Revision of ISO 14001:2004 Environmental Management System

The International Environmental Management System (EMS) Standard ISO 14001 was first published in 1996. It assists organisations in reducing their environmental impacts and assessing the effectiveness of environmental policies and procedures. As a certifiable standard, it is suitable for all types of commercial, industrial and public sector organisations. As of 2012, more than 285,000 organisations worldwide were certified to ISO 14001.


The overall aim of the International Standard ISO 14001 is to provide a systematic framework to protect the environment in balance with socio-economic needs. It uses the model of “plan, do, check, act” to provide the framework for EMS implementation.

ISO 14001 is undergoing major changes. ISO 14001:2015 will have a new High Level Structure and common text which would bring it in line with ISO rules for management systems standards. The structure of the Standard will change with new clauses and sub-clauses included. Existing clauses have been strengthened and their order changed as well.

This will affect the way certified businesses manage their EMS and measure their environmental performance. The supporting EMS guidance standard ISO 14004, which explains in more detail how to develop, implement and improve an EMS, is also being revised.

Environmental Consultant Mubin Chowdhury outlines some of the key requirements that may be introduced or amended in the revised Standard.

Timescales and updates

ISO announced in November 2011, the EMS was to be significantly changed for the first time since 2004.

The group working to update EMS reached Committee Draft 1 (CD1) in early 2013. The ISO 14001 review process then reached Committee Draft stage 2 (CD2) in October 2013.

Publication of the revised ISO 14001 is expected in 2015. Organisations with existing 14001 certifications will have 2-3 years from the date of publication to meet the requirements of the new revised Standard. The new Standard will be ‘future-proofed’ (not subject to significant change again) until 2025.

Key changes proposed in CD1 & CD2

Scope: This is likely to require greater detail than is included in the current scope of ISO 14001, which may include impacts from a changing climate on an organisation’s activities. The scope also puts emphasis on the need to take advantage of opportunities as well as reducing negative impacts.

Context of the organisation: Including external environmental conditions that might impact on the organisation and the need to take account of external parties.

Leadership, top management and commitment: There are new clauses on leadership and commitment, which strengthen the requirement to align the EMS with an organisation’s overall strategy and core business processes. Top management must integrate environmental performance into strategic planning, direction and organisational decision-making.

Definition of top management is tightened. Top management cannot delegate authority for certain elements of environmental management. These greater expectations are to promote meaningful top management involvement in EMS.

Policy: Additional commitments may be included to “support environmental protection” and provide some examples of potential environmental threats. Broadening policy commitment is intended to show that organisations are going beyond pollution prevention to incorporate wider environmental aspects, although the revision stops short of specifying what these might be.

Risks and opportunities: These were addressed in the earlier revision, ISO 14001:2004, through the identification and evaluation of environmental aspects and legal requirements. However, the proposed revisions also include specific requirements for the management of the potential business risks and opportunities arising from environmental impacts.

Environmental aspects: A “life-cycle perspective” has to be taken into account when identifying aspects. It is important to note that this does not require a life-cycle assessment to be conducted, but would mean that the impacts of the organisation’s products/services are to be considered and to not limit the EMS to direct operational management.

Environmental performance indicators: Indicators will be used to track improvement. This introduces a requirement for each identified objective to have one or more defined indicators associated with it, through which performance is evaluated. Flexibility is maintained by not specifying further what the indicator should consist of or specifying impacts to be included, which is required in the Eco-Management and Audit Scheme (EMAS).

Communication: The drafts will require organisations to determine what and when to communicate to internal and external audiences, although there is no requirement to communicate externally, beyond that legally required.

Value chain planning and control: Building upon the “life-cycle perspective”, the drafts introduce requirements to control or influence upstream processes such as design and development, and downstream processes, including processes governing procurement of goods/services and those activities which are outsourced.

Performance evaluation: More detailed requirements to determine criteria against which performance is evaluated and is introduced. This includes the incorporation of the value chain perspective on an organisation’s environmental impacts.

Planning: There is significant revision and restructure relating to planning, in particular in relation to environmental aspects and impacts. Specifically the aspects and impacts relationship to organisational risks and opportunities is proposed.

Evaluation of compliance: This is strengthened with the introduction of a requirement to maintain knowledge and understanding of compliance status, and not rely on external parties to inform an organisation when activities were non-compliant and which the organisation was not aware of.

Environmental Condition: There is a new definition of environmental condition.


There will be no reduction in the requirements of ISO 14001. The main text of ISO 14001 will contain requirements and the annex will provide interpretation of these requirements. The fundamental revision will impact on all ISO 14001 certified businesses, those currently considering implementing a certifiable EMS in the future and auditor expectations.


Disclaimer: The information provided through Legislation Watch is for general guidance only and is not legal advice. Legislation Watch is not a substitute for Health and Safety consultancy. You should seek independent advice about any legal matter.

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