The most misinterpreted elements or issues related to the ISO 14001 Standard are:

1. What records are required under the standard?

There are many instances where a company states, either verbally or in writing, that a certain task or activity is to be completed.  The fact that a task or activity is completed does not mean, in every case, that a formal record is required. It is up to the company to identify environmental records as appropriate to the EMS, and to demonstrate conformance to ISO 14001. Element 4.5.3 of the standard specifically states that records shall include training records and results of audits and reviews. The word “review” found under 4.5.3 implies that ‘records’ of reviews should be identified, maintained, and controlled  under the requirements set forth in 4.5.3. The clauses where “reviews” are applicable include 4.3.3, 4.4.1, 4.4.5, 4.4.7, and 4.6.

2. What equipment must be calibrated and what records must be kept?

The registrar should not require an organization to calibrate all measuring and monitoring equipment related to operational controls, objectives and targets, measuring and monitoring regulatory compliance, or other key characteristics of the organization. Monitoring and measurement equipment must be maintained and calibrated, if technologically feasible, solely in accordance with the organization’s procedures. However, if in the auditor’s judgment, the lack of calibration could lead to significant deviations from objectives and targets, regulatory compliance, or policy and/or lead to a potentially significant environmental impact(s), the organization must consider if calibration is feasible, and implement pertinent calibration procedures, as appropriate.

3. Must all elements of the EMS be addressed in an EMS manual?

An “EMS manual” is not a specific requirement of the ISO 14001 standard.  There must be information that describes the core elements of the EMS and their interaction which provides direction to related documentation. This documentation may be integrated with documentation of other management systems. It does not have to be in the form of a single manual.

4. Must the organization have EMP’s for all significant environmental aspects?

No. However, there must be at least one objective and target and EMP established related to the identified significant environmental aspects, and all significant aspects must be “controlled” in some manner.

5. How does the registrar judge the effectiveness of the identification of environmental aspects and the subsequent ranking process?

The process must be clear, comprehensive, logical and sound. A good test is that any auditor unfamiliar with the process should be able to generally reach the same conclusions without a significant amount of background information or detailed analysis. The process should be simple and direct. A DNV auditor may ask questions about why certain aspects received a particular ranking or why an activity was not identified, but their assessment is directed towards understanding the process. It is the sole responsibility of the organization to identify environmental aspects and their associated ranking.

6. How does the registrar audit regulatory compliance related aspects of the EMS?

DNV must follow requirements set forth in ANSI-ASQ ANAB National Accreditation Program Criteria for Bodies Operating Registration of Environmental Management Systems, also known as E 3.2. This document can be found on the ANAB website, www.anab.org. DNV is required to focus on the existence and implementation of the EMS which conforms to the ISO 14001 requirements. DNV must consider whether the organization’s EMS is planned and operated in a manner consistent with these requirements. Sufficient data (objective evidence) on the organization’s compliance with relevant legislation and regulations, gathered during the registration review and surveillances, are relevant and necessary to determine whether the organization’s EMS conforms to the standard. Objective evidence includes periodic evaluation of legal compliance and management reviews, regulatory noncompliance corrective and preventive action(s) and tracking, compliance records, relevant permits, and procedures related to operational controls and monitoring and measurement.

7. What happens if the auditor identifies a potential regulatory non-compliance?

A company may be certified or a particular audit is allowed to proceed despite observed legal noncompliances, provided that the DNV auditor is satisfied that the EMS has addressed such noncompliances and is taking corrective and preventive actions. Potential noncompliances are not recorded as a written nonconformance against the standard; however, they are reported verbally to the organization’s designated senior management representative, which is usually the ISO 14001 management representative or the facility manager.

8. What happens if the organization does not achieve an objective and target?

Provided the organization has identified that an objective and target will not be met and is taking corrective actions, simply not achieving an objective and target does not warrant a formal, written nonconformance against the standard. Objectives and targets may be modified or revised as necessary to ensure the effective implementation of the environmental management system.

9. Should all significant environmental aspects have documented operational control procedures?

No. All significant environmental aspects must be identified and controlled in some manner. Documented operational control procedures are required only for significant environmental aspects where the absence of documented procedures could lead to a deviation in policy, objectives and targets.

10. What should an organization measure and monitor and which of these should be     documented procedures?

As a minimum an organization must measure and monitor activities to track performance (including regulatory compliance and training), monitor and measure conformance to objectives and targets and relevant operational controls associated with identified significant environmental aspects or other key characteristics that the organization identifies. There must be documented measuring and monitoring procedures in all situations listed above, if feasible, where the absence of documented procedures could lead to deviation in policy, objectives and targets, regulatory noncompliance, or could lead to significant impact on the environment.

11. How long must the organization have the EMS implemented before it can be certified?

There is no specific requirement in the ISO 14001 standard regarding this matter. The EMS should be operational for a sufficient period of time to allow establishment of adequate objective evidence that the EMS is effective and will provide for regulatory compliance. DNV uses a rule-of-thumb that the EMS should be operational for at least three (3) months prior to the certification audit.

12. Does the organization need to have completed a “compliance audit” prior to the certification audit?

The ISO 14001 standard requires a “documented procedure for periodically evaluating compliance.” There is no specific requirement in the standard for the client organization to complete a “compliance audit” prior to the certification audit. In general, DNV shall require that the client organization complete an “evaluation of compliance,” which could include a “compliance audit,” prior to the certification audit. However, the number and type of significant aspects, the legal complexity of key characteristics, or the access to information about legal and other requirements, among other factors, may have an influence on the required comprehensiveness and detail of the organization’s “evaluation.” Therefore, DNV auditors must use good judgment and practical considerations when deciding if a detailed, “comprehensive evaluation of compliance” is necessary prior to the certification audit.