ISO 14000:2004 Key Changes

4.1
General Requirements

  New requirements to:

• Document, implement and continually improve the VEMS.
• Determine how the organization will fulfill the requirements of ISO 14001.
• Define and document the scope of the VEMS.

4.2
Environmental Policy

  New requirement to define the Policy within the scope of the VEMS.
Limitation of compliance commitment to those legal and other requirements related to the environmental aspects.
Policy must be communicated to others working in support of the organization, as well as to employees.  Alternate forms of communication, such as guidance on specific sections of the Policy could be used to communicate with contractors and others.

4.3.1
Environmental aspects

The aspects procedure must be implemented.
The requirement to identify aspects is limited to those within the scope of the VEMS.
A new requirement to include planned or new developments and activities within the aspects process (formerly under 4.3.4).
New requirement for documentation of the information from the aspects identification and significance determination processes.
Significant aspects are to be considered in establishing, implementing and maintaining the VEMS.

4.3.2
Legal and other requirements

The procedures must be implemented
New requirement to determine the applicability of legal/other requirements to environmental aspects.Ø      
New requirement to consider environmental legal and other requirements in development, implementation and maintenance of the full VEMS

4.3.3
Objectives, targets and programme(s) (formerly Objectives and targets)

Objectives and targets must be documented and implemented.
Objectives and targets should be measurable
Objectives and targets should be consistent with legal and other requirements.
Objectives and targets should be consistent with the commitment to continual improvement.Ø      
Text from 1996 element 4.3.4 Environmental management programme(s) has been moved to this element.

4.3.4
Environmental management programme(s)

The requirement to establish programs has been moved to 4.3.3 Objectives, targets and programme(s)
The final paragraph referencing new developments was moved to 4.3.1 Environmental aspects

4.4.1
Resources, roles, responsibility and authority (Formerly Structure and responsibility)

New requirement that management provide resources for establishing, implementing, maintaining and improving the VEMS.
Expands list of resources to include organizational infrastructure, as well as people, technology and dollars.
Management representative should include recommendations for improvement when reporting to top management on the performance of the VEMS.

4.4.2
Competence, training and awareness (Formerly Training, awareness and competence)

Requirements apply to persons working in support of the organization, not just to employees.  Contractors, volunteers etc. also must be competent to perform tasks associated with significant environmental impacts.
Records of training or other action must be kept to demonstrate everyone’s competence.
Specific requirement to identify training needs relevant to environmental aspects and the VEMS.
Awareness procedure must be implemented

4.4.3
Communication

Procedure should be implemented
New requirement to decide whether or not to communicate externally about significant aspects and to implement the external communication, if the answer is yes.

4.4.4
Documentation (Formerly Environmental management system documentation)

New requirement for documentation to include:

• The environmental policy, objectives and targets,
• Description of the scope of the VEMS
• Descriptions of elements of the VEMS including their interaction and references to related documents,
• Documents, including records, required by the Standard, and
• Documents, including records, needed to manage processes associated with significant aspects

4.4.5
Control of documents (formerly Document Control)

Identifies records as a special type of document requiring control.
Expands applicability to all documents required by the VEMS, as well as by the Standard
New requirement for identification and control of documents of external origin (e.g. permits) necessary to the VEMS

4.4.6
Operational Control

No significant changes.  Addition of the requirement to implement the procedure.
Subtle word change to communicate applicable procedures and requirements.

4.47
Emergency preparedness and response

No significant changes. Addition of the requirement to implement the procedure

4.5.1
Monitoring and Measurement

Change from recording information to track performance, which implies records of results achieved or activities already performed, to documenting information to monitor performance, which has more immediacy
Requirement that calibrated or verified equipment is used rather than that equipment shall be calibrated again implies immediacy.
The requirement for periodic evaluation of compliance with environmental legislation and regulations has been moved to the new element 4.5.2

4.5.2
Evaluation of compliance
(NEW ELEMENT)

Evaluation of compliance now includes both applicable legal requirements and other requirements to which an organization subscribes.
New requirement to keep records of these evaluation(s).

4.5.3
Nonconformity, corrective action and preventive action (Formerly 4.5.2 Nonconformance and corrective and preventive action)

This element clearly states requirements for:

• Implementing the procedure
• Investigation and determination of the causes of nonconformance to avoid recurrence.
• Evaluation of the need for actions to prevent occurrence/recurrence
• Records of the results of corrective and/or preventive actions
• Review of the effectiveness of the actions taken

4.5.4
Control of records (Formerly 4.5.3 Records)

New requirement for records to demonstrate results achieved, e.g., results of corrective action, programs to achieve objectives and targets etc.
No longer specifies training records, audit results and reviews. Explicit requirements for these records are incorporated into the appropriate element.
Broader interpretation of records required, including records to demonstrate conformity with the requirements of the VEMS.

4.5.5
Internal audit (Formerly 4.5.4 Environmental management system audit)

New emphasis on planning the schedule, procedures, conduct, reporting and record keeping for internal audits.
New responsibility for retaining records associated with the audit.
New responsibility for selecting auditors and conducting audits that ensure the objectivity and impartiality of the audit process.
Annex A references ISO 19011 guidance on auditing of VEMS.

4.6
Management Review

Specifies inputs to the management review process including:

• Results of internal audits and evaluations of compliance with legal and other requirements,
• Communication from external interested parties, including complaints,
• The environmental performance of the organization,
• The extent to which objectives and targets have been met,
• The status of preventive and corrective actions,
• Follow-up actions from previous management reviews,
• Changing circumstances including developments in legal and other requirements, and
• Recommendations for improvement.

Specifies outputs of the management review including decisions and actions regarding possible changes to:

• The environmental policy
• Objectives
• Targets
• Other elements of the VEMS