ISO 14001 2004 versus ISO 14001 1996

Both old and new standards expect you to define an environmental policy. However, the new standard asks you to think about the scope of your EMS while you define your policy.

The new standard also expects your environmental policy to state that you will comply with all applicable legal and other requirements that affect how you manage your environmental aspects. This new wording is more focused and narrower than the old wording. This is because the old standard talked about environmental legislation and regulations in general, while the new standard talks only about those legal requirements that influence how your environmental aspects should be handled.

Section 4.2 also adds the need to communicate the environmental policy to all persons who work for
or on behalf of your organization, not just your employees. Therefore, you need to make sure that your contractors also understand your policy.

While both ISO 14001 1996 and ISO 14001 2004 expect you to establish and maintain procedures to identify the environmental aspects of your activities, products, and services, the new standard makes it clear that this also means that you must implement (actually use) these procedures.

The new standard also says that these procedures should only be applied to those activities, products, and services that fall within the scope (boundary) of your environmental management system.

In addition, it says that it’s not good enough to just focus on the environmental aspect of existing activities, products, and services. You must also
focus on the activities, products, and services
that you plan to develop or modify in the future.

Finally, the new standard adds the need to document the environmental aspects of your activities, products, and services and to consider significant aspects when you set up your EMS.

Both old and new standards expect you to establish and maintain a procedure to identify and clarify the legal and other requirements that apply to your environmental aspects. Here again, the new standard wants you to not only establish and maintain a procedure, it also wants you to implement (use) it.

However, ISO 14001 2004 goes well beyond the
old standard because it explicitly asks you to use
this procedure to determine exactly how these
legal and other requirements apply to your environmental aspects. And once you have this information, the new standard expects you to
use it to design your EMS. None of this was
obvious in the old standard.

While both old and new standards stress the importance of competence, the new standard
makes it very clear that competence is the reason why training and awareness activities need to be carried out. It also makes it clear that competence and training records must now be kept. This record keeping requirement is new.

While both standards expect you to identify training needs, the old ISO 14001 1996 standard wasn’t very clear about what kind of needs should be considered. In order to address this important shortcoming, the new ISO 14001 standard now makes it clear that you need to identify the training needs associated with your environmental aspects and your EMS.

This section is almost entirely new. Only two things haven’t changed: the need to document the main elements (parts) of your EMS and how they interact, and the need to identify other documents that support or relate to your EMS.

New requirements include the need to document the scope of your EMS as well as your environmental policy, objectives, and targets. The new standard also expects you to develop or identify all of the documents and records that are needed in order to comply with the ISO 14001 2004 standard. These include process documents and records that are related to your organization’s significant environmental aspects.

According to the old standard, all you had to do
was establish and maintain procedures to identify
and respond to potential environmental emergency situations and accidents and to prevent or mitigate their environmental impact.

However, according to the new standard, procedures aren’t enough. You also have to actually use these procedures not only to respond to real emergencies and accidents but also to prevent or mitigate the adverse environmental impacts that emergencies
and accidents can cause.

The old standard wanted you to establish a procedure to define the responsibility and authority for handling nonconformities and taking corrective and preventive actions. Notice that it doesn’t explicitly tell you to take action; it tells you, instead, to assign responsibility
and authority.

Because of this shortcoming, the new standard
makes it clear that you not only need to establish
procedures but you also need to actually use
them to manage nonconformities, and take
corrective and preventive actions.

In fact, the new standard goes even further. It also expects you to investigate nonconformities, to determine their causes, to mitigate the environmental impact that nonconformities can have, and to record the results that you achieve.

While both old and new standards expect you to establish and maintain environmental records, the
old standard tells you what kinds of records you need to keep while the new standard talks more about what environmental records should be able to do. While the old standard tells you to maintain training, audit, and review records, the new one takes a more abstract approach.

The new standard, instead, tells you what your environmental records should be able to demonstrate. Section 4.5.4 of the new standard doesn’t tell you which records to keep. It instead says that your environmental records should be able to prove that your environmental management requirements are being met and that you comply with the ISO 14001 2004 standard.

While the old standard talked about environmental
management audits in general, the new one talks
about internal audits only. It also clarifies some
points and adds some new requirements.

While the old standard emphasized the need to develop audit programs and procedures, the new standard makes it clear that these programs and procedures must also be used. It makes it clear
that internal audits must actually be conducted.

And since the new focus is on actually doing audits, the new standard also expects you to keep records and to ensure that your internal auditors and your internal audits are both impartial and objective.

This section has been entirely reworked and
expanded in a big way. It now includes material
on management review inputs and outputs.

According to the new standard, management
review inputs should include audit results, changes
in your environmental aspects, communications
and complaints from external parties, legal changes, previous management reviews, the status of previous corrective and preventive actions, follow‑up actions, and recommendations for improvement.

The new standard also talks about management review outputs. In this context, outputs are decisions and actions. Outputs should include decisions and actions that change your environmental policy, objectives, or targets, and improve your organization’s EMS. In general, outputs should demonstrate your organization’s commitment to continual improvement.

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ISO 14001 2004 standard, please consider purchasing our
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OTHER ISO 14001 WEB PAGES

Introduction to ISO 14001 2004 Environmental Management

Overview of ISO 14001 2004 Environmental Management

ISO 14001 2004 Plain English Environmental Management Definitions

ISO 14001 2004 Environmental Standard Translated into Plain English

How to Develop or Upgrade an Environmental Management System

ISO 14001 2004 Environmental Management Audit Program

Our Plain English ISO 14001 2004 Gap Analysis Tool

Our Plain English Approach to ISO 14001