What is the status of ISO 14001:2015 within an EMS?

Do you find it difficult to understand whether ISO 14001:2015 is a “compliance obligation” and document of external origin? This article could help you with your EMS…

Many Environmental Managers, Consultants and Auditors are unsure of the status of ISO 14001:2015 within an Environmental Management System (EMS) especially whether it is a “compliance obligation” or “documented information of external origin”?

An ISO Interpretation could help you understand how to apply these terms to your use of ISO 14001:2015.

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, with all interpretation enquiries 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 but are intended to give users a better understanding on ISO 14001.

The question about the status of ISO 14001:2015 within an Environmental Management System was raised by the American National Standards Institute (ANSI) and relates to the intent of Clauses 6.1.3, 7.5.3 & 3.2.9.

The question asked was:

“Is ISO 14001 Standard a “compliance obligation” under Clause 6.1.3 and also a document of external origin?”

The Interpretation Response gives an emphatic answer. Yes.

It restates that Clause 3.2.9, which defines the term “Compliance obligation” includes any “legal requirements (3.2.8) that an organization (3.1.4) has to comply with and other requirements that an organization has to or chooses to comply with”.

Additionally, Note 2 to Clause 3.2.9 confirms that compliance obligations can arise from mandatory requirements, such as applicable laws and regulations, or voluntary commitments, such as organizational and industry standards, contractual relationships, codes of practice and agreements with community groups or non-governmental organizations.

In terms of the second issue, ISO 14001:2015 is documented information of external origin as provided in Clause 7.5.3  as the organization cannot update it on its own. The Technical Committee, through ISO, issues revisions to ISO 14001.

So, to summarise the ISO TC 207 Sub-Committee 1 interpretation clarifies that ISO 14001:2015 is both, a “Compliance Obligation” and documented information of external origin.

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

I hope that this article has helped to advance your understanding of the status of ISO 14001:2015 within your Environmental Management System. Please leave a comment in the box below, if this article has help you.

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