ISO 14001:2015

GAP GUIDE

This document provides an overview of the key changes

between the 2004 and 2015 version of ISO 14001 there
are several new requirements in addition to changes to key
definitions. You will need to prepare for change and adapt
your environmental management system to meet the new
requirements and transition timelines.
ISO 14001:2015 TIMELINE

WE ARE HERE TO HELP

Draft International Standard (DIS) - published

in July 2014
Final Draft International Standard (FDIS) expected June 2015
ISO Standard - expected Q3, 2015

We will help you understand the changes,

interpret the new concepts and act on the
implications.

STRUCTURE OF ISO 14001:2015

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The structure of ISO 14001:2015 follows the

high level structure being applied to all new and
revised ISO management system standards:

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1. Scope
2. Normative References
3. Terms and Definitions
4. Context of the Organisation
5. Leadership
6. Planning
7. Support
8. Operation
9. Performance Evaluation
10. Continual Improvement

Following publication there will

be a three-year transition period
for organisations currently using
ISO 14001:2004 to switch to ISO
14001:2015

GAP ANALYSIS AND GUIDANCE

ISO 14001:2015 CLAUSES

ISO 14001:2004 CLAUSES

GUIDANCE

4 Context of the organisation

4.1

Understanding the organisation and

your context

New requirement!

4.2

Understanding the needs and

expectations of interested parties

New requirement!

4.3

4.4

Determining the scope of the

environmental management system

Environmental management system

4.1 General requirements

4.1 General requirements

This new concept relates to the factors and

conditions affecting organisational operation
e.g. regulation, governance and environmental
conditions.
Environmental conditions are the elements of
the environment which can be affected by the
organisation (air quality, water quality, land use,
etc.), or those which can affect the organisation
(climate change, existing land contamination, etc.).
Consideration should be given to who the
interested parties might be and what their relevant
interests might be, e.g. employees, neighbours,
customers, shareholders, board members,
competitors, regulators, etc.
The needs and expectations of interested parties
can become compliance obligations.
It is no longer permissible to exclude activities,
products and services from the scope of the
environmental management system which can
have significant environmental aspects.
Consideration needs to be given to a number of
specified factors when establishing the scope of
the EMS. The scope now needs to be available to
interested parties.
Consideration needs to be given to the knowledge
referenced in clause 4.1 on the context of the
organisation when establishing and maintaining
the environmental management system.

5 Leadership
5.1

Leadership and commitment

New requirement!

5.2

Environmental policy

4.2 Environmental policy

5.3

Organisational roles, responsibilities

and authorities

4.4.1 Resources, roles,

responsibility and authority

Top management of the organisation are

now required to demonstrate leadership and
commitment to the EMS in a number of specified
ways.
The policy commitment to the prevention of
pollution has been replaced by the need for an
overarching policy commitment to the protection of
the environment. This is to include the prevention
of pollution and other issues (such as sustainable
resource use, climate change mitigation and
adaption, etc.).
There is no longer a need for a management
representative(s), however the roles,
responsibilities and authorities previously assigned
to them still need to be assigned within the
organisation.

6 Planning
6.1

Actions to address risk associated

with threats and opportunities
6.1.1 General

New requirement!

6.1.2 Significant environmental aspects

4.3.1 Environmental aspects

6.1.3 Compliance obligations

4.3.2 Legal and other requirements

6.1.4 Risk associated with threats and

opportunities

New requirement!

Consideration needs to be given to identified

internal and external issues (4.1) and the needs
and expectations of interested parties (4.2).
The identification of aspects and impacts now
needs to consider a life cycle perspective. It has
now been made explicit that this shall also take into
account abnormal and emergency situations.
Compliance obligations is the new term for
legal and other requirements this gives equal
weighting to non-legislative mandatory obligations
and voluntary obligations as legal requirements.
Documented information on compliance
obligations must be maintained.
This is a new concept which requires the
identification of the risk (defined as the effect of
uncertainty on objectives) associated with threats
and opportunities that need to be addressed,
whilst maintaining documented information on
these.

GAP ANALYSIS AND GUIDANCE

ISO 14001:2015 CLAUSES

ISO 14001:2004 CLAUSES

6.1.5 Planning to take action

New requirement!

6.2

4.3.3 Objectives, targets and

programme(s)
4.3.3 Objectives, targets and
programme(s)

Environmental objectives and

planning to achieve them
6.2.1 Environmental objectives

GUIDANCE
The organisation needs to plan to take actions
to address risk associated with threats and
opportunities, significant environmental aspects,
and compliance obligations.

The term targets is no longer used, however the

requirements for what would be known as targets
are included in clause 6.2.2.
When setting objectives consideration now needs
to be given to the risk associated with threats and
opportunities.
The standard no longer includes a specific need
to consider the views of interested parties when
establishing objectives and targets, however these
will still be covered if any compliance obligations
(which do still need to be considered) have been
set based on the needs and expectations of these
interested parties.

6.2.2 Planning actions to achieve

environmental objectives

4.3.3 Objectives, targets and

programme(s)

There are now specific requirements for the

objectives to be monitored, communicated and
updated as appropriate.
The term programme is no longer used and the
standard talks about planning how to achieve
environmental objectives instead. This planning
now needs to include details on what resources will
be required and how the results will be achieved.

7. Support
4.4 Implementation and operation
7.1 Resources

4.4.1 Resources, roles,

responsibility and authority

No significant change.

7.2 Competence

4.4.2 Competence, training and

awareness

Persons now need to be competent if they

can affect the organisations environmental
performance, rather than if they have the potential
to cause a significant environmental impact.
The need for training has been expanded into a
wider need for taking actions to acquire necessary
competences, which can also include mentoring,
re-assignment or hiring / contracting activities.

7.3 Awareness

4.4.2 Competence, training and

awareness

7.4 Communication

4.4.3 Communication

7.4.1 General

4.4.3 Communication

This section has been rewritten, however the

requirements are largely the same.
Requirements are now more prescriptive as to
what the process for communications (internal and
external) shall be. New requirements include the
need to ensure that it is planned what, when, how
and with who communications are made, and that
the communications take into account compliance
obligations, are consistent with the EMS and are
reliable.
Communications on the EMS must be responded
to.

7.4.2 Internal communication

4.4.3 Communication

The communications process must enable

persons working on the organisations behalf to
contribute to continual improvement.

7.4.3 External communication

4.4.3 Communication

The previous requirement on deciding whether

to communicate externally about significant
environmental aspects is no longer specific
referenced, as this is covered in the overall
communications process detailed in 7.4.1.

7.5

4.4.3 Documentation

Documented information

7.5.1 General

4.4.3 Documentation

The terms documents and records have been

replaced by the term documented information.

GAP ANALYSIS AND GUIDANCE

ISO 14001:2015 CLAUSES

ISO 14001:2004 CLAUSES

7.5.2 Creating and updating

4.4.5 Control of documentation

4.5.4 Control of records

7.5.3 Creating and updating

4.4.5 Control of documentation

4.5.4 Control of records

GUIDANCE
Specific reference is now made to the need for
ensuring appropriate format and media.
Controls now need to ensure that documented
information is adequately protected.
The document control activities to be addressed
by the system are specified.

8. Operation
4.4
8.1

Organisational planning and control

Implementation and operation

4.4.6 Operational control

Specific reference is now made to the planning of

operations, as well as their control.
Controls for processes should now be
implemented to prevent deviation from compliance
obligations, as well as from the policy and
objectives.
There are requirements for the control of planned
changes and the review of unintended changes.
It is now specified that outsourced processes are
controlled or influenced.

8.2

Emergency preparedness and

response

There are now requirements for determining

procurement activities and considering
requirements in design activities, taking into
account a life cycle perspective.
4.4.7 Emergency preparedness and There is now a specific requirement to prevent
response
the occurrence of emergency situations and
accidents.
The review and revision of the procedure should
now also take place in particular after tests.

9 Performance evaluation
4.5 Checking
9.1

Monitoring, measurement, analysis

and evaluation

9.1.1 General

9.3

Management review

4.5.1 Monitoring and measurement

4.5.1 Monitoring and measurement

4.6 Management review

Greater detail on requirements for monitoring and

measurement activities is specified.
There is a specific requirement for the evaluation of
performance and the use of indicators.
Changes in risk associated with threats and
opportunities need to be considered during the
management review process.
The consideration of the organisations
environmental performance now needs to include
trends in nonconformities and corrective actions,
monitoring and measurement results, conformity
with compliance obligations and audit results.
Review is required of opportunities for continual
improvement, rather than recommendations for
improvement.
The outputs of the management review shall
include any implications for the organisations
strategic direction.

10 Improvement
10.1 Nonconformity and corrective action

10.2 Continual Improvement

4.5.3 Nonconformity, corrective

4.5.3 action and preventive action

New requirement!

The specific requirement for preventive action has

been removed the entire management system
should be a tool for preventive action.
Actions to prevent recurrence of nonconformities
shall specifically include a determination of whether
similar nonconformities exist or could potentially
occur.
The EMS needs to be continually improved in order
to enhance environmental performance.

KEY CONCEPTS
Context of the Organisation
This is a new requirement to identify the internal and external
factors and conditions that affect an organisation. Examples
of internal issues could include an organisations culture and
capabilities, whilst external issues could include the effects
of climate change, flooding and the availability of natural
resources to name but a few.
The organisation needs to identify the stakeholders of its EMS
and any requirements they have.
Tip:
The context will influence the type and complexity of
management system needed.
Leadership
There is an explicit and enhanced requirement for top
management to demonstrate leadership and engage directly
with the system. This is an enhanced requirement relating to
top management.
Tip
Top management will need to take accountability for
the effectiveness of the EMS and provide support and
resources as necessary.

Strategic Environmental Management

Top management needs to ensure that the environmental
policy and environmental objectives are consistent with
the overall business strategy, and that management review
outputs include any implications for the strategic direction of
the organisation.
Tip:
This will be new territory for ISO 14001 audits and in
conjunction with the above, more audit time is expected
to be devoted to discussions with the organisations
leaders.
Risk Associated with Threats and Opportunities
This is a new concept introduced in the planning section
of the standard. It requires the organisation to identify the
effect of uncertainty (risk) associated with its threats and
opportunities and take action to address them.
Tip:
Threats and opportunities can include the negative or
positive impacts associated with environmental aspects
or compliance obligations (previously known as legal or
other requirements).
Life-cycle Perspective
The identification of aspects and impacts should now be
done whilst considering a life cycle perspective, i.e. from raw
material acquisition, or generation from natural resources to
end-of-life treatment.
A life cycle perspective should also be taken when
establishing value chain controls (see below).

Tip:
A life-cycle perspective does not require a detailed life
cycle assessment; a simple consideration of the life
cycle stages which can be controlled or influenced
would be sufficient.
Value Chain Control and Influence
Environmental requirements need to be established and
considered throughout the procurement and design activities
of the organisations products and services.
Tip:
Design processes would include development, delivery,
use and end-of-life treatment.
Performance evaluation
There is a new emphasis on the need for evaluation in
addition to the current requirements for measurement and
analysis.
Tip:
Evaluation is the interpretation of results and analysis.
This is not new to managers but is made explicit in
the standard for the first time. Processes may be
well defined and effective, but do they yield optimum
results? This may be a new challenge for internal audits.

AUDITING
The standard is written for the benefit of organisations, not
auditors. Auditors will need to understand and recognise
the extent and type of evidence that would be acceptable to
confirm compliance to the 2015 requirements.
ISO 14001:2015 auditors will be engaging in dialogue with
business leaders, seeking understanding and explanations
from them about policy, strategy and environmental
objectives, and ensuring these are compatible.
The audit experience from the client perspective is likely to be
different, but revisions to the audit process will deliver more
added value to the organisations being audited.

CONCLUSION
ISO 14001:2015 is expected to incorporate more business
management terminology and concepts and will ensure
that systems will be integrated into the organisations overall
business processes rather than being separate entities.
The changes will require effort from organisations to
implement, however the overall result will be a more effective
management system capable of achieving better results in
environmental performance.

GAP ANALYSIS AND GUIDANCE

MAJOR DIFFERENCES IN TERMINOLOGY
You will find that some of the familiar terminology of ISO 14001:2004 has either been changed or removed. Here are the highlights, but
please also refer to the key concepts above for additional guidance:

ISO 14001:2004
TERMINOLOGY

ISO 14001:2015
TERMINOLOGY

Legal and other requirements

Compliance obligations

Documents; records

Documented information

Management representative

Term not used

Preventive action

Term not used

Term not used

Leadership

Term not used

Risk

Term not used

Threat

Term not used

Opportunity

Term not used

Environmental conditions

Term not used

Life cycle

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