New ISO 14001 Update incoming
An amendment to ISO 14001:2015 came out in 2024 leading the way to a new draft standard ISO/DIS 14001 which is at the “Enquiry Stage” as of 19th June 2025
WHAT IS ISO 14001?
ISO state:
ISO 14001 is the internationally recognized standard for environmental management systems (EMS). It provides a framework for organizations to design and implement an EMS, and continually improve their environmental performance. By adhering to this standard, organizations can ensure they are taking proactive measures to minimize their environmental footprint, comply with relevant legal requirements, and achieve their environmental objectives. The framework encompasses various aspects, from resource usage and waste management to monitoring environmental performance and involving stakeholders in environmental commitments.
WHAT IS AN EMS?
An EMS is an environmental management system but it might be best to start with stating what a Management System is:
As per Clause 3.1.1 it is:
a set of interrelated or interacting elements of an organization to establish policies and objectives and processes to achieve those objectives
A management system can address quality, environment, occupational health and safety, energy, financial management). System elements include the organization’s structure, roles and responsibilities, planning and operation, performance evaluation and improvement. The scope of a management system can include the whole of the organization, specific and identified functions, activities or sections of an organization.
According to the old adage attributed to Peter Drucker (and not Mark Twain, Oscar Wilde or Ghengis Khan) is “you can’t manage what you can’t measure”. So think of it as a organised way of measuring your organisations performance and then planning how to better manage it (specifically how to improve it).
Another adage that is appropriate to bear in mind with management systems is the fundamental question to ask when auditing one: DO YOU DO WHAT YOU SAY YOU DO?Management system compliance can be both internally and externally verified as compliant with the standard, with objectives and targets, with the expectations of interested parties. The leadership of an organisation are accountable for the integrity and performance of the system and by extension of the organisation itself.
Turning to an EMS specifically, your management system should help you to manage environmental aspects and impacts, address environmental risks and opportunities and fulfil your compliance obligations.
WHAT WAS THE 2024 AMENDMENT?
The Amendment last year specifically emphasised Climate Change. Previously guidance to the standard and interpretation by practitioners and auditors had treated Climate Change like an environmental impact; i.e. a consequence of ones operations that was difficult for any organisation to properly quantify. The change was quite subtle; many people missed it:
4.1
Add the following sentence at the end of the subclause:
The organization shall determine whether climate change is a relevant issue.
4.2
Add the following note at the end of the subclause:
NOTE Relevant interested parties can have requirements related to climate change.
Making Climate Change a distinct issue in its own right requires organisations with Management Systems to approach climate change mitigation and adaptation as organisational objectives. Its not about just measuring your emissions of carbon and promising to do something about them, so much as about your corporate approach to the reality of climate change and your roles and responsibilities and relationships in that context.
WHAT IS THE “ENQUIRY STAGE”
Draft standards go through several stages before they are published as a final draft: Preliminary, Proposal, Preparatory, Committee, Enquiry, Approval and Publication. After being published they can be Reviewed and at their end, Withdrawn. Being at the Enquiry Stage means ISO are happy with the draft and are now circulating the draft for registration as Final Draft International Standard (FDIS). The approval stage involves acceptance of final proofs prior to publication. So this is imminent.
HOW IS THE UPDATED STANDARD DIFFERENT?
Well the amendment just changed two clauses whereas this a reissue of a standard with lots of changes. At this stage it probably doesn’t make sense to go clause by clause (I’ve put a summary in the comments for anyone who wants that). But I think it’s probably better to look at the spirit, rather than the letter, of the changes.
Firstly in raising the bar regarding Climate Change adaptation and mitigation (clause 6.1.2), a wording change: “fulfil your compliance obligations” changes to “meet your compliance obligations” (3.1.2 and elsewhere) . It might look at first glance like a relaxation of a requirement. But the change requires organisations to anticipate and react to a changing situation rather than box checking standard actions.
Arguably, because Management Systems are built around the Deming-Shewhart cycle - PLAN, DO, CHECK, ACT - the focus on continual improvement should always have been central to management system operation. But in reality much of the activity in organisations with an EMS has been about ticking off specific compliance activities as “Done” or “Complete”; and about getting certificates as badges of approval from external bodies. Systems have become inert; obsessed with regulatory compliance and maintaining certified status; largely immobile. Meanwhile the living world including all its strengths and vulnerabilities, complexities, sensitivities, conditions, threats, risks and opportunities are constantly in flux. Somewhat ironically, many EMS’s are, long term, not sustainable. What I mean by that is: they do little or nothing to prepare the organisations they purport to manage for the changed world of the future.
Secondly to this overall change of emphasis towards Climate Change is the issue of leadership and accountability. In the past organisations have been able to pass surveillance audits by the likes of BSi, LRQA and DNV without bothering seniormanagement too much. In many cases there was little or no leadership presence from one certification audit cycle to the next. That had to change and it has. The new requirements are for much more integration between EMS and other business processes ( and not just other management systems).
Thirdly compliance obligations and leadership have a bolstered linkage through documentation (7.5.1) and planning including improvements to planning for emergencies (8,2)
Lastly, there is greater focus on risk based approaches to environment and sustainability (6.1.4). The significance of risks needs to be based on established criteria, not a socially or politically convenient assessment of harm (realpolitik). There has been a tendency for environmental risk assessments to rate risks that caused harm to perhaps to one organism, or to a particularly large, diverse and/or resilient ecosystem, or to a habitat capable of being readily restored, as negligible “in the grand scheme of things”. This has been a convenient way of moving deckchairs on a vessel whilst the smoke from its stacks continue to cloud the horizon and the slick of gunge running out behind it becomes most indiscreet.
Going forward organisations that are certified to ISO 14001 should plan the three year interval that is the usual implementation period for an ISO standard in the following order:
Carry out an analysis of the gaps between the existing and new standards and determine what changes will be required. Don’t minimise it either. Make the analysis a comprehensive review of how you meet all of the requirements of 14001, notjust the clauses that have wording changes
Put together an implementation plan by targeting a compliance audit date well before the final implementation deadline and working backwards through the series of actions required to meet that target. Sense check that you have the resources, people and systems needed to meet the upgrade challenge and what might be missing and what the costs might be (not just money but people’s labour and commitment of time)
Address the skills and communication gaps. Start by making sure everyone is clear what the new requirements are but also that they are involved in the changes to the system. If they have an input they are more likely to own them. Make sure the attested benefits of a management system actually do accrue to the organisation by measuring those things properly and reporting them widely :
Enhanced environmental performance
Regulatory compliance
Risk management
Cost savings
Operational excellence
Stakeholder and customer trust
If you’ve resourced and timed it properly you should have a opportunity to monitor, internally audit and adapt the system before any external auditor gets a look at it so there are minimal risks of non-conformities.
And of course, if you need any help with all that, you know who to ask.