As promised, I am continuing my discussion on change management with respect to the ISO 14001:2015 standard.
Change has always been a part of the ISO management system standards, with the expectation that the change is managed. In the previous versions of the standards, it was heavily implied through terms such as “… keep up to date …”. But unlike the changes in ISO 9001:2015, there is no “Planning of Changes” section. So where can we find change management in the new standard?
The change all starts with the environmental aspects,
“When determining environmental aspects, the organization shall take into account: a) change, including planned or new developments, and new or modified activities, products and services;”.
This is not meant to be a one-time activity, but an ongoing process. Be careful not be complacent with just the standard annual review of aspects. The identification of change needs to be an ongoing and proactive practice. The “annual” review is meant to be the safety net in case anything was missed or overlooked during the remainder of the year.
Once we identify the changed aspects, then there is a cascading or domino effect on the rest of the environmental management system.
Anytime we see that the standard requires the maintenance of a process, usually in addition to establishing and implementing the process, there is a trigger for change management. The result of maintaining a process means a process will require a change.
Some of the triggers the will result in a change to a process are:
- changes to aspects,
- changes to compliance obligations,
- changes to controls.
We need to constantly monitor these changing circumstances and ensure that the EMS itself is changed as a result.
Element 4.4 – Environmental Management Systems:
The organization shall consider the knowledge gained in 4.1 and 4.2 when establishing and maintaining the environmental management system.
4.1 is understanding the context of the organization, which includes the internal and external issues affecting it. Some examples of changes can include:
- changes to the customer expectations,
- changes to chemicals being used,
- the addition of an entire shift, doubling production.
4.2 is Understanding the Needs and Expectations of Interested Parties. Interested parties can be internal as well as external. All of these influences on an EMS can change regularly and rapidly, depending on your industry. They should be monitored regularly.
Element 6.1.2 – Environmental Aspects:
The organization shall maintain documented information of its: environmental aspects and associated environmental impacts;
With changes to processes and legal obligations, the environmental aspects will need to be evaluated for changes. There may be changes to the significance of existing aspects as well.
Element 8.1 Operational planning and control:
The organization shall establish, implement, control and maintain the processes needed to meet environmental management system requirements.
With all changes, the controls will need to be evaluated to determine if they are still adequate, effective or even necessary.
Management review (element 9.3) requires the specific inputs of change into the process. Specifically changes in:
- external and internal issues that are relevant to the environmental management system,
- the needs and expectations of interested parties, including compliance obligations,
- its significant environmental aspects,
- risks and opportunities.
The resulting output includes decisions related to any need for changes to the environmental management system systems, including resources. Without managing change, the EMS cannot remain effective. Change, through maintenance and continual improvement of the management systems, are the core tenets of the Plan-Do-Check-Act model.