Many of our clients with environmental management systems (EMS) certified to ISO 14001:1996 will be aware that this standard is in the process of being revised. The Final Draft International Standard (FDIS) 14001:2004 was published in August and the publication of ISO 14001: 2004 is expected by the end of the year.

The publication of the FDIS in August means that the process of revision is now largely complete; the remaining amendments will relate to minor editorial changes only. The FDIS will then go to a final ballot.

The changes to the standard aim to make it more 'user-friendly' and clarify some of the requirements. It also brings some of the clauses in line with ISO 9001:2000.

A brief summary of how the changes may affect you are outlined below:

4.1 Scope - You will be required to define the scope of the EMS by describing what activities, products, operations and services are included in the EMS. You will also need to evaluate how your EMS meets the requirements of the standard, and ensure this is documented.

Definitions

• Auditor - this has been added to the list of definitions (it is the same as the one from ISO 9001:2000). You will need to ensure auditor competence is defined in your EMS and that your auditors satisfy this definition.
• Continual improvement - a minor change emphasising that this is a recurring process.
• Environmental management system audit - changes to the wording means that you need to check that you have clearly defined your audit criteria to include achieving both your policy and your objectives and that the audit is independent.
• Environmental performance - this is now aimed at ensuring that you can demonstrate improvement in the way you manage your environmental aspects (rather than the focus being on improving the management system).
• Prevention of pollution - pollution now includes 'creation, emissions and discharge of any type of pollutant'. You should make sure that the way you have defined pollution prevention in your policy and your EMS covers this clarified wording.

4.2 Policy - you need to ensure that your policy is consistent with the scope that you have defined and that it is appropriate to the nature, scale and environmental impacts of your 'activities, products AND services'. There is a minor change in the wording relating to 'legal requirements' and you should communicate your policy to all persons working for, or on behalf of the organisation (this will also include sub-contractors, temporary staff etc., not just employees).

4.3.1 Environmental aspects - a change in the text means that you now need to consider 'activities, products AND services' that you 'CAN influence' (rather than can be expected to influence). It also says you should take 'account of planned or new developments, new or modified activities, products and services'. You will have to ensure that significant environmental aspects are considered in developing, implementing and maintaining your EMS (not just in setting environmental objectives) and also considered in planning activities such as new or even changed activities.

4.3.2 Legal and other requirements - you will need to identify and have access to applicable legal requirements relating to your environmental aspects and other environmental requirements to which you subscribe and, as with clause 4.3.1 above, these will have to be considered when developing, implementing and maintaining your EMS.

4.4.1 Resources, roles, responsibility and authority - the title of the clause has been changed with the focus being on resources as well stating that management should 'ensure the availability of resources' essential for the implementation and control of the EMS rather than 'provide resources'. A change in the wording means that the management representative should now report their recommendations for improvement to top management.

4.4.2 Competence, training and awareness - your focus will be on ensuring that 'any person performing tasks' on your behalf that have the potential to cause a significant environmental impact is competent (rather than 'all personnel'). Again, this will therefore apply to contractors, sub-contractors, temporary staff etc. In addition there is now reference to 'records' in this clause which has wider implications than the previous wording of 'training records'.

4.4.3 Communication - if your organisation does communicate externally about its environmental aspects you will need to establish a method for this communication. It is likely that most organisations will communicate in some way therefore this will need to be considered.

4.4.4 Documentation - the requirements within this clause are in line with the clause on documentation in ISO 9001: 2000. Therefore the list of documentation that you are required to keep has been clarified to include:

• environmental policy, objectives and targets;
• a description of the main elements of the EMS and their interaction and reference to related documents;
• documents and records required by the standard;
• documents and records determined by the organisation to be necessary to ensure effective planning, operation and control processes that relate to your significant environmental aspects.

In practice it is likely that you already have this documentation, as you are currently required to 'describe the core elements of the management system and their interaction and provide direction to related documentation.'

4.4.5 Control of documents - this has also been changed in line with ISO 9001: 2000. The practicalities of the changes may mean that you need to review your procedures for document control.

4.5.2 Evaluation of compliance - this is a new clause but not a new requirement (this is currently found in 4.5.1.). This has been made into a separate clause to highlight the importance of this function and now clarifies the purpose of this clause as 'ensuring your organisation meets its commitment to compliance with legal requirements.'

• 4.5.2.1 - this will state that, consistent with your commitment to compliance in your policy, you should establish, implement and maintain a procedure for periodically evaluating your compliance with applicable legal requirements. You will also need to keep records of the results of these.
• 4.5.2.2 - You will also need to evaluate the compliance of your organisation with 'other requirements to which you subscribe' (such as codes of practice etc). You can either do this separately or combine it with your evaluation of compliance against legal requirements. Again you will need to keep records of this activity.

Note: as a new clause has been inserted, the subsequent clause numbers have changed.

4.5.3 Nonconformity, corrective and preventive actions - there are minor changes in wording for clarification purposes. You will therefore need to look at your current procedure to ensure that it complies (the new clause is very similar in wording to the clause in ISO9001:2000).

4.5.5 Internal audit - changes in the title of the clause from environmental management system audit now reflects ISO 9001:2000.

4.6 Management review - the wording has been aligned with ISO 9001:2000. Your management reviews will need to be conducted at 'planned intervals' rather than at 'intervals it determines'. This clause also outlines a more detailed list of inputs and outputs of your management review and you will need to ensure that your organisation's management review covers these.