Clarification of Intent for ISO 14001:2004

The U.S. Technical Advisory Group (TAG) to ISO/TC 207 has issued two new Clarifications of Intent for ISO 14001:2004:


Is it a nonconformance if an organization establishes Objectives, Targets, and Programs but, at the time of the audit, none relate to an identified significant aspect?

Answer: No. Clause 4.3.3 requires that significant environmental aspects be taken into account when establishing and reviewing objectives and targets, but it does not explicitly require that there be an objective and target related to a significant aspect at all times. It is the intent of the standard that the organization be able to demonstrate that it has taken significant aspects into account in setting objectives. Over time, however, given the required commitment to continual improvement, it would be expected that there would be one or more objectives related to one or more significant aspects to demonstrate conformance to ISO 14001.


Question: Under the third paragraph, second sentence of 4.3.3, how strong is the wording for “shall take into account”?

Answer: The 2004 revision of ISO 14001 replaced “consider” with the phrase “take into account”. This change was intended to strengthen the requirement, so that an organization would not take lightly the need to consider significant environmental aspects but rather, would evaluate whether and to what extent objectives should be set to meet the overall requirement to manage these aspects in keeping with the commitment to continual improvement.

To see all the clarifications of intent for ISO 14001:2004, go to the ASQ Standards Group web site.