My last few audits have produced a number of interesting situations. I’d like to discuss one relating to the new standard and the scope of an EMS.
I recently audited a large consultancy business – the type which involves high level design work for major clients. The sort of work that helps improve the efficiency of F1 engines, jet engine design, submarine emergency release systems. The business is steadily growing in numbers and people work from several different offices around the UK. The scope of their certification to ISO 14001 includes aspects relating to travel, office building management, IT equipment, and associated activities. It doesn’t include project work for clients.
The organisation naturally wants to revise their management system to meet the requirements of ISO 14001:2015. The vexed question of the degree to which the new standard impacts on their management system has hindered their plans and created uncertainty.
The central issue focuses on the scope and whether it requires the company to consider project specific issues (which may vary according to each client’s work scope) or not.
ISO 14001 states:
When determining this scope, the organisation shall consider: its activities, products and services; its authority and ability to exercise control and influence
Within the defined scope of the environmental management system, the organisation shall determine the environmental aspects of its activities, products and services that it can control and those that it can influence, and their associated environmental impacts, considering a life cycle perspective.
So to be clear, the project work done by the company may require them to design a new and better exhaust system for a Formula 1 supercar. The client wants this done to improve fuel efficiency and speed – not for environmental reasons. So, the consultancy works to that brief but is required to meet specific legal requirements which ensure that the engine emissions meets environmental standards. That would happen even if the consultancy was not ISO 14001 certified.
The client does not require the consultancy to design the most environmentally friendly emission system, because that was not within the contract that was agreed between the client and the consultancy.
On the other hand, the consultancy’s EMS includes travel and office activities. It is therefore appropriate that the aspects arising within that scope be included. Matters relating to business travel, office chiller systems, heating and ventilation issues are all within scope and therefore require control and influence to improve environmental performance.
ISO 14001:2015 does not really change anything when determining the scope of the management system except for the need to take a life cycle perspective. The next blog will cover this topic, as it deserves special attention and focus.