The purpose of this article is to review ISO 14001 requirements for identification and evaluation of organization’s environmental aspects. While the purpose of this article is not necessarily to focus on the ISO 14001: 2015 transition, we do reference ISO 14001: 2015 transition and use the text from the new standard in the discussion of environmental aspects.
The ISO 14001: 2015 standard was published September 2015 which means that companies have until either their re-certification or surveillance audit of 2018 (if it is prior to September of 2018) to successfully transition to the new standard. The new standard has a heightened top management requirement called leadership and it might be more successful for companies to start the transition earlier than latter to the cutoff date. We will write more about 2015 revision and best practices for the transition at a later date.
Without further ado, we first need to outline aspect identification and evaluation requirement:
“ISO 14001: 2015, 6.1.2 Environmental Aspects
Within the defined scope of the environmental management system the organization shall determine the environmental aspects of its activities, products and services that it can control and those that it can influence, and their associated environmental impacts, considering a life cycle perspective.
When determining environmental aspects, the organization shall take into account:
- change, including planned or new developments, and new or modified activities, products and services;
- abnormal conditions and reasonably foreseeable emergency situations.
The organization shall determine those aspects that have or can have a significant environmental impact, i.e. significant environmental aspects, by using established criteria.
The organization shall communicate its significant environmental aspects among the various levels and functions of the organization, as appropriate.
The organization shall maintain documented information of its:
- environmental aspects and associated environmental impacts;
- criteria used to determine its significant environmental aspects;
- significant environmental aspects.
Note: Significant environmental aspects can result in risks and opportunities associated with either adverse environmental impacts (threats) or beneficial environmental impacts (opportunities)” (ISO 14001:redline 2015(E), 6.1.2 Environmental Aspects, pages 11-12).
There is a lot to digest here, so let’s take it step by step.
What is an environmental aspect and impact?
The first question that needs to be answered is what is an environmental aspect and impact and how do I identify them. The second question is does my company even have environmental aspects and impacts. Well, to answer the second question first, yes, even the smallest companies have environmental aspects and impacts. They may not be significant, but they are present. Now to the first question, what is an environmental aspect and impact?
To put in the simplest terms, an environmental aspect is something that can have an impact or effect on land, air, or water. A BBQ restaurant using the finest cherry wood to smoke ribs is releasing smoke to the air, it may not be much, but it is still an environmental aspect. A tax office that uses pesticides in the planters outside the office is having an impact on land, it may be slight, but it is present. Finally, a trucking company that has a fleet of trucks come on and off the site can have fluids on the ground that are washed away into the storm drain during a storm and go to the ocean. That has an environmental impact. Environmental aspects are also the consumption and production of resources. A cellular phone store that keeps its store light on twenty-four hours is consuming a lot of energy. A dish manufacturer is creating a product that will eventually go into the trash and occupy a landfill. And the examples go on and on. We hope it is evident that any and all companies have several environmental aspects that have impacts on the environment.
We recommend you refer to the Annexes at the end of ISO 14001:2015 for additional information and guidance. Annex A to the ISO 14001:2015 standard has very helpful information about identifying environmental aspects. When implementing the standard, one should be living in the Annex. It will help the organization to implement an effective and efficient system that follows the spirit and intent of the standard. The Annex exists to assist in implementation and help with misinterpretation of the standard.
How to best identify aspects and impacts
Identifying aspects can be a daunting task, especially in a large organization. ISO 14001:2015 standard, there is no longer a requirement for a person in the organization to occupy the management representative role. However, the management representative should not necessarily be the one to perform the identification of the environmental aspects, even though that is what happens in a lot of situations.
A team of co-workers should identify the environmental aspects. If the management representative does all of the identification they might miss certain aspects in areas in which they don’t work simply because they are not familiar enough with that particular process to identify all aspects. Depending on the size of the organization, selecting a team that can split up the work and identify aspects in their own area is the most effective way of performing this required task.
Once the aspects are identify, one needs to score or evaluate them to determine their significance and place safeguards in the operation to control the significant aspects. There are many ways to score aspects and all of the methods have some level of subjectivity. It is highly recommended for an organization to choose a simple evaluation method of its environmental aspects. This will benefit the organization by allowing the organization to focus on actually environmental performance rather than a complicated system of paperwork, documentation, and scoring. One of the simplest methods is Failure Mode and Effects Analysis or FMEA where organization assigns scores for severity, frequency of occurrence and ease of detection of the potential aspect. We will write more about FMEA at a later article but if you simply search the internet for FMEA you will find lots of information.
Once the potential aspects are identified, the organization needs to review these aspects periodically or when a process(es) changes, new ones are added or taken away, or when new control measures in place. The best practice is to review of aspects on an annual basis or when any changes to the processes are implemented.
Difference from 2004
There are a few changes from the ISO 14001:2004 standard to the ISO 14001:2015 in regards to the environmental aspects. Under 2015, the company is not required to have a documented procedure on environmental aspects. However, it still may be beneficial for the company to have a procedure in place in order to ensure effective implementation. ISO 14001:2015 has a requirement for record keeping or, in the words of the standard, documented information on environmental aspects.
Second, the organization should consider the life cycle perspective on products under the ISO 14001:2015 standard. Before, organizations usually only considered impacts that occur on their facility, but now, the standard reaches further. So one must consider the energy the product takes after it leaves the facility, the recyclability of the product, and other possible impacts on the environment.
Third, one must consider foreseeable emergency conditions. Under the old standard, the identification of foreseeable emergency conditions was documented in the emergency preparedness and response portion of the standard. However, some of these emergency conditions can cause severe environmental impacts. For instance, in Southern California, an earthquake is always a foreseeable emergency condition, so hazardous liquids stored outside may tip over and drain into the storm drain. Usually, companies have secondary containment for hazardous liquids anyway, but these types of situations must be considered under the new standard.
Lastly, the new standard states that organization shall identify risks and opportunities. A multitude of environmental aspects may be risks because of the clean-up costs, the risk of regulatory violations and fines, and hazards to employees. Defining these risks will help a company to better manage these risks, and that is the essence of the standard. The annex notes, “The primary focus should be on the implementation of the environmental management system and on environmental performance, not on a complex documented information control system” (ISO 14001:2015 Annex A, Guidance on the use of this International Standard, A.7.5 Documented information, paragraph 1, sentence 2, page 39 –All rights reserved to ISO 2015).
In conclusion, although identifying and scoring or evaluating environmental aspects is one of the most daunting tasks required by the standard, an organization that works together as a team and that uses the identification and scoring to benefit environmental performance will be able to successfully implement an effective Environmental Management System, reduce its carbon footprint and reduce long-term liabilities associated with its potential environmental aspects.
