Are you, an Environmental Auditor or a Senior Manager struggling to understand whether you may have to conduct your internal EMS audit on an annual basis & to cover all ISO 14001 requirements?
An ISO Interpretation could help you more fully understand whether internal audit must cover all ISO 14001:2015 requirements.
This article looks at one of the interpretations given by the ISO Technical Committee, TC 207 Sub-Committee 1, which is the Sub-Committee responsible for ISO 14001:2015 and other associated environmental International Standards.
The interpretation process operates as an escalation of an interpretation enquiry from a National Member Body, such as BSI in the UK and ANSI in the United States. All interpretation enquiries are reviewed on an annual basis and their results published on the Sub-Committee 1 website.
It is important to note that its interpretations do not change the requirements in ISO 14001:2015 but are intended to give users a better understanding on ISO 14001.
The question about internal audit was raised by the American National Standards Institute (ANSI) and relates to the intent of Clause 9.2.2. The question asked was:
A quick recap on Clause 9.2.2 in its first part shows that it has requirements for the organization shall establish, implement and maintain an internal audit programme, which shall include the frequency, methods, responsibilities, planning requirements and reporting of its internal audits.
Additionally, the internal audit programme shall take into consideration the environmental importance of the processes concerned, changes affecting the organization and the results of previous audits.
So, back to the answer to the question…
The interpretation response clarifies that the first part of the question referring to whether the EMS internal audit should be conducted on an annual basis has already be addressed in an earlier ISO interpretation. You can find out the answer to whether internal audits should be conducted on an annual basis in the the article: Are EMS Internal Audits required each year?
The second part of the question asks whether an internal EMS audit must cover all elements of ISO 14001 during the audit. The environmental management system audit program takes into consideration the environmental importance of the process concerned, changes affecting the organization, and the results of previous audits.
So, according to ISO 14001, in order to be comprehensive, the audit program embrace the audit criteria, scope, frequency and methods, as well as the responsibilities and requirements for planning and conducting audits, reporting results, and retaining associated documented information.
The interpretation then clarifies that ISO 14001 does not require that all elements of ISO 14001 be audited each and every time an audit is conducted, nor does it require that every single element be audited within a one-year period.
However, it goes on to explain that the internal audit program is required to be established with consideration of the various factors discussed earlier; related to the audit criteria, scope, frequency and methods, as well as the responsibilities and requirements for planning and conducting audits, reporting results, and retaining associated documented information.
It, further clarifies, the organization should consider the purpose of the audit, i.e., to determine whether or not the environmental management system conforms to, firstly, the organization’s own requirements for its environmental management system; secondly, the requirements of the International Standard, and whether or not the environmental management system has been effectively implemented and maintained.
The interpretation, finally, states that these factors should be considered by the organization in determining the necessity for auditing each element of ISO 14001 and at what frequency, such as annually, each and every time an audit is conducted, or over a period that exceeds one year.
So, to summarise:
The ISO TC 207 Sub-Committee 1 interpretation clarifies that there is no explicit requirement for all elements of ISO 14001 be audited each and every time an audit is conducted, nor does it require that every single element be audited within a one-year period.
However, the organisation will need to consider the purpose of the internal audit as well as the audit criteria, scope, frequency and methods, the responsibilities and requirements for planning and conducting audits, reporting results, and retaining associated documented information in coming to its determine the necessity for auditing each element of ISO 14001 & the frequency of the internal audit.
If this article has helped to advance your understanding of the internal audit requirements in ISO 14001:2015, you should start by download the ISO Interpretation document here
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