ISO 14001:2015 Interpretations

The ISO/TC 207/SC 1 sub-committee has a process for managing interpretations of ISO 14001:2015. If you’d like to view the interpretations for the questions below, go to this ISO/TC 207/SC 1 web page.

1. ISO 14001:2015 has a very different structure than the two previous versions. Our documentation is aligned to the clauses that existed in the previous version. Do we have to restructure our documentation to follow the new clause structure?

2. Are the references to other standards in the Notes to Entry in Clause 3 (Terms and definitions) normative?

3. Are there any situations in which “top management” refers to persons outside the scope of the environmental management system?

4. Does the term “compliance obligation” in ISO 14001:2015 have the same meaning as the phrase “legal requirements and other requirements to which the organization subscribes” in the previous edition?

5. There appears to be ambiguity in ISO 14001:2015 regarding whether the term “risk” has only a negative connotation or includes both negative and positive connotations. The definition of “risk” (3.2.10) states that risk can be positive or negative, but the definition of “risks and opportunities” (3.2.11) implies that risk is only negative, while opportunities are positive. May an organization decide for itself whether to use the term “risk” in its Environmental Management System as a solely negative concept or as both a negative and positive concept?

6. In Note 1 to Entry 3.3.4 “outsource,” does the phrase “outside the scope of the management system” mean “outside the scope of the environmental management system”?

7. Is an organization required to establish a process in order to meet the requirements in 4.1 and 4.2 that it determine its context, relevant interested parties and their needs and expectations? Is an organization required to develop and maintain documented lists of its external and internal issues, its relevant interested parties and their needs and expectations?

8. Does the organization have to identify at least one risk or opportunity that needs to be addressed, i.e. at least one potential adverse effect (threat) or beneficial effect (opportunity) that needs to be addressed?

9. Does ISO 14001:2015 require Life Cycle Assessments (LCAs) to be completed as part of the enhanced life cycle perspective requirements?

10. Does ISO 14001:2015 require the organization to apply a life cycle perspective when determining which of its environmental aspects are significant, i.e., in its criteria for determining significance?

11. In Clause 6.1.4.a.3, which “risks and opportunities” is an organization required to plan actions to address?

12. What is an outsourced process? Is every process or service obtained from an external provider an outsourced process?

13. If an organization does not have any outsourced processes, to what extent does clause 8.1 apply? Do the requirements in the paragraph starting “consistent with a life cycle perspective” only apply to outsourced processes?

14. Does the phrase, “consistent with a life cycle perspective’ in Clause 8.1, Operational Planning and Control mean than an organization needs to consider a life cycle perspective a second time, with regard to operational planning and control?

15. The operational control clause of ISO 14001:2004 (Clause 4.4.6) referred to identifying and planning those operations associated with significant environmental aspects. The operational planning and control clause of ISO

14001:2015 (Clause 8.1) refers to processes needed to meet environmental management system requirements. Does the revised standard still refer to control of the organization’s operational processes?

16. Does the requirement for internal audit (9.2) include a compliance or financial audit?

It is important to note that these interpretations do not change the requirements in ISO 14001:2015, but are intended to give users a better understanding of ISO 14001:2015.

If you are interested in having a 1.0 day “ISO 14001:2015 Requirements” course taught onsite at your facility, please send an email to larry@whittingtonassociates.com. You can view the course description by clicking on the course title above.