ISO 14001 2004 vs ISO 14001 1996

4 . 1 General requirements

4 . 2 Environmental policy

Both the old standard and the new one expect

you to establish and maintain an environmental
management s y s t e m ( E M S ) . However, the n e w
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.

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.

4.3.1 Environmental aspects

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 its 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.

4.3.2 Legal requirements

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.

4 . 3 . 3 Objectives and targets

4.4.1 Resources

4.4.2 Competence

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 youve achieved your
objectives and targets, the new standard also says
that your objectives and targets must be measurable.

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.

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 wasnt 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.

4.4.3 Communication

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.

4.4.4 Documentation

This section is almost entirely new. Only two things

havent 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 organizations significant
environmental aspects.

4.4.5 Document control

4.4.6 Operational control

Although the content of this section hasnt 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.

Except for the quality of the writing (its worse),

this section hasnt changed much. While the
old standard asks you to establish and maintain
procedures, the only thing thats different about
the new standard is the need to also
implement them.

4.4.7 Emergency response

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
arent 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.

4.5.1 Monitoring & measuring

4.5.2 Evaluation of
compliance

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.
Youre 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.

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.

4.5.3 Nonconformities

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 doesnt 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.

4.5.4 Control of records

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 doesnt 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.

4.5.5 Internal audit

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.

4.6 Management review

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. O u t p u t s 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
organizations commitment to continual improvement