Do you struggle to understand what is meant by the word “consider” & the phrase “take into account” used in ISO 14001:2015? This article could help you with your EMS…
An ISO Interpretation could help you understand the difference between these two concepts.
An ISO Interpretation could help you understand whether you are required to have access to ISO 14001:2015 for certification.
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 understanding of the word “consider” & phrase “take into account” within ISO 14001:2015, which was raised by the American National Standards Institute (ANSI).
The question asked was:
“In some places in the Standard, the organization is directed to take certain items into account, while in other places in the Standard, the organization is directed to “consider” certain items. Is there a difference?”
The Interpretation Response states:
ISO 14001 uses the word “consider” and the phrase “take into account” with a specific intent.
The word “consider” means it is necessary to think about the topic but it can be excluded; whereas “take into account” means it is necessary to think about the topic but it cannot be excluded.
The Interpretation Response gives two examples to help illustrate the differences:
The first example used relates to Clause 6.1.1. When planning its EMS, the organization shall consider the issues referred to in Section 4.1, “Understanding the organization’s context”. ISO 14001 requires the organization to think about these issues, but it does not necessarily have to address these issues in its EMS.
The second example relates to Clause 6.1.3, “Compliance obligations”, where the requirement is for the organisation to “take these compliance obligations into account when establishing, implementing, maintaining and continually improving its EMS, means the organization must address its compliance obligations in its EMS.
So, to summarise the ISO TC 207 Sub-Committee 1 interpretation clarifies that the word “consider” means it is necessary to think about the topic but it can be excluded; whereas phrase “take into account” means it is necessary to think about the topic but it cannot be excluded.
You can download a copy of the ISO Interpretation document here, which includes this specific interpretation.
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