ISO 14001 2004 vs ISO 14001 1996

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

If you need a detailed and complete interpretation of the new
ISO 14001 2004 standard, please consider purchasing our
Title 50: ISO 14001 2004 Translated into Plain English.

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OTHER ISO 14001 WEB PAGES

Introduction to ISO 14001 2004 Environmental Management

Overview of ISO 14001 2004 Environmental Management

ISO 14001 2004 Plain English Environmental Management Definitions

ISO 14001 2004 Environmental Standard Translated into Plain English

How to Develop or Upgrade an Environmental Management System

ISO 14001 2004 Environmental Management Audit Program

Our Plain English ISO 14001 2004 Gap Analysis Tool

Our Plain English Approach to ISO 14001

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Updated on October 21, 2008. On the Web since May 25, 1997.