Revision to ISO 14001

what the publication of the

2004 edition means for
organisations using the
standard

Institute of Environmental Management & Assessment

St Nicholas House
70 Newport
Lincoln
UK LN1 3DP
Tel: 01522 540069
Fax: 01522 540090
www.iema.net
December 2004

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The Revision to ISO14001: 1996 - what publication of the

2004 edition means for organisations using the standard
Background
The revision process of ISO14001:1996 has been completed and ISO 14001:2004 was
published on 15th November 2004. For organisations using ISO 14001 for their EMS, including those with accredited certification to ISO14001: 1996, a detailed summary of the
changes is provided below. Please note that the revision to the standard has resulted in
revised clause numbering, so care needs to be taken to ensure that the right clause is
referenced in ISO14001:2004. This document is best read in conjunction with the new
standard.
The International Accreditation Forum (IAF) has set out the transition arrangements for
accredited certification from ISO 14001:1996 to ISO 14001:2004. Details of the transition arrangements are included at the end of this document.
The following sections relate to the sections in the ISO 14001:2004 version.

Introduction and Section 1: Scope

Revised text has been included in the Introduction and Scope of the standard. These do
not significantly alter the text in ISO 14001:1996 and do not form part of the requirements
of the Standard.

Section 3: Terms and definitions

New definitions have been introduced to the revised ISO 14001 standard, these are
auditor, corrective action, document, internal audit, nonconformity, preventative action,
procedure and record.
Requirements:
The definition of Auditor has been aligned with the definition in ISO 9000:2000. Organisations will need to demonstrate that their (internal) auditors are competent and
auditor competence must be defined in the organisations EMS.
The definition of Continual Improvement has been amended with an additional emphasis that the process must be a recurring one. The organisation must be able to demonstrate that the continual improvement process is recurring and is not a one-off
event.
Internal Audit has replaced the term Environmental Management System Audit, partly
to avoid confusion by users of the standard with external (certification) audits. The
wording of the definition has been amended to emphasise that internal audits must be
independent. The focus of the internal audit has changed from one of determining
conformance of the EMS to determination of conformance with the EMS audit criteria.
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Organisations will need to ensure that they have clearly defined audit criteria.
The definition of Environmental Performance has changed in focus from the management
system to the organisations management of its environmental aspects. Organisations
will need to ensure that the evidence they use to demonstrate environmental performance
improvement is in accordance with the revised definition.
The definition of Prevention of Pollution has been clarified to reflect methods and options
for the prevention of pollution. An organisation will need to examine how it defines prevention of pollution (and its scope), to ensure that it covers new concepts of creation,
emission or discharge of any type of pollutant or waste.

Section 4: Environmental management system requirements

4.1 General requirements
Revision:
This clause of the standard now requires the organisation to establish, document, implement and maintain an EMS as previously, but also to continually improve the EMS and
determine how it will fulfil the ISO 14001 requirements.
A sentence has been added to the revised standard which requires the organisation to
define and document the scope of its EMS.
Requirements:
The addition of determine how it will fulfil these requirements to clause 4.1 requires the
organisation to state how the EMS fulfils the requirements of ISO 14001. The process
will need to be traceable. It will be insufficient to claim that the internal audit cycle covers
all clauses of the standard and therefore you are able to demonstrate that the EMS fulfils
the requirements of ISO 14001.
Ensure that the scope of the EMS is clearly defined and documented, including what activities, operations, services and products are included within the scope. For organisations seeking accredited certification, the EMS scope must agree with the requirements
laid down by accreditation rules. These preclude organisations from ring fencing their
EMS scope to exclude difficult areas or areas that are part of their site. Copies of the
EMS accreditation guidelines EA Guidelines for the Accreditation of Certification Bodies
for Environmental Management System are freely available from the UKAS web site at
http://www.ukas.com/information_centre/publications.asp#pubs_cb

4.2 Environmental policy

Revision:
The introductory statement to 4.2 now requires the organisations environmental policy to
be consistent with the scope of the EMS.
The wording under policy with regard to legal compliance has changed. The phrase
applicable legal requirements and with other requirements to which the organisation subpromoting the goal of sustainable development
through improving environmental practice and performance

scribes which relate to its environmental aspects replaces the text in ISO 14001: 1996,
which referred to relevant environmental legislation .
The policy must now also be communicated to everyone working for or on behalf of the
organisation.
Requirements:
To comply with the requirement for the environmental policy to be consistent with the
scope of the EMS, the environmental policy must not cover issues that are wider, narrower or different from that of the EMS scope.
To demonstrate compliance with the new requirements the environmental policy must:
o
o
o
o
o

Be developed by top management;

Cover the scope of the EMS;
Cover all activities, products and services within the scope of the EMS;
Reflect the amended terminology with regard to applicable legal and other
requirements; and
Be communicated to everyone working for or on behalf of the organisation.
This includes contractors, subcontractors, temporary staff and remote workers.

4.3.1 Environmental aspects

Revision:
The organisation is required to establish, implement and maintain a procedure to identify
environmental aspects of its activities, products and services within the scope of the
EMS.
The requirement to take account of the environmental aspects it can control and over
which it can be expected to have an influence has been changed to take account of the
environmental aspects it can control and those that it can influence. Additionally, text that
used to be in section on environmental programmes relating to planned or new developments, or new or modified activities, products and services has been moved to the aspects section; hence, moving the requirements to start earlier at the aspect identification
state for new projects.
Significant environmental aspects must be considered when developing, implementing
and maintaining the EMS, rather than in setting environmental objectives as is required in
ISO 14001: 1996.
Requirements:
Activities, products or services has been replaced with activities, products and services
within the scope of the organisations EMS.
The requirement has been changed to those activities, products and services that it can
influence. This means there is now a clear requirement to determine those aspects that
an organisation can influence in addition to those it can control. The procedure for identipromoting the goal of sustainable development
through improving environmental practice and performance

fying aspects and impacts needs to be revised to ensure that it incorporates activities,
products and services that can be influenced within the scope of its EMS.
The aspect identification procedure needs to cover planned or new developments, or new
or modified activities, products and services.
Organisations are required to document the whole process of identifying their environmental aspects and determining which are significant.

4.3.2 Legal and other requirements

Revision:
Amendment has been made to the wording on legal and other requirements (in line with
the revised wording in Environmental Policy). The phrase applicable legal requirements
and other requirements to which the organisation subscribes related to its environmental
aspects is included.
An additional point has been added that specifies that the organisation needs to determine how the requirements (legal and other requirements) apply to its environmental aspects.
As for 4.3.1 above, legal and other requirements must be considered in developing, implementing and maintaining the organisations EMS.
Requirements:
The change in the wording of the requirement (in this clause and in Environmental Policy)
means that organisations will have to take account of all legal requirements that relate to
their environmental aspects. This means that not only the directly applicable environmental legislation but also other environmental aspects related legislation e.g. COMAH
(Control of Major Hazards and Accidents). Organisations will need to determine how the
legal and other requirements apply to their environmental aspects, ensuring that these
are reflected in the EMS overall.

4.3.3 Objectives, targets and programmes

Revision:
Objectives and targets are required to be measurable where practicable.
In addition to the requirements in ISO 14001: 1996, objectives and targets must be consistent with the commitment to compliance with legal and other requirements and continual improvement.
Requirements:
Organisations need to demonstrate through the EMS that the objectives are consistent
with the above.

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4.4.1 Resources, roles, responsibility and authority

Revision:
Management are required to ensure the availability of resources.
Requirements:
The revised clause incorporates resources, roles and authority, in addition to responsibility, which need to be reflected in the EMS and documented procedures.
Organisations are now required to ensure the availability of resources rather than
provide. This will mean, for example, that organisations will need to demonstrate that
there are contingency plans in place to ensure that competent people are able to fulfil
specific EMS roles.

4.4.2 Competence, training and awareness

Revision:
The organisation is required to identify training needs associated with its environmental
aspects and its EMS and the organisation shall provide training or take other action to
meet these needs.
Organisations must establish and maintain procedures to make people performing tasks
for it, or on its behalf, aware of 4.4.2 a d (as required by ISO14001: 1996 but a broader
scope).
Requirements:
The requirement for competence, training and awareness has been extended to incorporate all persons performing tasks for or on behalf of the organisation. The organisation
will need to review all people working for or on behalf of it to ensure they are competent
to fulfil their role in the EMS. Records must be retained by the organisation that demonstrate competence (on the basis of education, training or experience) of people performing tasks that have the potential to cause a significant environmental impact.
The organisation will need to ensure that all people performing tasks for or on behalf of
the organisation, which includes contractors, sub-contractors, temporary staff and remote
workers, have had an appropriate assessment for their potential to cause a significant environmental impact and the associated competence required.
The revised wording in paragraph two allows flexibility for the organisation to develop the
skills and competence to fulfil EMS functions, rather than simply requiring training.

4.4.3 Communication
Revision:
The requirement now is for an organisation to decide whether or not to communicate externally about its significant environmental aspects and to document its decision. If the
promoting the goal of sustainable development
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decision is to communicate, the organisation shall establish and implement a method(s)

for this external communication.
Requirements:
If the organisation decides to communicate about its environmental aspects it needs to
establish methods of communication in its EMS. The decision regarding this matter must
be documented by the organisation. Most organisations do communicate about their environmental aspects: sometimes actively to all the public, e.g. through an environmental
report or by the use of an environmental mark/ logo on their product; sometimes selectively to people who ask about their performance; sometimes as part of legal requirements, e.g. monitoring returns to environmental regulators. In all these cases the organisation will need to establish its methods for communicating. It is probable that only very
few organisations do not communicate in some way and hence do not need a method of
communication.

4.4.4 Documentation
Revision:
The listed EMS documentation now includes the environmental policy, objectives and targets, a description of the scope of the EMS, a description of the main elements of the
EMS and their interaction and reference to related documents, documents and records
required by the standard, documents and records determined by the organisation as necessary to ensure the effective planning, operation and control of processes that relate to
the significant environmental aspects.
Requirements:
The organisation will be required to demonstrate that the above documents are in place
to ensure the effective planning, operation and control of processes which relate to significant environmental aspects. The extended requirements are in accordance with the requirements of ISO 9000:2000.

4.4.5 Control of documents

Revision:
The revised standard requires documents required by the EMS and the standard to be
controlled. Documents must be controlled in accordance with the requirements in 4.5.4.
Organisations will need to establish and maintain procedures to approve documents for
adequacy prior to issue, review and update as necessary and re-approve documents, ensure that documents remain legible, ensure that documents of external origin determined
by the organisation to be necessary for planning and operation of the EMS are identified
and their distribution controlled (and prevent the unintended use of obsolete documents,
and apply suitable identification to them if they are retained for any purpose).

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Requirements:
Title and wording has been changed to align with ISO 9000:2000.
The organisation will need to demonstrate, in addition to the existing requirements, how
documents are approved for adequacy prior to issue and how documents of external origin, such as licences, are identified and their distribution is controlled.

4.4.6 Operational control

Revision:
The organisation needs to identify and plan those operations associated with identified
significant environmental aspects and ensure that they are consistent with the environmental policy, objectives and targets. To ensure operations are carried out under specified conditions, the additional requirements are to establish and maintain documented
procedures to control situations where absence of documented procedures could lead to
deviations from the environmental policy, objectives and targets.
Requirements:
No additional requirements.

4.4.7 Emergency preparedness and response

Revision:
The requirements have been re-specified, stating explicitly that the organisation shall establish and maintain procedures to identify potential emergency situations and potential
accidents that can have an impact on the environment.
In addition, procedures must be established and maintained to respond to actual emergency situations and accidents.
The organisation is required to periodically review and, where necessary, revise its emergency preparedness and response procedures.
Requirements:
Organisations should check that their existing procedure covers the identification of potential emergency situations and potential accidents that can have an impact on the environment and how it will respond to them.
Procedures must also cover actual emergency situations.
Organisations will also be required to demonstrate that the procedures have been periodically reviewed.

promoting the goal of sustainable development

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4.5.1 Monitoring and measurement

Revision:
The requirements for a periodic evaluation of legal compliance have been moved from
section 4.5.1 ISO 14001: 1996 and form the basis of a new clause (4.5.2 see below).
The additional requirement for this clause is for the monitoring and measurement procedure to include a requirement to document information to monitor performance and applicable operational controls.
Requirements:
Applicable has replaced relevant when referring to operational controls. Organisations
will need to update their procedures to reflect this change. Note a fundament change.

4.5.2 Evaluation of compliance

Revision:
This is a new section and is split into two parts (4.5.2.1 and 4.5.2.2)
4.5.2.1 Requires the organisation to establish, implement and maintain a procedure(s) for
periodically evaluating compliance with applicable legal requirements and keep records.
4.5.2.2 Requires the organisation to evaluate compliance with other requirements to
which it subscribes and keep records. This can be combined with the evaluation of legal
compliance noted above.
Organisations must record the results (and maintain the records) of the periodic evaluation
of compliance and these will need to be considered at the management review (see 4.6).
Requirements:
Organisations will be required to retain records of the periodic evaluation of legal compliance undertaken. Note should be made that this clause requires organisations to undertake an evaluation of compliance against all legal and other requirements and that this
will be a pre-requisite of accredited certification. This means that compliance against
each and every piece of legislation / regulation relating to an organisations environmental
aspects will need to be evaluated before it can be considered to be in conformity with ISO
14001: 2004; it will not be acceptable for organisations to claim that the periodic evaluation will be covered by their internal EMS audit programme at some future date.

4.5.3 Nonconformity, corrective action and preventative action

Revision:
The requirement is for organisations to establish, implement and maintain a procedure(s)
for dealing with actual and potential non-conformities and for taking corrective and preventative action.
The procedure needs to define requirements for identifying and correcting nonpromoting the goal of sustainable development
through improving environmental practice and performance

conformities and taking actions to mitigate their environmental impacts; investigate nonconformities, determine their cause and take action(s) to avoid their recurrence; evaluate
the need for actions to prevent non-conformities and implement appropriate actions designed to avoid their occurrence; record the results of corrective and preventative actions
taken; and review the effectiveness of corrective and preventative actions taken.
Actions taken need to be appropriate to the magnitude of the problem and environmental
impact encountered and ensure that any necessary changes to the EMS documentation
are made.
Requirements:
Organisations need to review and update their procedures as appropriate and ensure that
they incorporate, in particular, the prevention of re-occurrence of non-conformities and
the prevention of potential non-conformities.
The organisations processes must also be reviewed to ensure that it evaluates the need
for action to prevent non-conformities and implement appropriate actions to avoid their
occurrence.

4.5.4 Control of records

Revision:
The organisation shall establish and maintain records as necessary to demonstrate conformity to the requirements of the EMS and the standard.
A procedure must be implemented for the identification, storage, protection, retrieval, retention and disposal of records.
Records must remain legible, identifiable and traceable.
Requirements:
Organisations need to ensure that all records used to support the EMS and the standard,
demonstrate compliance with the EMS, procedures and results.
Record retention times are no longer required by the standard, although record retention
is still required.

4.5.5 Internal audit

Revision:
The organisation is required to conduct EMS audits at planned intervals and the audit
programme shall be planned.
The revised standard requires the audit procedures to address retaining associated records from audits. This was in the records clause in the 1996 edition.
The selection of auditors and the conduct of audits must be objective and impartial.
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Requirements:
The organisation will need to demonstrate that audits have been planned and an audit
programme is in place this may be done through the organisations audit procedure.
Organisations must also retain records from audits and provision for this must be included
in the procedure.
Impartiality and objectiveness of auditors will need to be demonstrated.

4.6

Management review

Revision:
The top management of the organisation is required to review the EMS at planned intervals.
The review must also include assessing opportunities for improvement
The results of the management review must be documented
The input into the management review will additionally include communications from external parties, performance of the EMS, extent to which objectives and targets have been
met, status of corrective and preventative actions, follow-up actions from previous management reviews, changing circumstances including developments in legal and other requirements related to its environmental aspects and recommendations for improvement.
The outputs from the management review shall include any decisions and actions related
to possible changes to environmental policy, objectives, targets and other elements of the
EMS, consistent with the commitment to continual improvement.
Requirements:
The input and output of the management review is now prescribed in detail (as listed
above) and each of the identified inputs / outputs will need to be incorporated into the organisations management review processes. Note that the management review is not
limited to the list of items and may cover other issues as well as reach decisions and recommendations beyond the listed items but which are of relevance to the EMS
As with audits, management reviews must be conducted at planned intervals, rather than
intervals the organisation determines.
Explicitly document decisions from the management review.

Prepared by the IEMA, December 2004. The IEMA would like to acknowledge the assistance of Dr Anne-Marie
Warris, UK National Expert to ISO TC207/SC1/WG1 in compiling this document.

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Copies of ISO 14001:2004 are available at a discount from the IEMA web site www.iema.net/shop

IAF Transition Plan for Accredited EMS Certification

from ISO 14001:1996 to ISO 14001:2004
1.

Preparation time (up to 6 months after the publication of the new standard)

When the Certification/Registration Bodies (CRBs) agree with the existing and new client
organizations on whether ISO 14001:1996 or ISO 14001:2004 is to be used as the audit
criteria, the standard being used shall be identified in the audit plan for initial audit, surveillance or reassessment. If ISO 14001:2004 is to be used, the CRBs shall ensure that procedures for assessment and certification to the new EMS standard are in place.
2.

Implementation date (from 6 months after the publication of the new standard)

From six months after the publication of the new standard, all audit plans prepared for existing and new client organizations should include ISO 14001:2004 as the audit criteria.
3.

Extra visits by the CRBs

Additional visits by CRBs to assess solely against revisions to the standard are not required.
4.

Nonconformities (during a further 12 months after the implementation date defined in clause 2)

For existing organizations that are certified/registered to ISO 14001:1996, nonconformities

against changes made in the new EMS standard may be raised. These nonconformities
will not adversely affect certification until the end of the transition period.
5.

Certificates

The EMS standard indicated on any certificate shall be consistent with the standard identified on the audit plan. For existing organizations it is expected that EMS certificates will
be renewed based on the outcome of the periodic visit in applying the new standard. This
renewal should not change the previous certification cycle unless a complete reassessment audit takes place. All existing certificates shall be renewed as conforming to the new
EMS standard before the end of transition (see clause 6).
6.

End of transition (18 months after publication of the new standard)

Eighteen months after publication of the new standard, any existing accredited certificates
issued to ISO 14001:1996 will no longer be valid. Outstanding nonconformities to the new
standard will become active and will affect certification/registration.
7. Accreditation body assessment
Accreditation body assessment visits will cover the CRB plans for effectively managing the
transition.
For further information on the International Accreditation Forum see www.iaf.nu

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