The Carbon Reduction Commitment (CRC) Energy Efficiency Scheme Order 2013 [1] came into effect on 20^th May. It confirms the expected changes to the scheme, with Phase 2 commencing in 2014.

Phase 1, which started in 2010 as a multi-fuel emissions trading scheme, with a participants league table, is reduced for its last two years (2012-13 and 2013-14) to a reporting scheme for electricity and gas consumption. The league table, intended as a reputational driver, has been abolished. Updated guidance from the Environment Agency, published in February 2013 [2], provides extensive interpretation of requirements for all elements of the scheme, including for organisational structure, reporting requirements, ordering and surrendering allowances, and exemptions.

The qualification period for Phase 2 was April 2012 – March 2013, and the qualifying criteria, subject to various exemptions, are:

• At least one settled half hourly electricity meter (sHHM); and
• Consumption in the qualifying year of 6,000 megawatt hours (MWh) or more of qualifying electricity supplied on the settled half hourly market.

The deadline for applications is no later than 2 months before the start of a Phase (so by the end of January 2014, if Phase 2 starts on 1^st April). More details are provided in the Regulators’ guidance for qualification [3].

The CRC is intended to be with us for a considerable period of time. The 2013 Order establishes Phase 2 with five consecutive phases, each of five years, with the initial phase commencing on 1^st April 2014, and a final phase of four years, commencing on 1^st April 2039.

If you would like any further information on the Carbon Reduction Commitment (CRC) Energy Efficiency Scheme or any other environmental compliance issues, please visit our environmental compliance web page or contact Nigel Leehane on nleehane@cra.co.uk or 0115 965 6700.

RGN 2, with appendices 1, 2, 3 and 4, was updated to account for changes introduced by the Industrial Emissions Directive (IED) that introduced some changes to the descriptions of a regulated facility.  (See our related briefing note “The Implications Arising from the Industrial Emissions Directive (IED)”). The term ‘regulated facility’ is found under the Environmental Permitting (England and Wales) Regulations 2010 as amended by the Environmental Permitting (England and Wales) (Amendment) Regulations 2013.

RGN 2 is a high level regulatory guidance identifying the facilities regulated under the Environmental Permitting Regulations and uses a ‘route map’ to navigate through the essential details.  The definition of ‘regulated facility’ is explained in Section 2 of the note where facilities are grouped into ‘classes’.

Appendix 1 provides an interpretation of Schedule 1 to the Environmental Permitting Regulations and Appendix 2 defines the scope of an installation.  Appendix 3 offers specific information and interpretation of what are seen as Intensive Farming installations and Appendix 4 is aimed at assisting with understanding the scope of mobile plant.

The Agency’s guidance note should be read in conjunction with other guidance issued by the Department for Environment, Food and Rural Affairs (Defra), the Department of Energy and Climate Change (DECC) and the Welsh Government (WG) who also have issued guidance on what is a regulated facility.

For further information, please visit the EA website and view the Regulatory Guidance series by clicking here.

If you would like assistance with deciding if yours is a regulated facility, and requires an environmental permit, please contact Bryan Hughes on 0151 207 7848 or bhughes@cra.co.uk.

CRA offers environmental permitting support that includes preparing and contributing to applications for new permits and variations to existing permits. This can extend to integrating the demands from planning consents and COMAH, and the findings of EIAs. CRA also carries out compliance audits and BAT reviews. For further information, please visit our environmental permitting web page.

When published, ISO 14001:2015 will have a new structure and “common text”, following ISO rules for all management systems standards. It will also address the recommendations from the ISO “Future Challenges” study, for the adoption of various new approaches and methods in the field of EMS, and to meet the needs of stakeholders in the future.

This is a fundamental revision of the standard, with far greater implications for organisations than the previous revision in 2004. CRA has identified seven major changes, and over the next few weeks, we will be publishing a series of articles on our website, to help you appreciate the key themes of the revision, and what auditors may expect from you once ISO 14001:2015 is released.

Some of these new requirements are addressed by changes to the structure of the standard, which will include new clauses on:

• Understanding the organisation and its context;
• Understanding the needs and expectations of interested parties;
• External communication and reporting;
• Value chain planning and control; and
• Continual improvement.

Many of the other clauses have been strengthened and the order of many in the standard has changed. For example, “awareness” is no longer part of competence and training, but is a separate sub-clause. Non-conformance now sits between management review and continual improvement, a new sub-clause which provides greater emphasis on improvement at the end of the standard.

WHERE CAN YOU FIND OUT MORE?

The Institute for Environmental Management and Assessment, and through it all of its members, are invited to participate in the current consultation exercise. For details of the consultation visit the IEMA website (www.iema.net).

CRA’s Nigel Leehane is one of the UK’s technical experts appointed to the ISO working group revising 14001. Please contact him on 0115 965 6700 or nleehane@cra.co.uk if you would like to know more about the changes to ISO 14001 and the implications for your organisation.

To view our seven follow-up articles, explaining in detail the seven changes we have identified, please click the links below:

Article 1: “ISO 14001 Revision – Greater Expectations for Top Management’s Leadership and Commitment” - posted 21/03/2013

Article 2: ”ISO 14001 Revision – How to Address Strategic Environmental Issues, the Interests of Stakeholders and the Direction of the Business” - posted 28/03/2013

Article 3: ”ISO 14001 Revision – What commitments to make to sustainable development and social responsibility?” - posted 04/04/2013

Article 4: ”ISO 14001 Revision – Extending environmental influence into the value chain, with implications for procurement” - posted 11/04/2013

Article 5: “ISO 14001 Revision – Environmental Design as a Tool for Improvement”  – posted 18/04/2013

Article 6: “ISO 14001 Revision – Demonstrating Environmental Compliance Status” – posted 25/04/2013

Article 7: “ISO 14001 Revision – Using performance indicators to track improvement” – posted 02/05/2013

The Future Challenges study report states that the objective of ISO 14001 should be the improvement of environmental performance itself, and argues that the current text, which implies that this improvement is achieved only by improving the EMS, is confusing to the users of the standard. The report recommends:

• Clarification of the requirements for improving environmental performance; and
• Strengthening performance evaluation, potentially through the use of indicators.

The first of those recommendations has not yet been addressed, with adherents of the traditional stance successfully arguing for the retention in clause 10.2 Continual improvement of:

“The organization shall continually improve the suitability, adequacy and effectiveness of the environmental management system to enhance its environmental performance”

It is to be hoped that the aspirations of Future Challenges for the emphasis to be on environmental performance improvement can be incorporated before the final draft is completed.

The second recommendation has been addressed, with a specific requirement to establish one or more indicators for each objective set by the organisation. Secondly, there is a generic expectation that indicators will be used for monitoring and measuring performance against specified criteria (for example discharge consent limits or energy intensity targets).  The Annex refers to ISO 14031 Environmental management — Environmental performance evaluation, and its approach to sub-dividing environmental performance indicators (EPIs) into:

• Management performance indicators (MPIs);
• Operational performance indicators (OPIs); and potentially
• Environmental condition indicators (ECIs).

The selection of indicators is at the discretion of the organisation, and can be aligned with any regulatory requirements, expectations of stakeholders and, as specified in the revised text, its objectives.

WHERE CAN YOU FIND OUT MORE?

The Institute for Environmental Management and Assessment, and through it all of its members, are invited to participate in the current consultation exercise. For details of the consultation visit the IEMA website (www.iema.net).

Nigel Leehane is one of the UK’s technical experts appointed to the ISO working group revising 14001. Please contact him on 0115 965 6700 or nleehane@cra.co.uk if you would like to know more about the changes to ISO 14001 and the implications for your organisation.

To view the rest of the articles in the series, which explain in detail the seven changes we have identified, please click the links below:

Article 1: “ISO 14001 Revision – Greater Expectations for Top Management’s Leadership and Commitment” - posted 21/03/201

Article 2: ”ISO 14001 Revision – How to Address Strategic Environmental Issues, the Interests of Stakeholders and the Direction of the Business” - posted 28/03/2013

Article 3: ”ISO 14001 Revision – What commitments to make to sustainable development and social responsibility?” - posted 04/04/2013

Article 4: “ISO 14001 Revision – Extending environmental influence into the value chain, with implications for procurement” – posted 11/04/2013

Article 5: “ISO 14001 Revision – Environmental Design as a Tool for Improvement” – posted 18/04/2013

Article 6: “ISO 14001 Revision – Demonstrating Environmental Compliance Status” – posted 25/04/2013

The Future Challenges study recognised that, while it is difficult for organisations to maintain complete compliance at all times with environmental legislation, they need to know when they are not, so that they can plan to restore compliance as soon as possible. This is not intended as a dilution of the requirement to comply with legislation; it is a pragmatic acknowledgement of what can be achieved, as a part of value added, through the effective application of an EMS. This also harmonises the ISO 14001 stance with that of many jurisdictions where the commitment to compliance is seen as a pledge, rather than a guarantee of perpetual compliance.

The revised text retains the requirement to identify applicable legislation and understand the compliance requirements. However, rather than simply imposing a requirement of “periodically evaluating compliance with applicable legal requirements”, the revised text stipulates that the organisation must:

• Evaluate compliance at pre-determined frequencies;
• Take any necessary action (i.e. to address non-compliance, actual or potential); and
• Maintain knowledge and understanding of its compliance status.

The Annex provides more information, explaining that the evaluation of compliance should not only involve periodic compliance audits, but also comprises:

• Site inspections and observations;
• Review of records; and
• Comparing the results of monitoring against regulatory requirements.

So, compliance evaluation is also part of everyday inspection and monitoring activities. It is important that the results of these checks are reviewed by competent individuals, capable of identifying actual or potential non-compliances and instigating action to remedy them. This will be nothing new to many organisations that already have comprehensive compliance monitoring and evaluation mechanisms in place; however, the new requirements should encourage external auditors to review that these processes are effective in maintaining knowledge and understanding of compliance status.

WHERE CAN YOU FIND OUT MORE?

The Institute for Environmental Management and Assessment, and through it all of its members, are invited to participate in the current consultation exercise. For details of the consultation visit the IEMA website (www.iema.net).

Nigel Leehane is one of the UK’s technical experts appointed to the ISO working group revising 14001. Please contact him on 0115 965 6700 or nleehane@cra.co.uk if you would like to know more about the changes to ISO 14001 and the implications for your organisation.

To view the rest of the articles in the series, which explain in detail the seven changes we have identified, please click the links below:

Article 1: “ISO 14001 Revision – Greater Expectations for Top Management’s Leadership and Commitment” - posted 21/03/201

Article 2: ”ISO 14001 Revision – How to Address Strategic Environmental Issues, the Interests of Stakeholders and the Direction of the Business” - posted 28/03/2013

Article 3: ”ISO 14001 Revision – What commitments to make to sustainable development and social responsibility?” - posted 04/04/2013

Article 4: “ISO 14001 Revision – Extending environmental influence into the value chain, with implications for procurement” – posted 11/04/2013

Article 5: “ISO 14001 Revision – Environmental Design as a Tool for Improvement” – posted 18/04/2013

Article 7: “ISO 14001 Revision – Using performance indicators to track improvement” – posted 02/05/2013Due 02/05/2013

The latest draft includes short but potentially powerful statements relating to the design, development and change of products and services, and the need to communicate information relating to potential impacts associated with the use and end-of-life of products, and the delivery of services. This is in contrast to ISO 14001:2004, where the first reference to design is in the single Annex, so addressing environment in design currently is not a requirement of the standard.

The revised text introduces requirements for:

• Identifying the environmental aspects of its activities, products and services … that it can control and those that it can influence considering a life cycle perspective; and
• Considering the result of the evaluation of significant environmental aspects as input in the process of the design, development or change of its products and services.

The Annex also explains that the organisation should consider how it will integrate environmental management system requirements into its various business functions, such as design & development. It also makes reference to product, process and facility design and development.

So, although there will be no requirement for organisations to undertake detailed life-cycle analysis of all inputs and outputs, there will be an expectation to identify and assess the significance of key aspects in the value chain, and to consider how these can be managed to reduce impacts. It will be up to the organisation to decide and justify its approach, but clearly it should be expected that external auditors will be looking for evidence that:

• Key value chain aspects have been identified and evaluated;
• Decisions have been made in relation to managing them, where feasible, to reduce value chain impacts;
• Mechanisms exist within the organisation to ensure that design functions consider these key value chain aspects;
• Consideration is given to minimising direct environmental impacts through considering process and facility design.

Many organisations already recognise the business benefits of reducing operating costs through process and facility design, but the expectation of the revised text clearly is to extend these drivers into the value chain, potentially to the benefit of the organisation, their partners, suppliers, customers and end-users in the value chain.

WHERE CAN YOU FIND OUT MORE?

The Institute for Environmental Management and Assessment, and through it all of its members, are invited to participate in the current consultation exercise. For details of the consultation visit the IEMA website (www.iema.net).

Nigel Leehane is one of the UK’s technical experts appointed to the ISO working group revising 14001. Please contact him on 0115 965 6700 or nleehane@cra.co.uk if you would like to know more about the changes to ISO 14001 and the implications for your organisation.

To view the rest of the articles in the series, which explain in detail the seven changes we have identified, please click the links below:

Article 1: “ISO 14001 Revision – Greater Expectations for Top Management’s Leadership and Commitment” - posted 21/03/201

Article 2: ”ISO 14001 Revision – How to Address Strategic Environmental Issues, the Interests of Stakeholders and the Direction of the Business” - posted 28/03/2013

Article 3: ”ISO 14001 Revision – What commitments to make to sustainable development and social responsibility?” - posted 04/04/2013

Article 4: “ISO 14001 Revision – Extending environmental influence into the value chain, with implications for procurement” – posted 11/04/2013

Article 6: “ISO 14001 Revision – Demonstrating Environmental Compliance Status” – posted 25/04/2013

Article 7: “ISO 14001 Revision – Using performance indicators to track improvement” – posted 02/05/2013

The current edition of ISO 14001 recognises the need to address the impacts of “activities, products and services”, but the emphasis is very much on controlling the organisation’s own activities. The ISO Future Challenges report suggests that the need to think more broadly outside the organisational control box is implied in the current standard, rather than being explicit, and it recommends that the revised standard should:

• Address life cycle thinking and the value chain perspective more clearly in the identification and evaluation of environmental aspects related to products and services; and
• Include clear requirements/guidance related to strategic environmental considerations, design and development, purchasing, marketing and sales activities.

The working group has made some progress incorporating these concepts, including a generic requirement for organisations to consider how they can control or influence upstream and downstream processes in the value chain. There are specific requirements to address environmental issues in procurement and outsourcing, for:

• Evaluating the supply of goods, services and outsourced processes, taking a lifecycle perspective;
• Specifying environmental requirements as appropriate for the procurement of goods and services or outsourced processes;
• Communicating requirements to suppliers, including contractors; and
• Monitoring key characteristics of the value chain.

There is no expectation that organisations would need to carry out detailed life-cycle assessments.

The revised text makes it clear that the consideration of value-chain issues should be related to significant aspects, and this should be the starting point for organisations to determine if they do have opportunities for control or influence in the value chain. The revised text provides definitions of the value chain, supply chain and lifecycle (see the Value Chain/Lifecycle model below), which are helpful in considering where and how organisations can exert control or influence.

Generally, organisations have more opportunity to control, and a greater sphere of influence over the characteristics and resultant environmental aspects of materials, products and services that they procure and ultimately supply, than they do over the activities of other organisations forming the value chain. The opportunity to influence other organisations should not be ignored, but the tools and approaches may be very different (softer communications and engagement), from those used for specifying materials.

How will external auditors test the processes applied to the planning and control of the value chain? The approach used for assessing the significance of value chain aspects will be a starting point, but also the auditors will be interested in how the organisation determines those significant aspects it can or should control or influence. As a minimum, this could include the process by which procurement decisions are taken, and whether they involve the consideration of the environmental characteristics of the purchased materials or services. More advanced approaches would address the opportunities to influence suppliers, not only to improve the environmental characteristics of the materials and services, but also to adopt better environmental management practices throughout the organisation. However, it must be recognised that organisations may have limited opportunities for influencing the behaviours of suppliers. SMEs may feel that they have no influence, but even so they do have the opportunity to decide what they buy and from who.

WHERE CAN YOU FIND OUT MORE?

The Institute for Environmental Management and Assessment, and through it all of its members, are invited to participate in the current consultation exercise. For details of the consultation visit the IEMA website (www.iema.net).

Nigel Leehane is one of the UK’s technical experts appointed to the ISO working group revising 14001. Please contact him on 0115 965 6700 or nleehane@cra.co.uk if you would like to know more about the changes to ISO 14001 and the implications for your organisation.

To view the rest of the articles in the series, which explain in detail the seven changes we have identified, please click the links below:

Article 1: “ISO 14001 Revision – Greater Expectations for Top Management’s Leadership and Commitment” - posted 21/03/201

Article 2: ”ISO 14001 Revision – How to Address Strategic Environmental Issues, the Interests of Stakeholders and the Direction of the Business” - posted 28/03/2013

Article 3: ”ISO 14001 Revision – What commitments to make to sustainable development and social responsibility?” - posted 04/04/2013

Article 5: “ISO 14001 Revision – Environmental Design as a Tool for Improvement”  – posted 18/04/2013

Article 6: “ISO 14001 Revision – Demonstrating Environmental Compliance Status” – posted 25/04/2013

Article 7: “ISO 14001 Revision – Using performance indicators to track improvement” – posted 02/05/2013

The Future Challenges study recommended that consideration be given in the revision of ISO 14001 to the content of ISO 26000 – Guidance on Social Responsibility, which considers the environment as the “planet” element of the “People, Planet and Profit” model. Future Challenges suggests that 14001 should address the environmental principles in ISO 26000 and also consider aligning its language.

The four environmental themes considered in ISO 26000 are:

• Prevention of pollution (waste and emissions);
• Sustainable resource use (materials, energy and water consumption);
• Climate change and mitigations (GHG); and
• Protection of the environment and restoration of natural habitats (ecosystems, biodiversity, land and natural resources, urban and rural development).

Prevention of pollution is already a key principle of 14001, to which a commitment must be made in the environmental policy. This is retained in the revised text, but with the additional requirement to “support environmental protection specific to the context of the organisation”, and decide if other commitments should be made.  The use of the term “context” refers to the new clauses 4.1 and 4.2, which require the consideration of the organisation’s internal and external issues and stakeholder needs and expectations.

This is not a detailed operational aspects assessment, but a high level, strategic review, intended to identify broader risks and opportunities. The outcome will depend very much on the nature of the organisation’s activities, products and services, the value chain and geographic factors, among others. The revised text incorporates the three ISO 26000 topics, with some modifications:

• Sustainable resource use;
• Climate change mitigation and adaptation; and
• Protection of biodiversity and ecosystems.

It also includes the catch-all “or other relevant environmental issues”, which, for organisations involved in agriculture, for example, could be water scarcity.

Although there is no mandatory requirement to address these sustainability principles in the policy, organisations should determine if they would benefit from doing so, taking account of the broader business implications. One of the requirements of top management is to ensure that the environmental policy is compatible with the strategic direction of the organisation, and so they should be sufficiently well informed to decide if commitment is needed to any specific sustainability principles.

Should specific commitments be made, then the system needs to provide the tools to fulfil them. The revised text provides substantially greater drivers for this, including:

• Setting objectives consistent with the policy;
• More detailed requirements for external reporting (compatible with the Global Reporting Initiative, etc.);
• Adopting a life cycle perspective;
• Requiring the use of key performance indicators for measuring progress towards objectives; and
• Value chain planning, control and monitoring.

WHERE CAN YOU FIND OUT MORE?

The Institute for Environmental Management and Assessment, and through it all of its members, are invited to participate in the current consultation exercise. For details of the consultation visit the IEMA website (www.iema.net).

Nigel Leehane is one of the UK’s technical experts appointed to the ISO working group revising 14001. Please contact him on 0115 965 6700 or nleehane@cra.co.uk if you would like to know more about the changes to ISO 14001 and the implications for your organisation.

To view the rest of the articles in the series, which explain in detail the seven changes we have identified, please click the links below:

Article 1: “ISO 14001 Revision – Greater Expectations for Top Management’s Leadership and Commitment” - posted 21/03/201

Article 2: ”ISO 14001 Revision – How to Address Strategic Environmental Issues, the Interests of Stakeholders and the Direction of the Business” - posted 28/03/2013

Article 4: ”ISO 14001 Revision – Extending environmental influence into the value chain, with implications for procurement” - posted 11/04/2013

Article 5: “ISO 14001 Revision – Environmental Design as a Tool for Improvement”  – posted 18/04/2013

Article 6: “ISO 14001 Revision – Demonstrating Environmental Compliance Status” – posted 25/04/2013

Article 7: “ISO 14001 Revision – Using performance indicators to track improvement” – posted 02/05/2013

ISO 14001:2015 will include new opening clauses concerning the context of the organisation and understanding the needs and expectations of stakeholders. This is an important development, aimed at ensuring the organisation considers high-level, strategic drivers when establishing the scope of its EMS, making its core commitments, and developing its environmental policy.

There is a clear shift in emphasis from the 2004 edition, in which the only explicit requirement to identify environmental issues is in the context of identifying and assessing environmental aspects, after the policy has been established. In the Annex, it is suggested that an initial review, including of the environmental aspects, should be undertaken before developing the policy, but there is no suggestion that this should be at a strategic, rather than operational, level.

The revised edition does both, with requirements for high level consideration of risk and also operational environmental aspects evaluation. This is an important distinction, separating strategic and operational environmental issues, and ensuring that appropriate attention is now also given at the strategic level. This should be undertaken when planning the system and also periodically, in the same way that operational environmental aspects are considered.

The new clause for understanding the organisation and its context requires the determination of internal and external issues “relevant to its purpose” and which may influence the effectiveness of the EMS. It also specifically refers to the implications of external environmental conditions, which is a subtle nudge towards addressing climate change adaptation. The use of the term “purpose” of the organisation is important, in that it directly relates environmental management to the raison d’etre of the organisation, implicitly requiring strategic consideration of anything “environmental“ that may have a bearing on broader organisational goals. This fulfils the Future Challenges recommendation that environmental management be integrated with business strategy.

The new clause for understanding the needs and expectations of interested parties, or stakeholders, simply requires the identification of relevant parties and their requirements, in relation to the environmental management system. Stakeholder needs and expectations clearly can vary in significance from one organisation to another and, rightly, the standard does not prescribe how or when these needs and expectations should be evaluated.

The output of both of these evaluations, of context and stakeholders, should provide an input into the determination of the scope of the EMS. Additionally, the environmental policy should also reflect the “direction of the organisation”, or its broader strategic policy.

These new requirements will pose some interesting challenges for organisations, potentially requiring a greater degree of consideration of environmental matters at strategic level. It will be interesting to see how far external auditors will go to obtain evidence that these requirements are being fulfilled.

WHERE CAN YOU FIND OUT MORE?

The Institute for Environmental Management and Assessment, and through it all of its members, are invited to participate in the current consultation exercise. For details of the consultation visit the IEMA website (www.iema.net).

Nigel Leehane is one of the UK’s technical experts appointed to the ISO working group revising 14001. Please contact him on 0115 965 6700 or nleehane@cra.co.uk if you would like to know more about the changes to ISO 14001 and the implications for your organisation.

To view the rest of the articles in the series, which explain in detail the seven changes we have identified, please click the links below:

Article 1: “ISO 14001 Revision – Greater Expectations for Top Management’s Leadership and Commitment” - posted 21/03/201

Article 3: ”ISO 14001 Revision – What commitments to make to sustainable development and social responsibility?” - posted 04/04/2013

Article 4: ”ISO 14001 Revision – Extending environmental influence into the value chain, with implications for procurement” - posted 11/04/2013

Article 5: “ISO 14001 Revision – Environmental Design as a Tool for Improvement”  – posted 18/04/2013

Article 6: “ISO 14001 Revision – Demonstrating Environmental Compliance Status” – posted 25/04/2013

Article 7: “ISO 14001 Revision – Using performance indicators to track improvement” – posted 02/05/2013

ISO 14001:2015 will include new clauses on leadership and the commitment of the organisation, which expand significantly on the requirements of the current version of the standard.

The current version of the standard requires top management (those who “control or direct organisations at the highest level)” to define the environmental policy, appoint a management representative responsible for the EMS and reporting back to them, and undertake the management review. This has allowed top management to become divorced from meaningful environmental management, instead relying on its delivery by an environmental management function.

The revised standard will require much more of top management, including:

• Understanding the organisation’s context (in terms of its environmental risks, opportunities and stakeholder expectations);
• Ensuring that the environmental policy and objectives are compatible with the strategic direction of the organisation;
• Considering environmental performance in strategic planning;
• Ensuring the integration of the EMS into the organisation’s business processes;
• Ensuring adequate resources are available;
• Communicating the importance of effective environmental management;
• Ensuring that the environmental management system achieves its intended outcomes and promotes continual improvement; and
• Directing and supporting staff to contribute to the effectiveness of the EMS, and supporting those responsible for environmental management.

These are far more onerous responsibilities for top management, aimed at encouraging them to be more involved in environmental management and supporting environmental management efforts. These robust criteria provide effective ammunition to auditors to allow them to test the involvement and support from top management, which is needed to foster organisational behaviour change.

Additionally, the new requirements should lead to greater integration of environmental management into business processes, and ensure environmental issues are considered at a strategic level, including in the context of longer term planning. These measures should encourage organisations to derive greater business benefits from improved environmental performance and crucially help to remove barriers to environmental improvement by harmonising business and environmental goals.

How will your organisation’s top management respond to these challenges? Consider what they will need to do to demonstrate to an auditor that they are fulfilling these obligations. What evidence will auditors need to verify that environmental performance is considered in strategic planning or that the EMS is being integrated into the organisation’s business processes?

WHERE CAN YOU FIND OUT MORE?

The Institute for Environmental Management and Assessment, and through it all of its members, are invited to participate in the current consultation exercise. For details of the consultation visit the IEMA website (www.iema.net).

CRA’s Nigel Leehane is one of the UK’s technical experts appointed to the ISO working group revising 14001. Please contact him on 0115 965 6700 or nleehane@cra.co.uk if you would like to know more about the changes to ISO 14001 and the implications for your organisation.

To view the rest of the articles in the series, which explain in detail the seven changes we have identified, please click the links below:

Article 2: ”ISO 14001 Revision – How to Address Strategic Environmental Issues, the Interests of Stakeholders and the Direction of the Business” - posted 28/03/2013

Article 3: ”ISO 14001 Revision – What commitments to make to sustainable development and social responsibility?” - posted 04/04/2013

Article 4: ”ISO 14001 Revision – Extending environmental influence into the value chain, with implications for procurement” - posted 11/04/2013

Article 5: “ISO 14001 Revision – Environmental Design as a Tool for Improvement”  – posted 18/04/2013

Article 6: “ISO 14001 Revision – Demonstrating Environmental Compliance Status” – posted 25/04/2013

Article 7: “ISO 14001 Revision – Using performance indicators to track improvement” – posted 02/05/2013