibilities and Authorities; EMS Documentation; Operational Control Procedures; Monitoring and Measuring Procedures for Key Characteristics; Monitoring and Measuring Procedures for Evaluating Compliance; and Management Review. Are there any other documents that would need to be controlled?

Answer

Yes. The lack of specific requirements for documented procedures was intended to allow greater flexibility for the user to determine if documentation was needed (see Clarification 97-05.A8). However, whenever an organization chooses to go beyond the Standard’s minimum documentation requirements and provide for additional EMS documentation, all of its additional EMS documents must be controlled in accordance with Section 4.4.5 in the same manner as EMS documents expressly required by the Standard.


Reprinted by kind permission of the standards coordinator, ASQ, USA, 1999.

Posted October 1999.

The Elsmar Cove