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4.1
General requirements
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Both the old
standard and the new one expect
you to establish and maintain an
environmental
management
system (EMS).
However, the new
standard
also expects you to document your EMS and
to
continually improve
it. In addition, section 4.1 adds
the
need to define and document
the scope of the EMS. |
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4.2 Environmental policy
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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. |
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4.3.1
Environmental
aspects
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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. |
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4.3.2
Legal requirements
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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. |
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4.3.3 Objectives and targets
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Both
old and new standards expect you to establish
and maintain environmental objectives and
targets.
But the
new standard makes it very clear
that
objectives and targets are useless unless you also
try to implement or achieve them.
Since you need
to be able to tell whether you’ve achieved
your
objectives and targets, the new standard also says
that your objectives and targets must be measurable. |
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4.4.1
Resources
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While both old and
new versions of the standard
expect you to
provide the resources needed to
implement an EMS, the new
standard also expects
you to provide the resources needed to establish,
maintain,
and improve your EMS. |
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4.4.2
Competence
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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. |
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4.4.3
Communication
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The new ISO 14001
2004 standard expects you to
establish a method to communicate with
external
parties about your
significant environmental
aspects. This was not mentioned in the old
standard. However, if you have chosen not
to talk to outsiders about your environmental
aspects, you can ignore this requirement. |
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4.4.4
Documentation
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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. |
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4.4.5
Document control
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Although the
content of this section hasn’t changed
much, it has been
entirely reworked and some new
requirements have been added. New
requirements
include the need to identify changes that are made
to documents and
the need to control external
documents that influence the planning
and
operation of your EMS. |
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4.4.6
Operational control
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Except for the
quality of the writing (it’s
worse),
this section
hasn’t changed much. While the
old standard asks you to establish and maintain
procedures, the only thing that’s different
about
the new standard is the need to also
implement them. |
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4.4.7
Emergency response
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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. |
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4.5.1
Monitoring
&
measuring
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The old standard
expected you to calibrate and
maintain your monitoring equipment, but it
only
implied that you also needed
to actually use this
equipment. This oversight has now been
corrected.
You’re now
explicitly expected to actually use
calibrated or verified equipment
to monitor and
measure those key environmental characteristics
that have or could have a significant impact
on the environment. |
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4.5.2
Evaluation
of
compliance
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This
section is entirely new. It asks you to establish,
implement, and maintain
procedures to periodically
evaluate how well your organization complies
with all
relevant legal and other environmental requirements.
And it also
asks you to record the results of your
evaluations. |
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4.5.3
Nonconformities
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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. |
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4.5.4
Control of records
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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. |
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4.5.5
Internal audit
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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. |
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4.6
Management
review
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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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